Transcripts For CSPAN2 Key Capitol Hill Hearings 20240622 :

okay, this is significance of what employees can do, not what they're considering doing in 2016. one of the reasons we do the survey in time frame that we do it. karen and i will be tag-teaming this presentation this morning. i will walk you through major findings in the survey an observations about those. karen will come up to talk about key tactics employers will introduce in 2016 to manage health care costs. i will talk about implications for employees during annual enrollment. then we'll go to q&a. first brief about a national business group on health. only nation's non-profit organizations that works with employers and devoted to working with employers on national health care policy issues. working with them to optimize business employment through health care improvement and health care management. we have roughly 425 members. these are primarily large companies. they, 71 of the fortune 100 and they provide health coverage for over 50 million employees, dependents and retirees. so a bit about the survey. the survey is a survey mostly of large employers. we have 140 respondents in the survey. it cuts across all industry sectors and it is predominantly large employers. more than 70% of the participants in the survey have 10,000 employees or more. nearly 50% of the survey participant have 25,000 employees or more. so these are big companies. these are companies that are typically self-insured, meaning that they pay claims out of their general assets, and they contract with health insurers and other third parties to ajudicate claims, to administer plans, to leverage their provider networks and provide medical management services but claims are paid out of general assets of these companies. so key takeaways of the survey. i think the first takeaway that health care costs are expected to increase in 2016 at rate of five% after companies implement certain changes they're making to their health plans. that's consistent what we've seen over the last several years. while 5% may sound like a modest increase, it is still from an employ every perspective an unacceptable rate of increase. it is still two times the rate of general inflation. when you think about what a five% increase means to say a company that spend half a billion dollars on health care. that is $25 million of additional health care costs for next year. $25 million translates into possibly between 100 million and 300 million of additional revenue that a company has to generate just to offset the increase in health care, depending if they're in high margin business or if they're in a low-margin business. when you factor in whether a business is within a growth cycle or a low growth cycle, they may have to take other steps. they may have to increase price. they may have to affect jobs. they may have to, they may have to, impact the amount of wage increase that they provide for employees. even 5% increase in health care costs is a significant burden or headwind for an employer as they look to go into the upcoming year. some of the key drivers of health care costs consistently every year we see high-cost claims as being one of top drivers of medical costs and that is really not a surprise. what is a surprise specialty pharmacy has moving up for these companies as number two driver for medical for them as they look into 2016. and what's significant about that, es specialty pharmacy affects 3% of the population. in a situation where we have specialty pharmacy trend running in double-digit. by 2018, specialty pharmacy will exceed traditional pharmacy in terms of how much it costs a company year in, year out. one of the things we did this survey is when we asked employers about the excise tax, the excise tax is scheduled to go into effect in 2018. and we asked employers when they would hit the excise tax if they weren't making any additional changes? the interesting feedback we to e got from that question, nearly half the employers in the survey at least one of their plans will trigger the excise tax in 2012 when it goes into effect. in 2020, over 70% of the companies would trigger the excise tax. have at least one plan that would trigger the excise tax and the interesting thing about the data, when we went out to 2028, which would be 10 years of the excise tax being in effect, nearly all plans would trigger the excise tax by 2028. so the excise tax in terms of way it is structured is more of a tax on all plans as opposed to cadillac, called cadillac tax on rich plans. . . we expected to see a similar type of jumping this year survey, and we didn't see that. we only saw another additional 1% of companies moving to full replacement or only option consumer adjusted health plan for 2016. when we step back and understand what's going on with that, from my perspective i think what we see is a number of companies who prefer not to go to consumer directed plans as the only option and taking a wait and see approach. we are seeing the calm before the storm. companies are looking see what's going on in washington and the season energy around possibly repealing excise tax and taking a wait-and-see approach. excise tax is repealed by data showing us 26% of companies will look to implement consumer directed plans as the an option in 2017. this year will be a quieter year from a plan change perspective as we go into 2016 as companies look to see whether not excise tax will be repealed, if it hasn't we will see another rush to replace the high deductible plans i believe in 2017. some of the other tactics companies are deploying to mitigate the impact of the cadillac attacks or to minimize or delay the impact of catlike tax is a continued investment in consumerism, continued investment in decision support, transparency tools, navigation tools to of employers make decisions, continued investment in wellness and welding initiatives and incentives around engagement. we are seeing some activity around spousal surcharges. if a spouse has coverage through their own employer, looking to move them to get coverage under their own employer which would reduce the company's cost as relates to the excise tax. we are beginning to see as you look into the future and interest in delivered system reform. narrow networks and centers of excellence as a way to control cost down the road. as we think about the impact on employees, and i'll stop there and send to to karen, as well as the annual enrollments, annual enrollment we expect it will be fewer planned disruptions, modest increase around 5% similar to what large companies are experiencing. and we'll talk a little bit at the end about what employees can do during enrollment to maximize their benefits. so, karen. >> thank you, brian. brian sort of already stated employers are expecting an increase in 5% next year. as we surveyed large employers we wanted to see what tactics they are using to control costs but also to help employees with healthier lives as well as navigate the health care system. what we found this attacks is to into three groups. those things that are on the rise which include aggressive management a include aggressive management of specialty pharmacy costs, implementation of telehealth, an option for employees with acute illnesses to connect with physicians via phone or video. more focus on employee advocacy tools, help with claims services as well as optimizing delivery system as brian mentioned around accountable care organization. we also saw some tactics decline or interest in a certain tactics decline around disease management programs, condition management programs. although we know one of the drivers of health care costs are chronic conditions, these programs where in place connect with nurse telephonically do not seem to the impact that employers had hoped for. in addition interest in private exchanges seems to be on the decline as well. then there's a pocket of tactics that would call holding steady which means they are continue to be a tactic that employers are using but they're not growing. brian taught to look at the consumer directed health plans. that's one of the tactics that seems to be holding steady. we have about 83% of employers indicating they offer at least an option. one of the interesting things although we are not seeing a lot of employers more employers going to consumer directed health plans, those that do offer them are investing more heavily in terms of helping employees with their health savings accounts. so health savings account is a vehicle by which employees can save money to pay for cost when it not met her deductible. last year we saw that an employee could earn a maximum of $600 from their employer for the health savings account that number jumped to 750 this year. in addition we have seen other tactics around cost-sharing. traditionally over the last silver years employers have struggled with these increasing costs and look to increase not only as committee of the fibers and increasing health care costs everyone's premium goes up simply because costs are more expensive but employers have shifted additional cost by increasing the percentage that employers pay. this year we did not sit a lot of employers think we will shift more costs to the employed. we had about one in three employers indicate they would make small increases into the mount the employers are going to pay for the health care. we had fewer employers, about 25%, indicated they would increase the deductible that employees would face. so from an employee perspective is probably not significant changes. brian will speak more to that later. while employers are not maybe changing their plan offerings and not making substantial increases in cost-sharing, one of the things they're doing is aggressively managing specialty pharmacy costs. brian opry spoke to the fact it's a major driver of the cost. especially the last 18 months as new medication for hepatitis b have come out. they've seen their costs skyrocket. although they have numerous tactics and some of them are ones which are usually see us on all medications such as therapy, if he is one medication before you go to the more expensive one. we have seen the look to other tactics especially targeted to specialty pharmaceuticals. these medications are complicated, require special delivery, significant side effects, require monitoring by clinicians. so employers have looked in the specialty pharmaceuticals through a specialty pharmacy. either a freestanding entity or one that's connected with their pharmacy benefit management company so that the medications are being monitored so you ensure the right medication gets to the right patient. not only is that happening but there's high touch care management, meaning that you were spend the time to make sure the employed understand what the medication is for, the fact that a particular disease, have to take the medication, and also go to report back if they have a problem not to just simply stop the medication. beyond those plans designed efforts that are numerous programs that employers are offering employees to help them. specifically i've already mentioned they have traditionally offered disease management, care management programs to employees as a way to help people with diabetes or heart disease, better manage their condition. they have struggled a bit with that in terms of getting employees to engage with nurses telephonically and we've seen a decline in terms of employers deciding that's the way to help these employees with their character instead of their focusing more on things like medical decision support services so that second opinion service every physician says you need back surgery, offering services for another position reviews that. we all know when a doctor tells us we should go and have a surgery, we should get a second opinion. but for most consumers are busy taking the time to find another position and go to the office and have that second thing isn't something that always happens. these services all committed electronically and on the phone so provides employees with additional data so that they could make better decisions. in addition we've seen some interest in about a third of people surveyed indicated they implement what's known as high touch concierge services. as an employee you might get a new insurance card and you call and say i need an insurance card and the person on the phone would be more than happy to help you but in addition to ask what you need an insurance card but i need to see a physician. can help you find a position? well conditioned you have, extra steps of helping them navigate the health care system. one area that we've seen significant growth that's on the rise as i said it's about telehealth. was a few years ago employers really look for additional ways to help employees with acute illnesses the maybe can't get to the physician's office during their office hours. these are people who may end up in emergency room or in an urgent care facility, both of which can be somewhat expensive. telehealth is an opportunity for employees to to call or video conference with a physician, to get help with an acute situation. last year we had about 40% of large employers offer telehealth. issue is so significant increase to 74%. they either directly contract with immunity that is able to provide a physician on call, or they are doing to their health plan. another area but there's a lot of interest in but we haven't seen a lot of huge movement yet is around these accountabl accoe organizations. this is about improving the supply side of health care. so the idea that we need to ensure that employees get the right care when they need it but the idea is to get the care and integrated delivery system such as accountable care organization. employers have a lot of interest in understand how these things are working, provided throughout the country connected together to greet these the capital care organizations but this year new for us this year we ask in 2016 are you going to actively pursuing some kind of strategy around accountable care organizations. what we found is about 20% are saying yes, we are going to either directly contract with accountable care organizations or we will be working very closely with our health plan to ensure our employees get access to them. 60% said our health plan probably has accountable care organizations but it's not something we're looking into at this point. i think that really gets at the issue of what these accountable care organizations really be able to deliver change their health care system, and will they really help to impact appropriate care, reduce unnecessary care, and improve, and control health care costs? what we are not seeing significant growth in for 2016 is up and private exchanges. private exchanges came out a few years ago, and we have a lot of our members were interested in understanding whether they should move back to the employed population to a private exchange. we seek about 3% this year will have the employed in a private exchange. that hasn't changed significantly from year to year. what we did see drop was laughter we had about 35% of our employees saying we are evaluating them for the next few years. maybe we'll move in a few years and the shoe is on the drop to 24%. i think a lot of employers can, large employers feel that the private exchange is not the right vehicle for them at this time. for the active employees i should say. because for their retirees we are seeing significant movement. employers who still have come to provide health coverage for their retirees, we've seen a jump. and 2013, 10% have moved their retirees. that number has increased to 24% for 2016. lastly before i turn it back to brian, we serve it out employers to ask them as you look to 2016 and beyond, where are you focusing in terms of behaviors of employees? with so many ways you can impact their health, impact on to receive health care, where are you focusing efforts for next year. we saw the top behaviors are similar to last year. the top one being consumer engagement in health care decision-making. having employees make smart decisions about their health care. in addition to that the second and third top behaviors their focusing on are those things that greatly impact the prevalence of chronic disease and health care costs per capita increasing physical like to be and weight management. at this point in going to turn it back over to brian. >> thanks, care to the question is what does this mean for employees during annual enrollment? when you think about changes, there are not a lot of changes. do not see the same type of plant disruption for next year. you are not going to see the same type of plan design changed in the past. increases seem to be small and modest for the most part from a contribution perspective. the opportunity for employees on the tools and resources that employers are government to help maximize the benefits until they make decisions. telehealth for example, or decision support tools or transparency, or in the case of wellness programs, the opportunity to engage to get incentives and a lot of compass of puttin putting money into heh savings account. care and talk about the increasing on average or median being $750 per employee. into health savings account. employers have the opportunity to put their own money into health savings account and maximize their benefits. the opportunity unlike last year, flashes a significant amount of change, it's not so much by the change in japan as it is the opportunity to maximize your benefits and to leverage the tools and resources that a company is providing you to engage and to make the best decisions for yourself. so with that were opened up to questions. yes? >> do you anticipate your members are going to pay the cadillac tax in 2018? >> that would be a mixed bag. i think you have some companies, each comprehensive thing different at the time to think it's a mixed bag you see some companies that will pay it but a lot of companies will not fit or they will share the cost with their employees. >> the irs has affirmed both employer and employee contribution hsa will fall under the excise tax threshold. do you see any movement, you talked about increases in hsa and contribution but will that be a mitigating factor as we approach 18? >> there will be. the interesting thing is in the meantime we continue to see money flow into health savings account's anti-bush continue to contributcontribut e to increase their contributions to savings accounts. you're right it will be a factor into determine whether not you get the thresher or don't have the threshold that could come into play in terms of employers reducing those contributions down the road. other questions? yes. >> you said you're not seeing a lot of disruption and big changes in plans and yet you are also seen companies expressing a lot of them thinking they're going to hit the excise tax in 20 teen or leased by 2020. seems like there's a disconnect. in terms of why they aren't reacting to avoid that you have any thoughts on why that might be? >> i think the companies, there's been a lot of movement over the last several years to consumer directed health plans, so big movement, significant last year for full replacement or only option. i think they are number of companies that would prefer not to go that route and so they sought a way to to do it before 2018. yosi a russian 2017. that's what i expect and that's what the survey data tells us as well. they are waiting to something will happen, energy, th a compay bills in congress right now in the house, one that has bipartisan support and they're waiting to see if something happens and it does get repeal. then they probably will not move in that direction but if it does if it does go into effect i think you'll see a big move with a lot of activity next year. yes? >> can you be a little bit more precise about what they think will be the successful strategies employed by companies that wish to avoid the excise tax? and can you give us an idea how long they can hold it off? >> sure. the interesting thing when you look at the companies that do the best job at managing their trend, it's not any one thing, it's everything. obviously, moving to consumer tract health plan is one of the bigger opportunities to minimize or defer the impact of the cadillac tax. but it's become a nation of everything employers are doing from investing in wellness, involving two investing in decision support, and consumerism, the specialty pharmacy management, to condition management. it's the companies that consistently run between zero and 2% a year in terms of trend have done just about everything that they can do to affect both help improve and health care management. we asked in the survey to what extent do they believe that initiatives could delay the impact of the cadillac tax. and for their plans with the most enrollment they feel that the best they can do is divide it by two years. -- is delay it by two years. other questions? yes? >> -- haven't gotten to it but what proportion of, you differentiate in the survey between at least one plant and the largest plan, right speak was yes. >> so what proportion of companies in your survey are going to get the excise tax? about half? >> about half believe you hit it when it doesn't affect in 2018 for one of their plans. and i think by 2020 half of them still able to get it for their largest plan. and so you can see that one plant comes earlier and then eventually it affects all of the plans as we continue to move down the road. >> thank you. >> and you will see in the materials that were sent out, for a couple of different drafts -- grasp that the ship when the companies will get and what timing of that will be. speed and you talked about the price of drugs which is going to increase even more with high-cost electoral drugs, onto the market. beside these programs, what other ways are companies looking to avoid, taken to mitigate impact of these high-cost drug? >> i think it gets to the focus on specialty pharmacy management, really being a core focus. in other words, there are a number of elements to the. for example, if you to a prior authorization to ensure only people in need of medication get the medication. that's the first step. while you have that employed and you're looking at was the most appropriate site of care for the person to receive the medication. when you get a sense of transparency on specialty pharmacy medication there is and dedicate variation in price within a site of care, many within physician office visits, or outpatient facilities. you can see a four x. or seven ask difference in terms of where to go to receive the medication. and you also see a significant difference between an outpatient facility and physician's office. so it's trying to identify what's the most appropriate site of care, physicians office even as a home or outpatient facility. and then within that site of care what is the most efficient, with those efficient price? you see a wide range of price within sight of care. i think that would be a big focus. you see an acerbic significant increase in sight of care management initiative. that's because for the first time over the last couple of years we are getting transparency, these things cost when they are delivered in areas of sites of care were employees never have visibility to the data in the past. so those are two areas, prior authorization, site of care management and i think i'll overall coordination of care of that individual the on getting the specialty drug and reaching back out to the rest of that individuals immunity of providers to make of everything is being coordinated. just real quick follow. you think a lot of employers are going to stop providing these types of specialty drugs if the costs continue on their current trajectory? >> i don't believe employers will stop providing. many of you special drugs are good. some of them, actually many of them are very good. it's really tightened managed to ensure that the right people get them, that they're compliant that you can do program around them, ashley get the right dosage so there's no waste. and we manage them effectively. now, some of them are challenging from a cost perspective and i think our efforts to go for like of a better term, kicked around different reimbursement models. are there other ways to reimburse that wouldn't be such a burden in a particular year for a particular drug? so think there's efforts to get to the ways of reversing and paying for these, but the end of the day if you have a drug that is secure, that's a good thing to george mitchell right people get it and you want to make sure that it's affordable and in place will continue work with health plans and prescription benefit manager and the pharmaceutical industry to see how we can best leverage that. there is concern about how they are trending and will be turning over the next several years. -- trending over the next several years. >> any other questions? [inaudible] -- for the hepatitis c drugs? that's a fast changing market. last year we had, everybody was talking about it and it's now kind of like yesterday's news. any insight from the survey on the? >> they didn't focus specifically on any drug. we really focus more on the category of specialty pharmacy, try to get a sense of al-qaeda's training and no employers are going to manage and focus on managing the overall category, nonspecific drugs like couldn't tell you on that particular question. >> great. number question i would like to thank you all for your attendance and participation. and egypt questions follow up material we provide, please do not hesitate to contact us. thank you. [inaudible conversations] >> a little later today here on c-span2, outgoing army chief of staff ray odierno, his last as the army's top general is friday and today at 1 p.m. eastern he gives his final news conference at the pentagon. that's lying here on c-span2. later on c-span2, a look back at the voting rights act which was signed into law 50 years ago. >> booktv continued in prime time here on c-span2. >> with the senate in its august break we'll future booktv programming weeknights prime time on c-span2. >> the environmental protection agency yesterday announced they will begin to regulate greenhouse gas emissions from airplanes because of the nation's endanger human health by contributing to climate change. the epa announced it will develop rules to limit airplane emissions as the agency is done with cars and power plans. yesterday's public hearing at epa headquarters in washington was two hours. >> good morning. on the director of the climate change division at the u.s. department of protection agency. no, half of the epa at the office of british i would like to welcome you to today's public hearing. thank you for taking time to come up or does the acumen take with us today. as you all know just to be clear that of today's erie is proposed fines, the greenhouse gas emissions for aircraft, cozza can ship it to air pollution, reasonably be anticipated to endanger public health and welfare and advance notice of proposed rulemaking. i like to can think of all for coming today. what mr. but using my fellow panel members. start down to the far left please stop about. >> bill charmley, director of the standards division. >> brian manning from the large marine and aviation center. >> leslie riegle. >> thank you. just to reiterate the purpose of hearing today is to receive comments from all interested parties on the proposed endangerment finding and advance notice of proposed rulemaking. this action as many of you know was published in the federal register on july 1, 2015. in this action the administration proposed to determine that greenhouse gas concentrations in the atmosphere and into the public health and welfare of current and future generations within the meaning of section 231 a of the clean air act. in addition to administrative proposing to find greenhouse gas emissions from certain classes of engines use primarily in commercial aircraft are contributing to the mix of the greenhouse gas air pollution in our atmosphere. today's hearing provides interested persons the opportunity for oral presentation and used in arguments. witnesses will be allowed to make oral statement which stimulate expand on in writing for the record. when you're finished with your comments members may ask clarifying questions. however, this hearing is not intend to be a discussion of the proposed findings or the advanced notice of rulemaking. we might ask questions or request additional data, we will not respond to comments in this forum. instead we ask please provide written comments as part of the record in finalizing this proposal. if any members of the audience today wish to test i have not already signed up, please imagine in at the registration table i got the entrance of the room. about attending today should sign the recall is a fourth or not he was scheduled to testify. finally, before i turn to my colleague, bill, but remind everyone in addition to today's hearing is also an opportunity to send us written comments. commentary close on august 31, 2015 at 11:59 p.m. eastern time. details on where to submit written comments can be found in the federal register a notice as well as on our website. so with that as introduction let me turn it over to bill. >> thank you, paul. good morning. concurrent with these proposed findings on july 1, 2015, epa also issued an advance notice of proposed rulemaking referred to as anpr to write additional information on the process for such an aircraft engine greenhouse gas standard under section 231 of the clean air act it should epa issued positive final engagement contribution findings under section 231. the npr largely focuses on recent efforts to set international co2 emissions standard for aircraft at the international civil aviation organization, icao. and how those efforts may inform epa's future action. is advance notice describes and seeks input on issues related to setting international sea to stand for aircraft and the potential use of section 231 of the clean air act to adopt and implement possibly correspond international engine aircraft engines you to organize gas emission standards domestically. this standard is expected adopted by icao in early 2016. epa has requesting, a number of issues related to setting this youtube stand for aircraft and these include appropriate and effective dates for potential standards, the appropriate stringency love for a standard and whether standard should apply to new production aircraft as well as new type of aircraft. let me go over how we be conducting today's hearing. we are conducting this hearing under section 307 of the clean air act to provide interested persons and opportunity for oral presentation in addition to written submissions on the proposed findings. we are having a searing recorded in the transcript will be available public inspection and copying nepa is air pocket number epa hq 08 our 20140828. the transcript to be available electronically and epa's website and on the regulations.gov website and the same docket number. the official record of this hearing will be kept open for 30 days after today to provide opportunity to submit rebuttal. you may submit this additional testimony to the same docket for this action by using one of the methods described in the federal register a notice announcing the proposal. this hearing will be conducted in formally and formal rules of evidence will not apply. paul and to be served as co-presented officers and as such were authorized to apply reasonable limit on the duration of the statements of any witness. each person we given no more than 10 minutes to provide his or her verbal testimony. paul and i then asked, vast epa personnel to serve as timekeepers, so reckon you. to keep close track of testimony time. the timekeeper would indicate when you have five minutes left and also and have one minute left and when your time is finished. please be courteous to those who followed you and keep your comments to know more than 10 minutes. we'll be using a grid format for today's testimony. three individual patty, because up to the testify at a table in the front. if you're not done so please check in at the registration desk for your group number of symantec when you hear your name or your group number called please make your way to the table are fighting for to be prepared to provide your testimony in succession. witnesses must state your name and affiliation prior to making your statement. please speak slowly and clic cld to our court recorder can record accurately. in order to streamline the process members should be in the room and advanced by the projected krypton and should be prepared to make the way to the front of the rim of the previous members are giving their testimony. and depend on the number of testify there's we may end up taking a break during the day. finally what if they represent a if they represent a speak and it will attempt to a should ask of any description we provide our discussion of the proposal in npr the official version of the proposal that is published on july 1 of 2015 at the controls in the case of conflicts between it and what you make your today. please refer to the official version when developing your written comments on the proposal or on the npr. thank you and with it would like to call the first group of witnesses to speak in this quarter. doctor nic lutsey, nancy young from airlines for america, and nancy kruger from the national association of clean air agencies. thank you. [inaudible conversations] >> good morning. thanks for the opportunity to give these remarks. my name is nic lutsey, i'm a program director at the international council on clean transportation. we are an independent nonprofit organization founded to provide a first rate i'm biased research and technical analysis to environmental regulators. we appreciate the opportunity to provide his testimony on epa's aviation finding an advance notice of proposed rulemaking on aviation greenhouse gas emissions. our comments are informed that engagement of icct staff environmental working group's to the international civil aviation organization, or icao since 2008. in particular since 2009 we contributed technical analysis efforts to build the international carbon dioxide, or co2 standard that is referenced heavily within the report. power, to focus on the following points. first the scope of endangerment finding, second the applicability, time and strangers of an international or domestic co2 emissions standards. and third potential domestic reporting requirements for aviation manufacturers under the clean air act. epa has proposed the engagement findings focus on six key greenhouse gases. we concur with hi is the general approach with caveats. we agree with epa the assessment scientific uncertainties on the climate impact of nitrogen oxides and water vapor emitted at altitude remain high enough so as not to address them in this initial engagement finding. asides regarding the contribution of black carbon to climate change on the other hand, is clear. black carbon was identified as a second most important contributor to emissions in 2013. reflect delays inside epa should consider incorporating black carbon in its final aviation endangerment finding. also while we do not support integrating crude nox under the engagement finding epa should consider expanding its existing nox reporting requirement for aircraft, engine manufacturers from older land and takeoff emissions. to include crude emissions. icao has outlined two general approaches for the applicability of international co2 emission standard and the first approach only new aircraft designs things-certified for the first time be required to comply. in the second, that all new aircraft delivered after a certain date, that is both new design and new in production aircraft would need to pass. based upon analysis, covering all of aircraft delivered after a certain date will be necessary for the standard is a difficult reduce emissions beyond business as usual. since nato aircraft are rare, our analysis suggests a new type only standard beginning in 2020 would only cover about 5% of the global fleet in 2030. as opposed to requirement after affecting all new aircraft which could cover half of the global seed of that year. furthermore, we do not expect a new type only standard to reduce emissions below business as usual because of the definition that icao has chosen of technological feasibility. in 2013 i can't decide only technology is widely available for deployment in 2016 across multiple aircraft types will be considered in establishing stringency. a standard implemented in 2020 for new applications for type certification will affect aircraft types of century and a service of 2024 or later due to the time required for certification. this time lag combined with the decision that most of the standards to require state-of-the-art 2016 technologies when implemented means even the most aggressive standard will lack the fuel efficiency new type aircraft when entry into service. for these reasons we conclude that covering all new aircraft will be required to meet the purpose of the standard to reduce emissions beyond business as usual. on stringency we believe that an international and/or domestic co2 standards should be set to require at least state-of-the-art 2016 technologies for new aircraft types certified after the standard takes effect. icao is investigating a tiered approach under which deliveries of new and production aircraft or models that are type certified before the standard takes effect they have separate target applied to them. pending additional analysis, and/or stringency level may be appropriate for those types but still within the highest three levels identified by epa. on time you know to minimize the number of years that a new type regulatory level lags business as usual aircraft, the standard should be applied for new types as early as possible. in this case 2020. early implementation for new in production aircraft even in 2020, 2023 is also preferable. finally since current discussions on international in mission standards assume a static stringency level it would be appropriate for the u.s. to press for early icao review of any international co2 standards starting in 2019 so that the updated requirements are in place to drive additional technology to government beyond 2020. regarding many reporting requirements we recommend that epa consider adopting a domestic reporting requirement for crude co2 and nox under the clean air act. icao is considering for development of a voluntary database for co2 only. we believe detailed mandatory reporting is necessary to ensure transparency and a little plainfield across manufacturers. finally, as noted before we believe a collection of crude nox get domestically would help improve our understanding of the climate impact of aviation nox a mission. eba would need to analyze the cost and complexity of developing measurement and reporting protocols for crude knocks if it decides to pursue this approach are more detailed comments will be submitted to epa in writing in addition to submit an update for the 2009 study referenced in the anpr in and titled efficiency transfer new commercial jet aircraft to the public docket. the two studies together highlight the importance of a meaningful co2 emission standard to the u.s. aviation greenhouse gas emissions reduction plan. thank you for the opportunity to comment today and for epa's continued work on this important topic. >> my name is nancy young. i'm the vice president of environmental affairs or airlines for america, representing the major passenger and cargo airlines in the united states. we appreciated this opportunity to testify regarding epa's proposed fines on aircraft greenhouse gas emissions, and advance notice of proposed rulemaking. as the record of our members to demonstrate we take our role in controlling greenhouse gas emissions very seriously. for the past several decades u.s. airlines have dramatically improved the efficiency and reduce carbon dioxide emissions by investing billions in fuel saving aircraft and engines, innovative technologies like when let's and cutting edge route optimization software. as a result of the u.s. airlines comprise 5% of u.s. economic activity, that account for only 2% of the greenhouse gas emissions inventory. the industry improve fuel efficiency 120% since 1978. further the u.s. airline carried a 20% more passengers and cargo in 2014 than they did in 2000, while the meeting 8% less carbon dioxide -- despite the industry's strong record to date, however, we are not stopping there. the u.s. airlines are active participants in a global aviation coalition that is committed to 1.5% annual average fuel efficiency improvements through 2020, and carbon-neutral growth from 2020 subject to critical aviation infrastructure and technology advances achieved by government and industry. our members are keenly focused on these advances both at the national and international levels. for example, the u.s. airlines are partnering to modernize the air traffic management system and to reinvigorate research and develop it in aviation environmental technology. in addition we are dedicated to developing commercially viable sustainable alternative aviation fuel which could further reduce aviation's greenhouse gas emissions while enhancing u.s. energy independence and security. we are accounting of other commercial -- the public-private partnership with faa and other stakeholders that is working on the development and deployment such fuels. having helped by the necessary technical groundwork, our members have already begun to use bio jet fuel on commercial flights. further our industry coalition in supporting the development of a global carbon emissions offset mechanism that could be used to fill the gap should concerted industry and government investment in technology, operations and infrastructure measures, otherwise not allow us to achieve our goals of carbon-neutral growth from 2020. it's against this backdrop that kind of other welcomes the opportunity to submit a full set of comments on epa's proposed findings and anpr by the august 31, deadline. for purposes of this hearing, a4a offers five preliminary observations. first, dashed over for the agency limit its engagement and cause or contribute findings to the six well next long lived greenhouse gas emissions. icba points out in its proposal, aircraft only emit two of those six emissions. 99% of which is carbon dioxide. as carbon dioxide is directly related to fuel burn and with jet fuel thousand and one cost for commercial airlines, a4a members already have a powerful incentive to continue to reduce co2 output. second, a4a urges epa to keep our industry strong fuel efficiency record relatively greenhouse gas emissions contribution and global sector of approach commitment squarely in mind as the agency proceeds. indeed, commercial aviation accounts for 2% of the nation's greenhouse gas emissions inventory, while the sources epa previously have sought to cover with greenhouse gas emissions regulations on road motor vehicles and power plants, respectfully account for 23 and 31%. third, given the industry's demonstrated fuel efficiency record an economic incentive continue that trend, there's a real question as to whether any epa regulation of greenhouse gas emissions from aircraft engines is needed. that said, as aviation as a global industry, with airlines operating internationally and manufacturers selling to aircraft in international markets, it is critical that aircraft standards be set at the international level and not imposed unilaterally. accordingly, we appreciate the direct engagement of epa and faa in the development of aircraft carbon dioxide certification standard at the international civil aviation organization, the united nations body charged with setting standards and recommended practices for international aviation. not only is the icao process for setting aircraft standards highly rigorous, but the icao criteria for adopting such a standards align well with the criteria under section 231 of the clean air act. fourth, a4a strong support epa's stated intent to adopt the future icao co2 surrogate instead into u.s. law. insisted with its act and an arm of the international community. finally a4a urges epa to take note of the fact that the future icao see a justification standards for new aircraft is but one arrow in the aviation industries whatever for meeting its emissions goal -- quivered. faa's nextgen initiative, public-private research and development partnerships are collaborative efforts to deploy sustainable alternative aviation fuels at commercial scale, and a vast array of additional, operational and infrastructure initiatives being undertaken by airlines, airports, manufacturers and other stakeholders are also critical arrow's in that quiver. commercial aviation has an important role to play in how america responds to climate change. be assured that a4a and our members are committed to doing our part. thank you. >> good morning. i nancy kruger, deputy director of nacaa, a national association of clean air agencies. thank you for this opportunity to testify and provide preliminary comments of nacaa on epa's proposed aircraft engagement finding an advanced senator proposed rulemaking seeking input on icao's ongoing develop at of international democratic standards, or co2 and also the potential forthcoming development by epa of an aircraft carbon dioxide emission standard. nacaa is a national nonprofit and nonpartisan association of air pollution control agencies in 41 states, the district of columbia, for territories and 116 metropolitan areas. our members, our professionals and a member agencies have vast experience in improving air quality in the u.s., and our testament is based upon that experience. first with respect to engagement finding, nacaa commends epa and supports it on its proposal to find that concentrations in the atmosphere endanger endanger thc health and welfare of current and future generations within the meaning of section 2:31 a.m. the clean air act, defines that emissions from certain aircraft classes cause a computer to air pollution that endangers public health and welfare and also accused of the same definition of air pollution under section 2318 as the agency used in making its 2000 engagement finding with respect to motor vehicles. epa's take this proposal that the 2009 engagement finding instrument established and well settled and that there's no need to reopen wher or reduce indooro make additional findings under section 231. nacaa agrees and support epa's proposal to make such additional finding now. epa's proposed finding under section 231 sets the stage for harmonizing international and u.s. aircraft co2 emission standards. with iq expected to top international standards as early as february of 2016, we appreciate epa's request to the anpr for input on establishing that standard and the potential use of clean air act section 231, to adopt enablement the icao standards domestically. lef.. to regulate aircraft emissions beyond limits set by epa. accordingly, the overarching preliminary comments on three key issues highlighted in a npr. timing instruments easy of an aircraft. considering various approaches with the fundamental question being whether this standard should apply in production aircraft will make two completely new aircraft. nacaa believes it is essential to standard applied to production aircraft and new type of designs in the definition of in production bna covered aircraft produced at the compliant deadline. we simply cannot forgo the emissions reductions garnered from regulating engines can find no persuasive reason to forego them. on the issue of timing, nacaa recommends the standard take effect as soon as possible by 2020 for new aircraft types in 2023 for production engines -- and sorry come aircraft. nacaa is still studied eastern is the options identified by the epa and anpr to strongly encourage a standard just possible and the standards-based technology for a scene rather than technology following. nacaa would like to touch on a few reef issues. first we recommend the engines associated with but not part of an aircraft also be addressed by aircraft co2 standards key among these artillery power unit. secondly recommend epa pursue opportunities for establishing dinners were in use aircraft which can be retrofitted to reduce draft and save fuel. third, although the standard at issue here is for co2, there's also the potential for emission reductions and we encourage the potential to be an life carefully and take steps to maximize reductions. finally, while nacaa supports the establishment, i ko, the full measure of production from this category is critically important. therefore we urge epa be prepared to adopt the international standard college short including the items raised in this testimony. the coming weeks will continue to study these and other issues related to epa's finding and anpr and will offer additional comment by the deadline and in the meantime we appreciate the opportunity to share abuse and look forward to working with you on this important initiative. thank you. >> thank you for your thoughtful comments. i appreciate that. let me now called the second group of speakers. thank you. in the second group we have mr. eric white from the resources board. joe depete from airlines international and mr. kingsley, member of the public. >> just for everybody's purposes, into the microphone massive monster became here. >> good morning. thank you for the opportunity to testify today on the finance and advance notice of the proposed rulemaking for greenhouse gas from aircraft. my name is eric white in an chief of the source control division of the california air resources board. the board of the california state agency was constable permitting federal air quality standards in coordinating the state activities to produce greenhouse gas emissions. arb while providing written comments into the docket. however, i am here to emphasize the need for a strong national greenhouse gas emissions enters our aircraft and reemphasized unique opportunity to u.s. epa has to be a global leader for reducing aviation emissions. i would like to reiterate part of the testimony provided by chairman barry nicholson 2008 at the hearing for regulation of greenhouse gases under the clean air act. affects hearing, chairman nicholson at climate changes are a real urgent threat to our state in our nation. over the past 100 years we've experienced a seven-inch zero are wrote in our coastal communities and threatening critical infrastructure. in the winner the california stalinist rain and snow that into less water availability in critical spring and summer, and impact the thread is one of the most productive agricultural regions in the world and a pillar of the nation's export economy. climate change is also a major earner locker in her severe season predict it without major efforts to reduce greenhouse gases in this century, california will see a one to two for sea level rise, 75% loss in snowpack over twice the frequency of drought and 55% or large forest fires. her comments are even truer today than they were seven years ago as demonstrated by severe drought and wildfires that are gripping california even as i speak. the passage of california's bill 32 with global warming solutions act establish one of the world's most comprehensive and vicious greenhouse gas reduction programs and positioned california to be on the forefront of addressing climate change emissions. however, some sectors such as aviation california and the various states are dependent on the federal government to set the aggressive standards feasible. in that vein the clean air act provides the u.s. epa with authority and responsibility to do at california and other states cannot do by themselves. today i speak before it is supported the finding that greenhouse gas emissions from aircraft contribute to air pollution reasonably anticipated to engage public health and welfare. i stated in california's 2007 joint petition or aircraft emissions rule making comments on the advance notice of proposed rulemaking for greenhouse gases, the overwhelming scientific data support the claim that air pollution made up of the elevated atmospheric con temptations of ghd endanger the public health and public welfare. since that time, new scientifiscientifi c assessments of further substantiated the detrimental effect of the missions i have in 2005 in the u.s.a. had the obligation under section 231 of the clean air act from a emission standards accordingly once the endangerment finding is made. as the u.s. epa is now to come aircraft emissions make the third-largest transportation sewers and ghd after emissions for light duty vehicles and medium heavy duty trucks. the aircraft emissions 11% of the u.s. ghd emission are greater than all other transportation sources combined that come after it and remained the single largest unregulated transportation service in the u.s. furthermore it is estimated u.s. aircraft will exhibit largest growth in emissions amongst all transportation sector vocations. as such it is imperative that expeditious action be carried out to stab emissions from aircraft. arb recognizes the international civil aviation is anticipated to promulgate a co2 aircraft standard. while this is a promising initial step in controlling emissions from aircraft, historically standards have been technology following not take knowledge of forcing. as such, arb is concerned standards adopted may not sufficiently reduce emissions past a business as usual scenario. arb supports the international establishment of emission standards that are as stringent as possible and in the absence of a strong showing but i ko we urge the u.s. epa to extend its regulatory authority further and adopt a co2 emission standard that will be forward technology development and provide accelerated reduction. there are a variety of aircraft design an aircraft engine technologies under development which showed tremendous promise in furthering national and california g hg emission reduction goals. he should be considered as part of the regulation. arb recommends the u.s. epa the case of biogen feel is a method to reduce emissions from the basis the use can have a substantial impact on reducing emissions from aviation. going beyond the business as usual also means standards must be adopted applicable to aircraft models in production after the fact the date of the standard as well as future aircraft types. arb supports an additional requirement for aircraft crews, co2 emission rate due to the importance of data to ascertain regulatory compliance as well as policy decisions on teacher co2 emissions reduction opportunity. reporting requirement could be stand-alone or in conjunction with emissions standards for new and in production aircraft types. further, as a complement to the co2 emission standard, arb encourages additional aircraft related reduction opportunities. these include richer for requirements for existing in nice aircraft with fuel-efficient technologies and reducing emissions from auxiliary power units on aircraft. arb also uses the epa to consider regulations to further reduce engine criteria pollutants, particularly oxide nitrogen. the mitigation of aircraft related emissions is a critical part of the emission reduction strategies and arb is working to do its part ensuring other aviation related reduction opportunities pursuing other opportunities. for instance in the near term, arb will consider measures from ground support equipment ,-com,-com ma shuttle buses and other facility airport related emissions. enclosing in the event i ko failed to adopt a meaningful aircraft emissions standard by next february, standards go far beyond business as usual, arb urges u.s. epa to act independently and establish a strong national co2 emission standard without further delay. california believes it has cleared u.s. epa has authority to impose more stringent regulations on u.s. aircraft and engine manufacturers and we believe the overwhelming scientific data has proven aircraft emissions to endanger public health, therefore u.s. epa has the obligation under section 231 of the clean air act to set emission standards as expeditiously as possible. decisive and timely regulation of major sources is critical to meet our state and national g hg goals. thank you for your time. >> thank you, mr. white. mr. joe depete. the floor is yours. >> an afternoon. thank you for the opportunity for this important hearing. i am captain joe depete, first vice president of the airline huts association international and i service the national safety court nader. i'm also a fedex pilot and captain. a-alpha is the world's largest professional airline pilots union. we have 52,000 members who fly 31 airlines in the united states and canada. i would like to give alpa speeone greenhouse gas emissions in its advance notice of rulemaking. first i would like to provide context about why we are passionate about the subject. i will also talk about the positive difference u.s. airlines are making to reduce emissions while safely transported more than 2 million passengers and 63,000 tons of freight and mail each day. airline pilots literally sit at the intersection of technology. aircraft operating procedures, air traffic control procedures and techniques in varying aircraft capabilities. this gives us a unique vantage point from which to manage aircraft capabilities in such a way as to burn must feel while operating as and efficiently as possible. alpa's principal goal is to further advance his aviation authority made towards reducing greenhouse gas emissions and improving efficiency of our industry while maintaining or improving on our current level of safety. improved engine and aircraft technologies have resulted in significant reductions of harmful emissions and increased reliance on satellite-based navigation would lead to more significant reductions. in addition these improvements contribute to the need to ensure ongoing viability and sustainability of the airline industry. fuel is the largest single expense are airline employers face. in addition to the need to act responsibly towards the environment, airlines have a strong motivation to safely find ways to use as little fuel as possible and look for alternative fuels not only less expensive but also less effect on our environment. the simple fact is whatever effects are employers ultimately affects pilots as well. we have a similar financial incentive to help conserve fuel. pilots work with companies in air traffic control on a daily basis to safely reduce fuel burn while airborne and underground. additionally, the membership is cognizant of the need to protect our environment take the airlines. we strive to do that on every flight within the bounds of safety which is of course our primary focus. alpa strongly supports a small percentage of contributions to greenhouse gases while at the same time preserving economic viability of the airline industry. these two goals are complementary as fuel and operational efficiency continue to improve economic viability is enhanced. air transportation is a significant portion of the mass transportation system here in north america. u.s. airlines transport about 775 million passengers in kerry about 23 million tons of freight and mail each year. aviation arguably has the most successful record of any sector of the economy and limiting its impact on the environment while simultaneously increasing product committee. airlines have greatly reduce carbon-based emissions throughout red ants in engine technology that reduces fuel burned in emissions of gases and particulates. we use airframes that are lighter, stronger and create less fuel burning drag. in 1972 the north american airline industry carries six times more payload using 60% less fuel per flight. that is a significant number reduced by 95% the number of people significantly impacted by aircraft noise. because of advances, airline domestic travel accounts for 2% of all greenhouse gas emissions while accounting for about 5% of the gross national product. the bottom line for alpa is where strong advocates when it comes to improving fuel efficiency for new technology. airlines must afford to invest in new more efficient aircraft engines that reduce impact on the environment which has been the key to their success. concerning epa's announcement, we are pleased the agency is working with the committee on aviation environmental protection and is engaged in developing a future aircraft certification standard for co2 carbon dioxide. we urge the agency not to exceed the standards slated to be considered for approval february 2016. as the epa does, i ko is in a unique position to bring world airlines to collaborate and develop standards adopted by member states including united states and canada. going beyond the agreed-upon standards could have a detrimental effect on our airlines. alpa is a strong proponent of a level playing field for all airwaves. creation of the u.s. pacific standard more stringent than that used by other iko nations that put us at a distinct financial advantage is that it commits are unafraid to the environment. regarding the advanced fp iran. we do not believe in air crashes involve aircraft already on order. the standard should apply to new types of aircraft yet to be certified to not cause an undue financial harm to the airline industry. i wish to thank you for the opportunity speak with you today and i'd be pleased to take any questions. thank you. >> hi, my name is james lee from south carolina. i'm a citizen. why is the epa claiming the six greenhouse gases emitted from jet planes are a threat to human health on the clean air act while doing nothing to address ongoing losses are related aviation gasoline for the real health concerns of stakeholders worldwide. cancer-causing heavy-metal synfuels and additives in aviation induced cloud is. you see epa claims the authority under the clean air act, a law from the aforementioned pollution. over the definition of pollution is to mean climate change gases in what can only be called a violation of the spirit of the law. air pollution which may reasonably be anticipated to endanger public health or welfare. as you see by the wording of the clean air act, like in the dairy and the toxic chemicals clearly present a greater danger to public health and greenhouse gases do matter how much climate science to accumulate. furthermore, material data sheets almost always contain the same morning. do not dump in water. they are brought their broad fuel dumping her burning these chemicals and then dumping them in water is somehow safe. finally, despite great efforts to define bioaccumulation or by a mag education studies on her syndicated aviation pollutants, aviation pollutants commencing to access. epa an obama administration are ignoring the global outrage over the most visible climate change can turn from airplane cloud creation. do a search for the word can trail on the internet and you will see millions of concerned citizens who look up and wonder what in the world are they spraying. despite what you may think of the myriad of maladies attributed to these clouds, the global outrage is nonetheless clear. they are right to be worried and we should all be can earn. the epa claims here to as a greater threat than cloudiness is based on incomplete data that downplays the effects on our climate. the ipcc for the assassin enough radiative force and only accounted meaning any kind of trail that spreads out and was not accounted for. how significant is the heat trapping conundrum? formed by aircraft can evolve into serous clouds indistinguishable from those naturally. the spreading trails may be causing more climate warming today than all the carbon dioxide invaded by aircraft since the start of aviation. another researcher stated a single aircraft operating in conditions favorable appears to exert a radiative force in some 5000 times greater than the estimates that the average forest in the entire civil aviation fleet. although this research is now incorporated in the ipcc computer models and these claims highlight gaping holes in climate science. as 2013 quote cloud interactions are one of the main uncertainties in climate research. scientific understanding into serous clouds is lacking the rapidly evolving with the latest research showing clouds are filled with metal aerosol string humans sources. the big one we found this lad coming from things like fuel still used and might aviation probably the biggest metal we find for the most frequent metal we find. we find a whole host of different metals actually. apparently small amounts of particulates have major effects on serous clouds. it would seem that you would have to change all of the aerosol of the atmosphere radically to get a big affect on the clouds that because mineral dust and metallic particles are such a small amount of the particulate matter, just a percentage or two means you only have change about a percent or two of the particles to get a big effect on the clouds. the latest research casts doubt on the ipcc assumptions and require serious consideration when addressing the real climate change impact of aviation. high-altitude metals than serous card can't station are coming from leaded gas and jetted costs. kind trails are making serous clouds and nondescript metal have large impacts on serious cloud creation. clouds trap heat and are likely to have a greater impact climate change impact than co2. finally, aviation induced cloudiness endangers future growth in solar energy, effect tourism and is projected to make terrestrial astronomy impossible by 2050. geoengineering scientist, nasa, noaa, faa, dob and international corporate partners are discussing the use of biofuels and sulfur doped jet for contrail controls. this feeding with business tri-iodide to melt these clouds away. the epa should be directly involved in these discussions. as a result of these filings, i strongly encourage the epa to consider expanding the scope of endangerment to the metal particulates and confirmation from jet exhaust. if the epa complies with the spirit of the clean air act, they will protect those metal aerosol's attributed to alzheimer's, autism and other debilitating illnesses. the epa is truly concerned about aviation induced climate change, they will regulate production of cotton trails and paths to change our climate to a much greater extent than the sum of the six greenhouse gases in the proposal. regulating how they metals will be meaningless without proper verification. even though members sign a binding agreement, we all know agreements and regulations are useless without proper verification. therefore i request mandatory random testing be immediately implemented. this is the most important step the epa can take to follow the spirit of the law and do its due diligence to protect us from pollutants and gave real-world data to improve future regulations. most of the data behind this endangerment comes from research in highly controlled environment where most variables are known. we need verification of nine ideal situations where fuel filing, contamination or improper maintenance and particulates in the last settings. to achieve verification i propose the epa randomly attach a trailing traub to foreign and domestic flight to collect and analyze results to determine real-world exhaust constituents. alternatively, ground-based observations may be possible over six high-traffic areas and prevent possible terrorist attacks using aerosol. either way you choose, we need verification and protection. in conclusion the epa should expand endangerment to include cloud creation, creative verification system with all aircraft to protect aviation pollution, hold violators accountable and commit the accuracy for future determination. thank you for the opportunity to speak on behalf of so many who could not be here thank you for listening to a layperson's views on the subject. while i appreciate efforts of the center for biological diversity's, sierra group and friends of the earth to hold the industry accountable the poor people like myself have to live near these airports under these fuel dumps and under the clouded skies. i hope that some faith can be restored in our epa by your action here and now. tell the icao they will meet your demands and our demands, not the other way around. thank you very much. >> thank you, mr. lee for all of your comment. second panel. >> yes, thank you, all. i will call forward group number three panel at this point. this would be -- i apologize if i don't pronounce names properly. leslie reagle, doug walls and michael saraceno. [inaudible conversations] >> im leslie riegle at the industry association. thank you for the opportunity to testify the proposed endangerment finding an advance notice of proposed rulemaking on aircraft greenhouse gas emissions. aia as the largest aerospace trade association representing the nation's major aerospace and manufacturers. we represent more than 300 u.s. manufacturing comp needs with nearly 1 million skilled employees. members are recognized across the globe for manufacturing reliable and comp amazing aircraft that connect passengers and cargo to help defend national security. our industry is heavily regulated and must pass grueling safety and airworthiness criteria on any new aircraft or changes to existing aircraft. we never compromise on safety. aviation is a global industry and works under the united nations international civil aviation organization iko which is setting global aviation standards for environment and safety for over 50 years. this globally harmonized model has worked well for the united states. the u.s. aviation industry has thrived on the global playing field as evidenced by the cost of impacts that we play on the national trade talents and we hope to continue to build on this model as we develop new fuel efficiency standards for aircraft. .. more than 3% of global growth domestic product is supported by aviation yet only 2% of global co2 emissions are attributable to aviation. it is for this reason that the commercial aviation industry is committed to building upon its strong environmental track record. the industry understand climate change issues global and environmental challenge requiring incredible action. in 2008 the industry agreed to a set of are the targets to combat carbon emissions. they include improving fuel efficiency by an average of 1.5% per year from 2009-2020, stabilizing emissions from 2020 with carbon-neutral growth, and reducing net carbon emissions from aviation by 50% by 2050 compared to 2005 levels. the industry will meet these goals through improved aircraft fuel efficiency such as the introduction of new aircraft models with the latest fuel saving technologies and advanced propulsion systems, operational efficiencies, air traffic management system modernization and improvements such as nextgen, and greater use of sustainable aviation biofuels. in addition our industry by way of competition and regulation must make certain that in achieving our co2 reduction goals we address other environmental considerations such as particulate matter's and nox. icao is a new international body in which aviation specific technological feasibility, economic viability, and environmental benefit can be evaluated together in shaping policy. it takes a comprehensive approach to response to environmental challenges facing the commercial aviation industry, including aircraft co2 emission standards. these interdependencies are critical to consider when any new regulation is proposed and incorporate into domestic law. the u.s. has agreed as one of the 190 parties to the chicago convention that icao has the authority to establish environmental standards for aircraft. epa's practices been to adopt icao standards as its own for new commercial aircraft engines. the federal aviation administration with support from the ep and other federal agencies has followed a similar approach in setting aircraft noise standards. we see no reason for the epa to deviate from this well-established practice in addressing aircraft co2 emission standards. the committee on aviation environmental protections is expected to adopt a final emission standards in february 2016 with full ratification by the icao assembly in september of 2016. this recommendation will be a result of years of data input analyses and careful consideration. our members along with aviation colleagues, government officials and ngos have been working at icao annecy to standard for civil aircraft for over six years to ensure that this is done in the most educated and effective manner. as it has in the past epa should follow this well-established path without the icao standards india for domestic law under section 231. doing so will ensure that the u.s. aircraft and engine manufacturers are not placed at a competitive disadvantage, vis-à-vis international competitors. moreover, it will avoid the disruptions to air travel in the u.s. having to enforce an aircraft huge emission standard that is different from that adopted by other countries. again on behalf of aia and its neighbors by thank you for the opportunity to testify today to aia will also be submitting comments. >> thank you so much for having this important hearing. my name is michael and i'm a citizen. while greenhouse gas emissions from aviation may be only two, 2.5%, the global aviation is u2 a nation is almost equals the amount of co2 put out in the country of germany. others have talked about how co2 is trapping atmospheric causes warming of the earth so i will leave more of that to them. but the fact is that the more co2 that is put into the atmosphere, that result -- that result in more combustion. the -- i think one of the biggest concerns with more combustion from aviation and the sheer increase in addition, the faa forecasts aviation will grow 2% per year reaching 1 billion passengers by 2029. and the issue with more combustion, not only with more co2 but the modernization act that was recently passed in 2012 essentially a slide the faa through precision-based navigation to save, yes, to say the fuel on a decent but what they're not telling is the faa is allowing the airlines to cropduster u.s.a. the reason why, how they're doing this is through nextgen or precision-based navigation. they are allowing the airlines to pack in more planes in tight formation a much lower altitudes. we know from nasa that aircraft operations below 3000 feet decreased ground-level air quality. that's necessary that, and i'm submitting my testimony into the dr. cassel with all the references so you can feel free to look them up yourself. so we have all around this country the faa allowing, ride, the change highways in the sky across the u.s.a. and they have not found one environmental impact. that's it. you can change the highway over the entitled continental u.s. and there's not one of our mental impact that will impose on anyone or any person. that is absolutely ridiculous. the most important issue, the reason why this needs to be investigated further is that the more combustion that we have, the more landings and takeoffs year over year in tax the people who live downwind from airports across the united states. now what's the difference, right, from living downwind from a highway from living downwind from an airport? shortly both situations will give you downwind pollution. the difference is a highways having to is buried our pollution barriers and there's studies that those on barriers with education, prevent highway pollution from food and then went into communities. where is the barriers to downwind pollution from aviation? most of that this approach is that i've listed studies that have done, london heathrow will, laguardia, a bunch of different studies that have shown that, in fact, airport particulates can reach as far as five to six and in some cases 10 nautical miles downwind from an airport. so the biggest issue with that is is that we know that vaccines do not cause autism. the largest organization in february 2012 came out and said that vaccines do not cause autism. every scientific journal that was published on the reputed. in fact, it proves the opposite. we now have 12 peer-reviewed studies, and i cite in the references, that there's an increased risk of autism associate with increased air pollution around conception and/or pregnancy. the vast majority, and i've talked to harvard scientists through personal to me patient, is not genetic. it's environmentally induced pollution. environmentally induced pollution is what is causing autism. we will see a spike in awe system across u.s.a., and i look at diagnosis or hide incidents but the fact of america's more children are receiving services today than they were and to continue to receive more services over the next 10 years. it is a heavy metal load in autism. we know that. that's why vaccines were pointed at. the heavy load, heavy metal load indexing, i mean, in air pollution can, in fact, de paul said in a hair and and the nails of these children. in fact, when did you look back at the hair and nails of the show and they find that the heavy metal deposition in the hair and nail this significantly higher. we know they're being exposed to toxic metals. that's from environmental pollution. uc davis 2012 came out with a new study that said the 2015 cost of autism related expenses are $268 billion. and by the year 2025 it could be anywhere between 500-100 -- $1 trillion related costs. we know that aviation emissions have traced heavy metals, byproduct is knox. it is sold for. the aviation jet fuel contains 100 times more sulfur in diesel trucks. and we can talk about autism but also high air pollution areas also decreased iq of children. very interesting thing about that is that even when these children hit six, seven years old they still did not catch up to their peers. this damage has been caused by pollution induced, does that effect on one of the most important things that i will tell you, if you want to know how dangerous air pollution is you just have to look at the trend, trends generational changes. there was a study done in, that i have been a reference by -- let's see here. where is the? by tracy and 2013. they exposed mice to jet fuel and what they found is that it didn't change the gene fo but it changed the way the gene was expressed. that changing the way the gene is expressed for obesity will got into the genome and was passed on to subsequent generations. so this is what i care because my nieces and nephews, my children could potentially very somebody else's kids who are in heavily polluted environment, and a change in the genome gets into the gene pool. so your grandchildren and great-grandchildren could, in fact, develop transgenerational epigenetic changes through environmental pollution. and another way besides greenhouse gases, and i'll keep this brief, there is evidence to show that persistent contrails did, in fact, warmed the earth. take up and comer solely -- infrared radiation that there were studies done by nasa found after nine 9/1 nine 9/11 attacks those of one degree celsius spike between the maximum size and the maximum loads in terms of temperature. so they looked at skies without contrails after 9/11 because the trains were grounded for today's pentagon the spike in the temperature range. so without contrails to change the climate. and i'll just end with another nasa scientist also talked about contrails into using data from i think the 1990s to 2000, early 2000. this is all the dated but what he says is that increase in service and lower atmosphere tempters by .36, or .5 degrees fahrenheit per decade. that's what he is saying the contribution, the contrails could be to warming. .36, .54% fahrenheit per decade. i think that proves contrails do in fact affect temperature. the other thing you should know about contrails is with more combustion, more jet aircraft, marketplace, you get more contrails and get more warming. it's this whole vicious cycle. the thing about contra this they produce clouds. windy city contrail spreading the only study within the first few hours. they did not study a whole lot of that artificial cloud that is produced. that artificial cloud that is produced would not inform if there would not have been a contraband that area. these clouds that are being produced are producing clouds that would naturally be there. that changes the hydraulic of cycle, which is ringed. the other thing you should do is the way you can change the rain is when the engine at high altitudes freezes the ice crystals in the atmosphere, it is actually changing the vapor content in the atmosphere. so the vapor content will have a change on regional change everything to do much for having this open hearing. >> my name is doug wolf, represent the center for biological diversity. thank you for convening this hearing after soliciting further public input concerning agencies crucial efforts to promulgate greenhouse gas emission standards for aircraft. the center for biological diversity appreciates the opportunity to comment. with these -- the center for biological diversity is a nonprofit organization with more than 800,000 members an online activist. centers climate law institute seeks to reduce u.s. greenhouse gas emissions end of air pollution to protect diversity, the environment and human health and welfare. specific objectives and to secure protections for species threatened by global warming, ensuring compliance with applicable laws to reduce ring as gas emissions and other air pollution, and educating and mobilizing the public on global warming and air quality issues. climate change is already upon us with unprecedented temperature increases, rising sea levels, extraordinary rates species extinction and more extreme weather events. efforts to quickly and sharply curb and then eliminate carbon pollution are essential if we are to avoid the worst effects of climate change. science tells us this requires the use to reduce emissions in the range of 35-65% by 2030, 1990 baseline levels. to begin to approach those levels every significant carbon emissions source must reduce its emissions and aircraft industry is too long unabated every attempt to make a contribution to its fair share. its global aircraft to two conditions were compared to those of countries, they would write the seventh just behind cheerleader outranking about 150 other countries in the world. aviation emissions are growing rapidly and to triple within a few decades. unless epa puts in place stringent standards to reduce greenhouse gas emissions, increase aviation traffic will cause the sector to become one of the fastest growing sources of harmful emissions. within the global community united states is by far the largest emitter. with its domestic and international flights contributing 29% of the total, dumping that amount into the global skies absolutely unchecked. in other words, u.s. aviation emissions harms the global community initiative a disproportionate fashion. u.s. must reverse its situation i can't emissions quickly and steeply, and must reject the insufficient measures proposed by the international civil aviation organization, or icao. we fully agree with epa's findings that aircraft carbon emissions endanger human health and welfare. we believe, however, that this proposed finding was much too late in coming and we urge the agency to make up for lost time by finalizing its list and no later than november 2015, 3 months after the close of the current comment period. we also urge epa to follow up its anpr with proposed standards at the same time it finalizes its endangerment findings. there's no reason to wait the outcome of negotiations at icao as even the most stringent measures under consideration there would hardly make a dent in the problem. in fact, the likely outcome of the negotiations in 2030, only 5% of the global aircraft fleet would even be regulated, and missed by standard based on technology in existence in 2016, or some 14 years behind 2030 technology. moreover, the icao proposal said no cap on emissions. in other words, icao's proposals to next to nothing affect business as usual.com utterly incompatible with epa's duties under the clean air act, the president's climate action, the demands of climate science. epa should seize the opportunity issue proposed emission standards and time to make a difference at the paris negotiations in december of this year. we are pleased to see epa's acknowledgment of the clean air act authorizes it to regulate not just aircraft engines by the entire aircraft. we add that the act delegation of authority be under section 231 is extraordinarily broad at the epa is explicitly authorized to set emission standards for all classes of aircraft. moreover, as he be recognized in this 2008 anpr, epa's regulation can encompass aircraft operations and air traffic management. finally, the standard epa settles on should be technology forcing, not stalling. with these premises in my dba should set emission standards not just for new type of aircraft also for all aircraft currently in production and in service, should base among current existence was under develop technology and should include operational and air traffic management requirement that reduce emissions. aircraft as director but to meet the standard should be phased out. we urge epa to craft the standards by employing an approach similar to standards for vehicles setting the white averages for new and in service aircraft. the standard should be sufficiently stringent not only told the total commissions and decent gap but i can reduce them for the entire u.s. aviation sector within the coming decade. the center will be submitting written comments at the close of the comment appeared but working with other organizations and we thank you for this opportunity to be here. >> thank you very much. thank you for all speakers to appreciates your comments and thoughts. i will now move to the next group of speakers. as i call you please come up to the table. we have kathy kinsley from the northeast states, sue valdez, a member of the public, and andres restrepo from sierra club. thank you. >> thank you. good morning. good morning. minus kathy kinsey, i' and a ser policy adviser with the northeast states for coordinated air use management. would like to thank you for the opportunity to be your to testify on epa's proposed engagement finding, and on the advanced notice of proposed rulemaking. we organization of eight states, north '60s states and new york and new jersey and my testimony today here reflects the majority view of our state and does not necessarily reflect the views of all of our individual state members. so nscaum purports epa findings under section 231 that aircraft greenhouse gas emissions endanger public health and welfare. is supported consistent with the support, our support in 2009 for epa's proposed, or endangerment finding for mobile sources. since 2009 rulemaking, climate science has only grown stronger. the latest science is summarized in the 2014 international panel on climate change. establishes a climate related threats already affecting our states, our nation, and the world. nscaum also supports epa's determination that aircraft emissions from certain classes of aircraft our country bidding to the mix of greenhouse gases that are subject to this rulemaking. we support the development and adoption of aircraft greenhouse gas emission standards for u.s. aircraft. in this regard we support a whole aircraft approach to adopt these standards. that doesn't focus solely on the engine. whole aircraft approach recognizes that emissions are influenced by aircraft weight, aerodynamics, and engine specific fuel consumption. we urge epa to adopt greenhouse gas standards for new aircraft and in production aircraft. that approach will begin to materially reduce greenhouse gas emissions in the next five to 10 years from the projected business as usual levels. they will be based come to be based on a reference center that reflects current aircraft performance. a reference center that is based on outdated aircraft performance will only two conflated estimates of greenhouse gas emission reductions from current reductions. and, finally, nescaum urges epa to take the opportunity with this rulemaking to revise the current aircraft not emission standards are given detention imposed on attainment problem in our region, the northeast region, the nation as a whole, and the fact that under its current process icao is unlikely to adopt new aircraft nox standards project 2022, if they get epa should take the opportunity to act now and establish a production date of december 31, 2018, for the united states after which standards will apply to newly manufactured aircraft into the of the cure six standards. nescaum intends to send more detailed written comments, and again we thank you very much for the opportunity to be here today. >> thank you. my name is andres restrepo and i'm an associate attorney with sierra club's environmental law program. sierra club is that any teenager and stansted is one of the largest and most active grassroots environmental organizations in the united states. with over 2.4 million members and supporters as well as 64 chapters nationwide the club works to secure a clear healthier and more sustained environment for today's world and for future generations. one of the club's most urgent goals is working to curb the effects of climate change and we advocate for steve and immediate cuts to greenhouse gas emissions from all sectors. unless governments act now will be unable to avoid the worst impact of climate change which include rising sea level, more extreme temperatures and weather events, as displacement of people come more severe droughts anand floods, enhance formationf harmful air pollution widespread extinctions of plant and animal species. we support our greenhouse gas regulations for aircraft to mitigate the harm. for far too long u.s. aircraft have been emitting a limited amount of these pollutants into the atmosphere domestic and international u.s. flights nothing to nearly 30% of the co2 emissions from aircraft, far more than any other country. u.s. aircraft submit more greenhouse gases than the entire economies than -- increased that much is 50% over the next two decades plus mandatory restraints are imposed. epa's funny greenhouse gas emissions of aircraft in danger public health and welfare is therefore entirely separate the effects of both the climate effective greenhouse gas emissions also will document they require no additional discussion. under section 231 of the clean air act and engagement find triggers the agency obligations to issue aircraft regulation to give them the size and scope of epa must not delay the process in any way. the agency must forge ahead without waiting to greenhouse gas standards forthcoming from the international civil aviation organization, or icao. the most stringent proposal under consideration by that body would cover only 5% of global aircraft, relying 2016 technology for aircraft built in 2030 and would not impose total cap on emissions from the global fleet. even under test cases into the icao stand will do little if anything to curb the intensifying problem. the united states must exhibit leadership on this issue ndp should move forward with strong effective standards under section 231. epa must adhere to federal principles. first come the agency must cover all aircraft under any final standard. this requires regulation not what the new designs or newly constructed aircraft that aircraft currently in use as well. .. hence those capabilities above what they would have been otherwise. section 231 provides regulations shall take effect to permit the development and application of requisite technology epa must face its standards not only on existing technology but in lo

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