Message wouldve been a different one to the business community. Would have been yes we are negotiating ploy might have the dl, yes there will be a deal, but dont cross these lines because this is whats going to happen. Instead, the examples given in the precedents that were in the opposite direction. The message was sanctions or is till in the law books but we are not going to implement them which is why Companies Feel comfortable even though they are so five, six months into implementation they go through the breach. The Swiss Parliament by the way feels the same way. Switzerland maybe not the biggest Global Player but it had a fruitful trade relations and a lot of the phone companies they were running to circumvent oil sanctions, procurement sanctions, to lg sanctions lifted all of its sanctions. They abolished it. They are not waiting for congress. They are not waiting for implementation. Even if you can treat sanctions as a yellow light, not a red light anymore, it is not the yellow light that comes before the traffic light turns red. The gala light in some countries comes out before the traffic light turns green. If you come from a country like mine is a recommendation and not a command. When you see the yellow light, you hit the gas in the forward. Thank you. [applause] thank you to heritage for having me. I dont have any pithy driving tips so let me tackle some of the stuff we talked around so far. I want to focus on three things. We talked a lot about the effects or processes relating to the sanction implementation with regard to iran. Lets get down to the nittygritty. Theres three things we should be thinking about what the sanctions basket of the joint comprehensive plan of action. First of all, were both come from . The myth says this is a gift from the american tax airs. It is money that iran generated from the foreign sales of oil to key consumers. China, singapore, south korea, japan, india, others. These were targeted and has been an earnest targeted and 2010 and a comprehensive fashion since the passage of a piece of legislation in 2010 which mandated all the countries began to scale back the purchases of iranian oil to show a goodfaith effort they were trying to wean themselves off of dependence we. The onetwo punch of the approach was in addition to trying to compel iranian consumers to reduce consumption of iranian oil, we also ask road, first come and made them accessible revenue generated in the interim. When you see the iranian economic effects that brought the regime to the table in the first place a great deal had to do with the fact they couldnt receive the oil benefit. Sanctions are not taxpayer dollars but they are still very important because they provide an aggregate expansion of the economy. Thats the second question. How big is it . Here in the debate in washington is an awful lot of heat but not a lot of light. President obama himself has said publicly the sanctions relief they can expect to get will be anywhere from 142100 xt alien dollars. They estimate a little bit less than 60 billion. Either way what you look at is an unprecedented scope of sanctions relief. Its always nice to go right in the middle. 100 billion to more of sanctions. This is so large a figure that i think it is actually very unhelpful because ordinary americans its hard to put in context what does that mean. But they explain to you in comparative terms what this looks like. In 2014 the iranian annual Gross Domestic Product was 415 billion so sanctions package in the direction of the Islamic Republic in the next six to eight months worth roughly a quarter of the iranian economy again. In comparative metrics this is larger than the entire Marshall Plan for the reconstruction of europe that the truman and industry should initiated from 1948 to 1952 the land known as the European Recovery Program formerly was 13 billion in 1948. Todays equivalent 120 billion. It spent four years and by the way as vacation times in europe now demonstrate that was remarkably successful in reinvigorating qualityoflife and european economies. The impact should not be understated. Youre looking at a Marshall Plan for the Islamic Republic that is going to be applied in sort of a fastforward fashion in a way thats likely to have tremendous effects for everything relating the iranian economy including domestic foreign adventures. The second comparison youve heard with regard to the sanctions package is its comparison to the u. S. Economy. The most recent estimate and it was roughly 14. 7 trillion. What youre looking not as if somebody gave us the same economic gift of the same scope it would need 4. 5 trillion. You are looking at five times the stimulus package that followed the 2008 Global Economic crisis. Think about what the United States can do with this financial windfall and you have a appreciation in comparative terms how this is perceived in tehran. That gives us a fair question. What will it be used for . The Obama Administration has expressed hopes it will use funds for domestic reconstruction of the real Marshall Plan for domestic reconstruction for Economic Stabilization theres two possibilities. And that it will. Here i think an example read a good sense of what this looks like. 1991, congress has simply known as the comprehensive Threat Reduction act of 1991 known far more popularly as nunn lugar. This is the program that is still ongoing and cars that started with the collapse of the soviet union to dismantle the strategic arsenal. Very wellintentioned program started with an initial infusion of 409 is now grown to 1. 4 billion annually. Figured out over time a lot of money sunk into helping the russians dismantle the transition their strategic arsenal. Has accelerated the pace and there is a series of investigations done by magazines like Readers Digest about what the groundlevel impact of nunn lugar was on the premise that congress and the Clinton Administration was going for that if russia had more money to dismantle missiles, to make it stop pile more manageable to do work with it. We found nothing of the sort happened. Russians allocated the Defense Budget to dismantlement and they didnt care where the money came from and if that money, 10 , 15 came from the United States, it freed up capital for them to use on other things. Theres a great article for those of you interested in looking it up from 1998 in Readers Digest about how u. S. Taxpayer dollars helped restart the russian bio weapons for this reason because they didnt widen the pie for dismantling. To use the money because money is fungible for other things. Theres a very real danger of that happening today. It is possible like the Administration Says we are going to see iranians use some of the sanctions relief for domestic reconstruction. This is an awful lot of money is at least as likely as not were so that it uses that im not rather things on two key regime priorities and heres where we enter the zone of danger. The Reagan Administration formerly listed iran as the worlds leading state sponsor of terrorism in 1984 and has held the position of her send and then the last several years it has maintained the position despite a series of sanctions increased in severity. In 2007, 05a, treasury undersecretary for terrorism and Financial Intelligence at the time said iran maintained a nine digit line item in its budget for the support of terrorism. They spend some on the order of 200 million to support hezbollah and spends as much as 25 million monthly on hamas and funds the entire annual budget for 56 billion a year currently destabilize the regime in syria to start telling the numbers in syndicates to be real dollars. This is a real expenditure and one as a result of sanctions relief is likely to grow exponentially. Iran will have more capital to do the same things that committed to doing already even when its sanctioned constraint. This gets us to irans regional ambitions. It is worth noting even as the e. U. Three plus three, p5 1 or whatever term you use, even as we were busy negotiating the nuclear deal with iran, what you saw was a rising trend in the middle east in places like serious and yemen and places like bahrain and southern lebanon. What you saw is in iran that was more and more not willing to think globally but act globally. Iranians have knocked out an ambitious global agenda to promote ideals to export revolution and do so not only in the immediate periphery but increasingly far abroad. As part of the effort, iranians have built a rather significant Online System with the worlds most troubling machines. They hope the overthrow of the government in yemen to hezbollah and hamas has expanded a threat to israel and the region by both movements. In latin america you see in iran increasingly in league with the regime of hugo chavez in venezuela as well as the regime of ava morales in bolivia, rafael or quayle and ecuador and iran has insinuated it off into the premier antiamerican geopolitical bloc known as the Bulgarian Alliance appeared in africa you see in iran has become a key sponsor for the regime of albashir and in our brand that is bankrolling the modernization of this in a way military. In a show you see in iran deepening strategic target ship with north korea on Ballistic Missiles and nuclear cooperation. Ucl at this rather troublesome Strategic Partners iran has a line and it is not a very large leap of imagination to assume that an iran no longer part of the conversation that has become the conversation because of the scope of sanctions about to receive as likely to transform from being a part or to becoming a patron of some of these regimes and what you are heading towards as heading towards that the result is an International System far more inimical to the interests of the united state and American Allies in these respective regions. This gets us to one of the reasons, probably the main reason why im skeptical about the joint comprehensive plan of action. To me the watchword of diplomacy has to be to do no harm. You should not engage in diplomacy that leads you in our National Interest to adversely affect than you were before hand. But it violates the principle and does so in a way that will affect our security and the security of our allies significant date in the years ahead. I will stop there. Okay, all right. [applause] we have about 35 minutes left. Let me give you some quick rumbles because we have a ton of people not getting questions from some of the folks online. I will acknowledge you didnt stand up, wait until my colleague gives you a microphone and tell me who you are and ask a question. Please, no speeches from the floor. We have too many folks with a lot of questions. I will give you two sentences. If i dont hear it . I will ask you to sit down. Okay, we are ready. Who has the first question . Jim phillips here at heritage comest Senior Research fellow in middle eastern affairs. To me, one of the most inexplicable aspects of sanctions relief the administration agreed to was totally outside the framework of Nuclear Sanctions in the area of Ballistic Missile sanctions and the arms embargo. This is particularly inexplicable to me. [inaudible]. Happy to go first. I think the technical answer is, well, these ambassadors were part of the u. N. Security Council Resolution that were really addressing the nonproliferation agenda of the Security Council and thats why they had to be addressed. I think that thats not an answer because you can write anything you want. The u. N. Security Council Resolution provided you have consensus, and they could have kept the arms embargo and the Ballistic Missile embargo. I think the underlying sewages here is that the nuclear deal will unlock relations between iran and the west by empowering those inside the regime who understand that iran has to change in order to remain a player in the International Community, and, therefore, the details of the deal, though important, are less critical than the deal itself. So we can make these concessions because, yes, you know, its a gamble, but in five years time when the iranians are so busy reaping the benefits of the economic windfall, which will require them to open up and well get all of these vacationing italians to come to tehran, will be more reasonable, and once theyre more reasonable, they can have their arms and once theyre even more reasonable, issue we can let them have their missiles. Now, i think that the bottom line here has to be, we need to have a discussion about how a regime that has been defiant, that has not changed an iota of it behavior and practices, that has actually become more aggressive as a result and more assertive as a result of this deal, is suddenly going to say, oh, we preserved our national pride. We preserved our assets. We cheated the International System and got reward ode for it, so now were going to change course . So that is the problem with the assumption. Just to second that, think thats absolutely right. Deals not only with the lifting of restrictions on ballistic missle and also the started nonNuclear Sanctions relief iran will get, including the delivessing of sewell man sewell man soul man any from the do not fly. The Administration Says the deal is just nucleares issue but from the way the white house is talking and positioning the deal, that this is intended to be transformational. Intended to fundamentally reset our relationship with iran, irans relations with the west, and then all good things will flow. I think thats speculative. I think thats hopeful. I would point out that hopees not a Foreign Policy. And i think that its much more useful to understand that the threat potential of iran, as a result of the various provisions of the jcpoa, including the exclusion of Ballistic Missile development, is not diminished. It is slowed but not diminished. And heres an interesting little vignette which i think that the jppoa is having an interesting Ripple Effect throughout europe and throughout the International Community. I think it took the russians seven and a half hours after the announcement of the jcpoa signing on july 14th to argue that now that the iran threat has been dealt with, theres no need for missiles in europe. That hasnt flown or at least hasnt flown yet as a persuasive argument, but one of the reasons it hasnt flown, as the russians are discovering, is because they helped facilitate the exclusion of irans back his stick missile portfolio from the scope of the negotiations. The iranians insisted this was an unacceptable demand to put on the table. We caved. The russians assisted us caving. And now the russians are discovering that the one thing they care a lot more about, which is the ability of europe to hold their strategic arsenal at risk, is not going to alter in their favor as a result of this deal. So, my sense is that there are different permutations of how favorable this deal is. Certainly for the iranians, very favorable. I think some irans International Partners in which category i put russia as well as china, i think theyre finding it may over time be less favorable. The gentleman in the back. Nude nude of [inaudible] im interested not what power we have in congress over what portion of the sanctions regime, which is arguably the most complex sanctions regime ever we have had of a rouge state. Ive counted 17 executive orders and about four dozen provisions, major legislation every couple of years since at least 1990. Some of those for nonproliferation, some human rights, some for terrorism, some are ewan lat ewan raft recall, some have a president ial waiver, some dont. Love to hear your thoughts what portion of that congress has control over, especially how it interfaces with the corker legislation. Regardless of how the disapproval vote goes. I think we have somewhat different views. Well, my sense is that theres a couple of things toen unpack here. I think the way the white house has talk about this deal, its made it appear as if its a binary choice. I Congress Disapproves of the deal and then vetoes the override, this is a path to war. This is how secretary kerry has talked about it, how the president talked about it last week in his speech at american university. I think that the is a strawman argument. Nobody wants war. But i think its worth noting that everything that i talked about with regard to the benefits of economic revenue flowing to iran from the sanctions relief is prospective. Hasnt happened yet. Doesnt happen until implementation day or thereafter. So, what youre looking at is an iran that is still sanctions constrained. You hear serious problems, serious cracks in the International Consensus over irans isolation. Remember, what were looking at is an iran that is still for the moment has diminished purchasing power. So the idea that iran sort of loses the shackles and makes a sprint toward the Nuclear Capability presumes an iranian that is not visible yet. Theres many ropes to expect that the day after a veto looks an awful lot like today does in which the iranians do not get the benefits of the jcpoa. The second point here, which is that when we look at sanctions, you have to understand that sanctions are annual tate qualitatively difference in congress than in europe inch congress theyre more complex, dealing with the nuclear and proliferation portfolios and deal with terrorism and human rights issues with regard to iran. The sanctions accountability and divestment act of 2010, is best drawn as a kitchen sink in which all these things go. The Nuclear Issue is the most important but not the only one. Here i think congress has a lot of incentive to refocus if this deal does go through, on the other legs of the stool on which our regime of pressure on iran, our legislative regime of pressure, actually there is, of course, hangup. As part of the terms of the jcpoa the administration has commit itself to preventing ancillary forms of pressure that will make the deal harder to implement, which all of us, meaning all of you, have read as the Administration Working actively against the application of additional sanctions. That may be true. That may not be true. Well have to see. My sense is that for congress, this is a gut check moment, but obviously for in terms of congressional priorities and constitutional prerogatives but also a gut check moment in terms of how robust congress economiesment is to Nuclear Sanctions and the other modes of pressure we have and are Still Available to us to change iranian behavior. I cannot disagree certainly. I do take slightly more skeptical view of the effective unless of a congressional disapproval and veto override on the deal itself, because i believe, and i certainly have been told, in europe, that the rest of the International Community will not agree to go and renegotiate the deal. But i think that the broader question here is whether Congress Challenges the president or not. How the administration addresses those sanctions that remain in the law books in the next 16 months. That to me is the real question. If past is prologue, i think that regardless of what congress does, the administration will do its utmost not to fault the iranians for any violation of sanctions until january 20, 2017. There, so the big question there, which is i think relevant, especially to u. N. And to the good work you do every day, is what happens with the next administration, given that this administration is saying tons of norms and regulations, punishing and restricting iranian economic facilities, still remain in the lawbooks the next Administration May feel less committed to giving the iranians a path, even if Congress Approves the deal in the end. And you still have a very long area of weapons and tools in the sanction basket you can use and ask the administration to enact, and thats one. The second thing is, that when you go through the measures and the entities that are going to be listed on implementation day, on transition day, which there is a lot of inconsistency in the way these entities have been chosen. I want to give you one example. May not be the sexiest one but i think it speaks to the problem. Between 2011 and 2013, the United States sanctioned through treasury five iranian airlines. Irran air tour, iran air, and three of these entities were sanctioned under executive order 13382. The one that dealed with nonproliferation. Two of them were sanctioned by executive order 13224, which is the executive order that deals with Financial Support for terrorist. When you read the motivation for the designations of the five airlines, all five were involved in a variety of activities which included ferrying weaponry and military personnel to and from syria. And giving aid and support to the irgc. So, even though three of these five airlines also had some activity linked to nonproliferation, all five were supporting the syria war effort and the irgc. By the Administration One would aseem that all five remain under sanctions. Actually, three of them, the three sanctions under 13382, are being removed. So one thing that congress can do is raise this question and ask, why entities and companies that have been supporting and are presumed to be continuing to support the irgc in the supply of weapons to terror organization, to the syrian regime, violations of human rights, human war crimes and so on, are going to be getting sanctions relief on implementation day. You can go through these things and find a lot of such examples, and i think that would be a very useful way to keep the administrations feet to the fire until in 2017 we know whether the next administration will feel as committed or less committed to this deal. Anything to add to that . Okay. All right, well get this lady right here and then ill ask one from our online listeners. A question for you. The first thing iran did with its money was sign a deal for refueling aircraft, which was serendipitous for the russians because they have an airplane and couldnt keep the production lines open nice didnt have any money. Now they have movement yesterday there were russian warships having war games, more games than war. Are we seeing the beginning of russia getting its warm water port and russia making a move into the persian gulf that could ultimately affect the United States and iran would be the other side of that . I think that is a good question, and its certainly a plausible one in the sense that what we have seen over the last year and a half has been a Russian Foreign policy that is animated by precisely this type of risktaking, this type of brinksmanship. Ever since february of 2014 when Vladimir Putin went into ukraine, what youre looking at is a russia attempting to revive the established rules of the road, which its in Eastern Europe or now sort of more so in the persian gulf. What youre looking at, though, think, is both. One of the, i believe, main misconceptions we have with regard to russia is that putin has a desired end state. Everything that you have seen in ukraine suggests thats not true. That putin is engaging in opportunistic policy. His gradual escalation of russian asymmetric presence of russian activities in ukraine is calibrated in response to nato action, or lack thereof. So my sense is that i think this is probably very good framework to a reply to what russia is anything middle east. Russia has big ambitions to supplant the United States as the goto arms supplier in the middle east. It has already assumed pride of place as the core Nuclear Supplier nor miami. One of the lesser known facts that russia is the worlds leading experter of nuclear technology, and the iran deal from a commercial sense looks an awful lot like a showroom for the russians. But i think what youre looking at may be less a longterm definitive strategy as a russian regime which is pushing on the door, trying to exploit potential opportunities. Plenty of them in the middle east now as the United States appears to retract over the horizon, has less and less equities. Were seeing in iran today what we saw six, eight, 12 months ago, with regard to russian engagement with egypt, for example. This is not because russia has such a enduring stake in egypt and now iran. Its because theres a russian saying that an empty place shall not remain empty for long, a sacred place. This is what youre seeing in the middle east. Okay. This question came in from one of our viewers. Im going to ask a little differently. You have already started to touch on it in one of your previous responses. But is the president s construct of, its either this deal or war is that a valid construct in this case . You get to go last because you already started to answer it. And bruce i want you to answer that one, too. Based on experience with north korea. I just see a logical disconnect on the front end, if its premised as its this deal or war, and then sort of the tail end, when the question is raised of, okay, what happens if iran cheats . One would think, then if the deal has fallen through, youre going to washing you your snapback is automatic military operations. Instead the construct is then, no, we snap back on sanctions. Sort of on the front end there are only two options but on the tail end it said there are three options, including sanctions. Now, pointed out by others, the sanctions are toast, then your threat of snapping back is weak. But it does seem if the result is reimposition of sanctions that means you have three options in the beginning. You could have continue this to try to get a stronger agreement. So, i will just leave it at that. Well, the administration certainly has so weakened and undermind its alternative policy that it seems we have basically set up the stage for say, well, the sanctions dont work anymore because we have trashed them, and the military option is not credible anymore because we drew red lines in syria went and went to play golf and theres nothing left, so take it or leave it. I find it very peculiar that the administration should make that argument because the administration at the same time tells us that the iranians are two months were two months away from breakout, and would dash the bomb if the deal collapsed, but it just signed up to a deal that proclaims extensively and explicitly and in flowery lang that iran will never pursue a nuclear weapon. You can say since the deal says the iranians dont want a weapon and never pursued one, why do you need a deal at all . You just shake hands and go home. What i think is that if the deal were to collapse or if disapproval voter disapproval with veto override were taken as a denunsation of the deal and the iranians said were not committed to it anymore, youre not going to have war. Just like youre not going have war if the iranians cheat egregiously and you walk to a snapback and the snap bark is mike obviously approved. What i think you will see is a number of much less severe, much less grave intermediate options. The iranians, for example, could respond by to a vote of disapproval by saying the americans are in violation of ahn Security Council revolution and could file a complaint and they will play victim. You will see a lot of other much less severe responses, and by the way, one of the arguments. That the administration makes alongside its european allies to justify the and proclaim the effectiveness of the snapback is if there is a political will and a recognized set of violations by the iranians, it will be fairly easy to snap back sanctions. You cant say i have this tool to snap back and its fairly easy to snapback if there is agreement and the mechanism protects the majority from russian and chinese interference and this and that and the other, and then say the only alternative to the deal is war. No, the alternative is if there is a violation, set of behaviors that are violating the deal, or if the american or u. S. Congress or the american the u. S. Administration decide to relist entities on different accounts for syria for human rights violations, terrorism, and the iranians scream and shout and protect, youre not going war. You have a whole arsenal of other policy choices, and to suggest otherwise is disingenious, and if the administration continues to defend its deal and its Foreign Policy with these ingenious argue and sound bites, what does that tell about how good this deal is . Right. So, just two seconds. I answered this already. I think its a strawman argument. I think theres plenty of other options but we are far fewer optimal options than we did before because of the administrations conscious and cognizant walking away from the satisfyings regime and divesting itself of a credible military option and other things. I would actually point out, what emanuel said was very important because were here in washington, and across the street is where the numbers are going to be crunched. If you look at the electoral math, you and you sort of look out it objectively, there is some doubt there will be a veto. Its not a slamdunk. We dont like to use this words anymore but its not a slamdunk, and i think theres some skepticism that this deal, or something very similar to it, wont actually become the law of the land, at least temporarily, and this actually is i think an important Inflection Point for folks who work in congress, because one of the things the administration talks a lot about is what the deal contains. They dont talk about what the deal does. For example, what are the on the Ground Effects in the middle east of an iran that is infused with this kind of capital i talk about in my presentation. So, on. What does it do to global proliferation dynamics . You can sort of begin to list a significant and compelling order of battle about issues that are likely to be affected once or if the jcpoa kicks in, and one thing that theres really not a lot of talk about now but should be, is how do we manage the consequences . Are our institutions, in the u. S. Government, whether in the executive branch or legislative branch our institutions really keyed in to being able to respond effectively to additional iranian influences of cash to global terrorist groups. Are we properly moderating proliferation dynamics out of space the middle east. These are all serious questions and questions that can be the basis of new legislation or new orders of battle for different governmental agencies, but this is the dog that has been barking. We are in the process of deliberating a deal which, if it goes through, will put into play a series of very significant trend lines in the middle east and far beyond that are likely to affect american security. So we should be thinking, even as we think about whether or not to pass the deal see, think about what we do if the deal passes, how do we manage the consequences. Okay. Somebody over here . I havent got anybody on this side yet. No . Other questions. All right. Ive got a wrapup question for all of you. Youre each now sitting at as te new National Security adviser to the president of the United States today, and the president of the United States in 2017, january 21st. Give you a couple of minutes each. Tell me what advice would you give this president , what should he do, and what advice would you gave new president . Well, im not going to start with that one. Well, i cant really conceive of doing that because not being an american, u. S. Citizen, i could never i would be disloyal to my country if i served a foreign government. We have friends. We can get you squared away. But just for argument sake, i think that its easier to give advice to the next president. My impression and i dont mean to be disrespectful this president only takes advice he agrees with. But the next president may be more openminded. I would advise the next president to hold the iranians feet to the fire and to restore the deterrence of the United States, both militarily and otherwise, starting from sanctions. Reminding the president that policies never a choice between two mutually exclusive options, not either fund the irgc or build bridges. Its a bit like asking a blue Collar Worker who just won the 150 billion at the lottery, will you buy a house or will you buy a car . Ill do both. So, thats would be my advice knowledge restore deterrence using all the tools in the policy box and dont be afraid if the iranians then to walk air. They still need this agreement more than we ever did. I guess id refer to previous advice and say, sir, dont you remember, dont do stupid stuff . At some point youre just sort of so far down a rat hole you dont know how to get out. When glory a hole, stop digging. When youre in a hole, stop digging. Emanuels point is good. Separate from the negotiations ensure you have sufficient resources devoted to security requirements to suitably defend yourself and your allies. We hey been undermining the defense department, even before sequestration, with massive defense cuts so right now, there is a serious question about u. S. Capabilities, given those massive cuts as well as u. S. Resolve. When someone says, all the options are on the table, i dont think people really believe that. On the asia side, we have been hearing from allies, throughout the region, theyre concerned about u. S. Resolve and u. S. Capabilities. They can see theres no there is no asia pivot. Its a good talking point but no resources there for it. Its more of a divot. So i think i presume were hearing that from our european and our middle east allies, is that theres concern in the direction were going, concern about the lack of capability, the lack of resolve, so that will there be a desire or inclination to do a snapback . I dont really think so. I think it would be a lot of intel is really difficult. I did it for 20 years. Its really hard to get smoking gun, slamdunk. We dont like that phrase evidence of cheating. It takes time. And when youre premising an agreement on something that, well be able to find it quick enough to impose sanctions which emanuel says takes tomb to do theres just so many things that to me dont add up. So i would parenthetically say i was in a position of advising both this president and the next one, theres something asecure at the office of personnel management. That aside, i would make the case and i think the point that the president is sort of on a Foreign Policy path where theres not a lot of room for deviation or disagreement from his advisers is correct. I would only make the point that for a president who prides himself on his Foreign Policy acumen and his flexibility, he has left remarkably unused the tool that he has at his disposal, which is to use congress as a bad cop. You could have hammered out a much more beneficial deal for a longterm american Strategic Interests simply by saying were a democracy, i am constrained by my legislative branch. My legislative prank hat its open prerogatives. Theyre insisting i put this and this and this on the fable that could be back his city Ballistic Missiles or human rights or Americans Still in jail in iran. Thats not very good advice because im not sure theres a lot of sunlight to penetrate here, but for the next president , i think what youre seeing dish think youre beginning to see it in the primary debates on both sides of the aisle, is this sort of emerging theme of, we need to mend it or end it. I think thats its elegant in its simplicity but i think its more than that. I think we need to also, if we have an administration that comes in and really begins to reassert american prime si glowil and have our response to the nuclear deal be part of the to roll back iranian adventures. Several years ago, about 20 years ago, Danielle Patrick moynihan. The then senior senator from new york, wrote a piece about criminal justice and defining deviancy down. Thats germane here because were defining irans deviancy down. Our problem with iran just extend to the nuclear program. It deals with its support for terrorism, the attempt to remake the middle east in its own image. All things that an administration that is fully committed to engagement win. The middle east will have to deal with. Not just about the nuclear portfolio, and the quicker we can get out of that policy culdesac and think about the iran challenge more broadly, frankly, the better off well be. Well, folks, we had a pretty rich discussion here this morning. This is a very, very difficult issue set. Its not just one issue. Its a whole set of them. It is not amenable to Simple Solutions. Anybody who offers Simple Solutions to this kind of problem set, you probably dont want to listen to because it takes more than a Bumper Sticker to deal with these kind of problems. I would ask each of you to take what you have heard this morning, resume nate on it, think about it, and come to your own conclusions. Dont just take the headline off this mornings paper or some other paper. We have some heavy lifting to do in this country to address these problems. Please join me in thanking the panel. [applause] and we thank you for your kind attention. Were concluded. [inaudible conversations] the cspan cities tour visits Historic Sites across the nation to hear from authors, specific leaders. Every other weekend here on booktv, and American History tv on cbs 3. And this cspan3, and this month the cities tours on cspan each day at 6 00 p. M. Today we visit ohama to learn about the history of the largest city in nebraska. And after that at 7 10 p. M. Donald trump holds a town hall meeting in enough. Live coverage from hampton, new hampshire, at 7 10 on chance. And tonight at 58 eastern on cspan 2 its bookve in primetime with president candidates on their recent books. First, mike huckabee, at 9 00, retired neurosurgeon ben carson on his book, one nation. What we can all do to save americas future. And then at 10 00 eastern, senator marco rubio and his book, american dreams, restoring Economic Opportunity for everyone. And at 10 25, we hear from a democratic president ial candidate, hillary clinton, talking about her book, hard choices. With the u. S. Senate in recess, this august, booktv is in primetime each week night starting at 8 00 p. M. Eastern. Cspan is in des moines for the iowa state fair and road to the white house coverage of president ial candidates. Our live coverage is on cspan. Cspan radio, and cspan. Org. As the candidates walk the fairgrounds and speak at the des moines registers candidate soap box. Heres the schedule. Saturday, republican Rick Santorum at noon. Followed by democrat Lincoln Chaffee at 12 30, and senator Bernie Sanders at 3 00. And on sunday afternoon, republicans ben carson 5 00, and George Pataki at 5 30. Cspans campaign 2016, taking you on the road to the white house. This sunday night, on q Arkansas Institute for policy studies fell explore antiwar activist, Phyllis Benis on u. S. Foreign policy since 9 11. The recent negotiations with iran and the war on terrorism. Who is isis . All those questions are important and i address them in the book. What is more important in some ways because its something we can do something about, is what is the u. S. Policy regarding isis . Why isnt it working . Can we really good to war against terrorism . Are we just doing the war wrong or is it wrong to say there should be a war against terrorism at all . I think those are the questions that in some ways are the most important and that will be the most useful. Sunday night at 8 00 eastern and pacific on cspan2s q a. The Environmental Protection agency yesterday announces it will begin to regulate Greenhouse Gas emissions from airplanes. Because the emissions endanger human health by contributing to Climate Change the epa announced will will develop rules to limit airplane emissions as the agency has done with cars and power plants. The public hearing at epa headquarters in washington this week was two hours. Im the director of the Climate Change division at the u. S. Environmental protection agency. On behalf of epa i would like too welcome you to todays public hearing. Thank you for taking the time tout come and participate and communicate with us today. As you all know, just to be clear, the title of todays hearing is proposed findings the Greenhouse Gas emissions for aircraft cause or contribute to air pollution that may reasonably be anticipated to endanger Public Health and welfare and the advance notice proposed rulemaking. Thank you for coming today. Bet he start by introducing my fellow panel members. Far left. Lina williams, office of general counsel. Mike, director of the large Marine Aviation center. Bill, the director of the assessment and standards division. Brian from the large marine and aviation center. Leslie, from the Climate Change division. Thank you. Just to reiterate the purpose of the hearing today is to receive comments from all interested parties on the proposed endangerment finding and advanced notice of proposed rulemaking. This action, as many youve know, was published in the federal register on july 1, 2015. In this action, the administrator is proposing to determine the Greenhouse Gas concentration nets the atmosphere endanger the Public Health and welfare of current and future generations within the meaning of sex 231a of the section 231a of the Clean Air Act. The administrator is proposing to fine that Greenhouse Gas emeteorologistings from certain engines used in commercial aircraft are contributes to the mix of Greenhouse Gas air pollution in our atmosphere. Todays hearing provides interested persons the opportunity for all presentations and views and arguments. Witnesses will bev allowed to make oral statements which they may later expand on in writing for the record. When you are finished with your comments, members of the panel may ask clarifying questions. However, this hearing is not intended to be a discussion of the proposed findings or the advance adenoids of proposed rule making. We might ask questions or request additional date attemptunder or supporting materials we will not respond to comments in this forum. Instead we ask you please provide written comments as part of the record as finalizing this proposal. If any members of the audience today that wish to testify have not already signed up, please submit your name at the registration tle back at the entrance in the room in the foyer. Everyone attends here today should sign in regardless whether youre schedule to testify. Finally, before i turn to my colleague, bill, let me remind everyone that in addition to todays hearing, there is also an opportunity to send us written comments. Comment period closes august 31, 2015, at 11 59 p. M. Eastern time. Details on where to submit written comments can be found in fed register notice that announces the proposal and on our web site and the fact sheet available at the registration desk. So, with that introduction, let me turn it over to bill. Thank you, paul, and good morning. Concurrent with the proposed findings on july 1, 2015, epa also issued an advance notice of proposed rulemaking, referred to as an anpr to provide Additional Information on the process for setting engine aircraft Greenhouse Gas standard. Should the epa issue positive final and endangerment findings. The npr, largely folks on effort to set international co2 emission for aircraft. And how those efforts may inform epas future action. This advance notice described and vehicles input on issues related to setting an international co2 standard for aircraft and be potential use of 231 of the Clean Air Act to adopt and implement a possibly corresponding International Engine aircraft engine co2 or grownhouse gas emissions standards domestically. This standard is expected to be adopted in early 2016. Epa is requesting comment on a number of issues related to setting the standard for aircraft and these include, the appropriate effective dates for potential standards, the appropriate stricken general si level and whether standards should apply to new and production aircraft as well as new aircraft. Let in go over how we will won duct the hearing. We are conducting the hearing under section 703 of the Clean Air Act to provide interests persons an opportunity for pole presentation and written submissions on the proposed findings. Were having this hearing recorded and transcript will be available for public inspection and copying in the radiation docket, docket number epahqoar 20140828. The transcripts will be available electronically, and epas web site and on the regulations. Gov web site. The official record of this hearing will be kept open for 30 days after today, to provide opportunity to submit rebuttal and supplementary testimony. You may submit this additional testimony to the same docket for this action by using a method prescribed. This hearing will be conducted informally, paul and i will be serve as the copresenting officers for the days hearing and are authorized to apply rome limits on the duration of the statements of any witness. Each person will be given no more than ten minutes to provide his or her verbal testimony. Paul and i have been asked have asked epa personnel to serve as timekeepers, right down here. Please speak slowly and clearly so are Court Recorder can record of these proceedings accurately. In order to streamline the process members of each group should be in the room and advance other protected group time and should be prepared to make their way to the front of the room while the previous members are giving their testimony. And depend on the number of suppliers where today we may at end up taking a break during the day. Finallyday. Finally, while the representatives will attempt to assure the accuracy of any description we provide more discussion of the proposal in the npr the official version of the proposal that is published on july 1 of 2015 and it controls any cases of conflicts between it and what you may herr today. Please refer to the official version when developing your written comments on the proposal or on the npr. Thank you, and with that we like to call the first group of witnesses to speak in this order. Dr. Nick lutsey from International Council on clean transportation. Nancy young from airlines for america, and nancy kruger from the National Association of clean air agencies. Thank you. Good morning. Thanks for the opportunity to give these remarks. Wayne andersen nick lutsey, im a Program Director of the National Council on clean transportation. The icctf an independent Nonprofit Organization founded to provide first rate Unbiased Research and Technical Analysis, environmental regulators. The icctf appreciates the opportunity to provide his testimony on epas aviation endangerment finding and advance notice of her post will making on aviation Greenhouse Gas emissions. Our comments are informed by the engagement of icct staff environmental working groups to the International Civil Aviation Organization, or icao, since 2008. In particular since 2009 we have contributed Technical Analysis to efforts to develop the International Carbon dioxide, or co2 standard, that is referenced heavily within the anpr. Our comments will focus on the following points. First, the scope of the endangerment finding, second, different ability, timing and stringency of an international or domestic co2 emissions standard. And third, potential domestic reporting requirement for aviation manufacturers under the Clean Air Act. Epa has proposed that the endangerment findings focus on 16 Greenhouse Gases. We concur with his general approach with caveats. We agree with the epa the assessment of scientific uncertainties on the Climate Impact of nitrogen oxide, or knocks, and water vapor emitted at altitude remain high enough so as not to address them in this initial endangerment finding. The science regarding the contribution of black carbon to Climate Change on the other hand, is clear. Black carbon was identified as the second most important contributor to anthropogenic emissions in 2013. To reflect the latest like an epa should consider incorporating black carpet 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, but land and takeoff emissions to include crude emissions. Icao sli two general approaches for the applicability of an international co2 emissions standard. In the first approach only new aircraft designs being type certified or 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 our analysis, covering all new aircraft delivered after a certain date will be necessary for the standard to significantly reduce emissions beyond business as usual. Since a new type aircraft are rare, our analysis suggests that a new type only standard beginning in 2020 would only cover about 5 of the global fleet in 2030. As opposed to a requirement after affecting all new aircraft which could cover more than half of the global fleet that you. 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 the technological feasibility. In 2013 thank you decided only technologies 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 with entry into service of 2024 or later due to the time required for certification. This time lag combined with the decision that at most standards can require stateoftheart 2016 technologies when a limited means that even the most aggressive standard will lack the fuel efficiency of new yuletide aircraft when they enter into service. For these reasons we concluded 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 international and or domestic co2 standards should be set to require at least stateoftheart 2016 technologies for new aircraft types certified after the standard takes effect. Icao is also investigating a tiered approach under which deliveries of new in production aircraft, or models that are type certified before the standard takes effect, they have separate target apply to the. Pending additional analysis, and lower stringency level may be appropriate for those types but still within the highest three levels identified by epa in the anpr them. On timing in order to minimize the number of years a new type of regulatory level lags business as usual aircraft, instead should be applied for new type as early as possible, in this case 2020. Early implementation for new in production aircraft either in 20242023 is also preferable. Finally, since the discussions on a National Commission standards the semistatic stringency level, it would be appropriate for the u. S. To press for early icao review in international co2 standard starting in 2019 so that the updated requirements are in place to drive Additional Technology Development Beyond 2020. Regarding manufacturing 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 the development of a voluntary database for co2 only. We believe that detailed mandatory reporting is necessary to ensure transparency and a level Playing Field across manufacturers. Finally, as noted before we believe that a collection of crude nox david domestically would help improve our understanding of the Climate Impact of aviation nox in nations that epa would need to analyze the cost and complexity of developing measurement and reporting protocols for crude nox if it decides to pursue this approach. Are more detailed, to be submitted to epa in writing in addition will submit an update to the 2009 study referenced in the anprm entitled efficiency transfer new commercial jet aircraft to the public docket. The two studies together highlighted 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 here today and for epas continue work on this very important topic. Minus nancy young, i am the Vice President of Environmental Affairs or airlines for america, representing a major passenger and Cargo Airlines in the United States. We appreciated this opportunity to testify regarding epas proposed fines on aircraft Greenhouse Gas emissions advance notice of proposed rulemaking. As the record of our members demonstrate, we take our role in controlling Greenhouse Gas emissions very seriously. For the past several decades u. S. Airlines have dramatically improved fuel efficiency and reduced Carbon Dioxide emissions by investing billions in fuel saving aircraft and engines, Innovative Technologies like winglets and cuttingedge route optimization software. As a result, although u. S. Airlines comprise 5 of u. S. Economic activity, they account for only 2 of the Greenhouse Gas emissions inventory. The industry improved fuel efficiency 120 since 1978, saving 3. 8 billion metric tons of Carbon Dioxide emissions, the equipment of taking 23 million cars off the road each of those years. Further, the u. S. Airlines carried a 20 more passengers and cargo in 2014 than they did in 2000, while the meeting 8 less Carbon Dioxide. This by the industrys strong record to date, however, we are not stopping there. The u. S. Airlines are active participants in the global Aviation Coalition that is committed to 1. 5 annual average fuel efficiency improvements through 2020, and carbonneutral 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 of 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 development in aviation environmental technology. In addition, we are dedicated to developing commercially viable, sustainable alternative Aviation Fuel which could further reduce aviation Greenhouse Gas emissions while enhancing u. S. Energy independence and security. A4a is a Founding Member of the commercial aviation alternative fuel initiative, a Publicprivate Partnership with faa and other stakeholders that is working on the development and deployment of such fuels. Having helped lay the necessary technical groundwork, a4a members have already begun to use bio jet fuel on commercial flights. Further, our Industry Coalition is 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 goal of carbonneutral growth from 2020. It against this backdrop that a4a welcomes the opportunity to submit a full set of comments on epas proposed findings, and anpr, by the august 31 comment a deadline. For the purpose of this hearing, a4a offers five preliminary observations. Observations. First, a4a concurs with epa that it is appropriate for the agency to limit its endangerment and cause or contribute findings to the six well mixed long live the Greenhouse Gas emissions. As epa points out in its proposal, aircraft only in the two of those six emissions. 99 of which is Carbon Dioxide. As Carbon Dioxide is directly related to fuel burn and with the jet fuel as the number one cause 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 nations Greenhouse Gas emissions inventory of a sources epa previously has sought to cover with Greenhouse Gas Emissions Regulation on road Motor Vehicles and power plants, respectfully account for 23 and 31 . Third, given the industrys domestic to efficiency record and economic incentives to continue that trend, theres 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 their aircraft in international markets, it is critical that Aircraft Emissions standards be set at the International Level and not impose unilaterally. Accordingly, we appreciate the direct engagement that epa and faa and the development of aircraft Carbon Dioxide certification standards 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 without aircraft standards highly rigorous, but the icao criteria for adopting such standards aligned well with the criteria under section 231 of the Clean Air Act. Fourth, a4a strongly supports epas stated intent to adopt the future icaos co2 certification stand into law consistent with the Clean Air Act, its treaty obligation and in harmony with the International Community. Finally, a4a urges epa to take note of the fact that the future icao co2 certification standards for new aircraft is but one arrow in the Aviation Industries quiver for meeting its emissions goal. Faas nextgen initiative, publicprivate research and develop partnerships, our collaborative efforts to deploy sustainable alternative Aviation Fuels at commercial scale, and a vast array of additional operational and Infrastructure Initiative being undertaken by airlines, airports, manufacturers, and other stakeholders are also critical arrows in the 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. Im nancy kruger, Deputy Director of nacaa, the National Association of clean air agencies. Thank you for this opportunity to testify and provide preliminary comments for nacaa a epas proposed aircraft endangerment finding advance notice of proposed rulemaking seeking input on icaos Ongoing Development of International Aircraft standards for co2 and also the potential Forthcoming Development by epa of aircraft cabin outside the mission standard. Nacaa is a National Nonprofit nonpartisan association of air pollution control agencies in 41 states, the district of columbia, four territories, and 116 metropolitan areas. Our members, professionals and our agencies have asked each to improving air quality in the u. S. , and our testimony is based upon that experience. First with respect to the endangerment finding, nacaa commends epa and supports in on its proposal to find that ghg concentration in the atmosphere endanger the Public Health and welfare of current and future generations within the meaning of section 231 a of the Clean Air Act, to find that ghg emissions from certain aircraft classes cause our country to air pollution that endangers Public Health and welfare, and also to use the same definition of air pollution under section 231 a as the agency used in making its 2009 endangerment finding with respect to Motor Vehicles. Epas states in its proposal that the 2009 endangerment finding is, established and well settled, and that there is no need to open or revisited to make additional finding under section 231. Nacaa agrees and supports epa proposal to make such additional finding now. Epas proposed finding under section 231 sets the stage for harmonizing international and u. S. Aircraft co2 Emission Standards. With icao expert to adopt International Standard as early as february 2016, we appreciate epas request to the anpr for input on establishing that standard and the potential use of Clean Air Act section 231, to adopt and implement the icao standards domestically. Nacaa supports of the United States continued support for adopting an International Standard as well as pd epas adoption of a domestic stand that will address the source category in a siificant way. Aircraft represents the single largest u. S. Casper tatian source of Greenhouse Gas emissions not get subject to Greenhouse Gas standards. Clearly, this is a sector that merits regulation commensurate with other transportation sectors. Icao and epa must establish as rigorous and comprehensive regulatory package as possible. In the u. S. This is especially critical because state and local air pollution control agencies do not have authority under the federal Clean Air Act to regulate Aircraft Emissions on the limits set by epa. Accordingly nacaa offers the following overarching to live in the comments are three in the anpr. Applicability, timing and stringency of an aircraft co2 Emission Standard. Icao is considering various approaches for the applicability of an aircraft co2 standard with a fundamental question being whether that standard should apply to in production aircraft or only to complete the new aircraft type design. Nacaa believes it is essential that standard applied to both in production aircraft and a type designs, and that the definition of in production be unique of aircraft produced after the compliance deadline. We simply cannot forego that Emission Reduction regarded from regulated in production engines and find no persuasive reason to forego them. On the issue of china, nacaa recommends the center take effect as soon as possible by 2020 for new aircraft types and a 202314 production engines. Im sorry, aircraft. Nacaa is still studying this stringency object identified by epa and the anpr. However, we can say now that our association strongly encourages icao and epa to set the standard that is a stringent as possible at the state of the technology forcing rather than technology following. Nacaa would also like to touch briefly on a few additional issues related to aircraft co2 emissions standard. First, we recommend engines associate with but not part of aircraft also be addressed by aircraft co2 standards, key among these are auxiliary power units. Second we recommend epa pursue opportunities for establishing standards in use aircraft which for example, can be retrofitted with winglets to reduce draft and safer fuel. Third, although the standard at issue is for co2, theres also the potential for additional nox the nation reductions and we encourage epa to analyze the potential carefully and take steps to maximize reduction. Finally my nacaa supports the establishment of an International Aircraft co2 standard, through icao, a domestic stand to reach the full measure of potential reductions from the source category is critically important. Therefore, we urge that epa be prepared to adopt a more rigorous program and standard than icao if the International Standard falls short, including the respect to the items weve raised in this despotic will continue to study these and other issues related to epas proposed endangerment finding and anpr and offer additional comments in writing by the august 31 deadline. And in the meantime we appreciate this opportunity to share our views and look forward to continue to work with you on this important initiative. Thank you. Thank you all for your thoughtful comments or i appreciate that. The agency appreciates your comments to let me now call the second group of speakers up, please. Thank you. So in the second group, we have mr. Eric white from the California Air Resources Board, joe depete from the air Line Pilots Association international, and mr. James lee, never of the public. Member of the public. And just for everybody purpose, into the mic, please, nice and loud so we can hear. Good morning. Thank you for the opportunity to testify before getting on the proposed endangermen endangermen advanced notice of proposed rulemaking for Greenhouse Gas emissions of aircraft. My name is eric white and then chief of the mobile Source Control Division at the California Air Resources Board. The air Resources Board is a telephone state Agency Responsible for meeting federal air quality standards in coordinating the states activities to reduce Greenhouse Gas emissions. Arb will be providing written comments into the docket. However, i am here today to emphasize the need for Strong National Greenhouse Gas Emission Standards for aircraft and to reemphasize the unique opportunity that u. S. Epa has to be a Global Leader producing aviation emissions. Id like to begin by reiterating part of the testimony provided by the arb chairman mary nichols in 2008 at hearings for regulation of Greenhouse Gases under the Clean Air Act. At that hearing chairman nickles said Climate Change is a real and urgent threat to our communities, our states and our nation. Over the past 100 years we have experienced a seveninch c. Rice, eroding our coastal communities at threatening to go infrastructure. In the winter more of our precipitation in california is falling as rain and snow leading to less water availability in the critical spring and summer, and impact of threads when of the most productive agricultural regions in the world, and a pillar of the nations export economy. Climate change is also a major factor in our longer and more severe wildfire season. It is predicted that without major efforts to reduce Greenhouse Gases in this century, california will see a one to twofoot sea level rise, 75 loss in snowpack, twice the frequency of drought years, and 55 more large forest fires. Our comments are even true today than seven years ago estimate shared by the severe drought and wildfires that are put in california even as i speak. The passage of californias Assembly Bill 32, the Global Warming solutions act, established one of the worlds most comprehensive and ambitious Greenhouse Gas reduction program, imposition california to be on the forefront of addressing Climate Change emissions. However, in some sectors such as aviation, california and the various states are dependent on the federal government to set the most aggressive standard feasible. In that vein to Clean Air Act provides you a cpa with both the authority and responsibility to deal do what california any other states cannot do by themselves. Today, i speak before you to support the endangerment finding that Greenhouse Gas emissions from aircraft cause or contribute to air pollution that may be reasonably anticipated to endanger Public Health and welfare. As stated in californias 2007 joint petition for Aircraft Emissions rulemaking and comments on the 2008 advanced notice of proposed rulemaking for Greenhouse Gases, under the Clean Air Act, the overwhelming Scientific Data to support the claim that air pollution made up of the elevated atmospheric concentrations other six well mixed ghgs endanger both the Public Health and public welfare. Since that time new scientific assessments of further substantiated the detriment of effect that ghg commissions. As a certain 2007, the u. S. A. Has the obligation under section 231 of the Clean Air Act, to set standard accordingly once the endangerment finding is made. As noted Aircraft Emissions make up the Third Largest u. S. Transportation source of ghg is after emissions from light duty vehicles and medium and heavyduty trucks. The aircraft ghg commissions, 11 of you ghg commissions from transportation are greater than all other transportation sources combined that come after it. It remains the single largest unregulated ghg in getting transportation source in the u. S. Furthermore, it is estimated use aircraft will exit the largest growth in ghg commissions among all transportation sector vocations. As such, it is imperative that the sciences and expeditious action be carried out to stem ghg emissions from aircraft. Arb recognizes that the International Civil Aviation Organization is anticipated to promulgate a co2 Aircraft Emissions standard. While this is a promising initial step in controlling ghg commissions from aircraft, historically icao emissions standards have been technology following, not technology forcing as such, arb is concerned that the standards eventually adopted by icao may not sufficient to reduce ghg commissions passed the business as usual scenario. Arb supports the International Establishment of Aircraft Emissions standards that are as stringent as possible, and in the absence of a strong showing by icao we urge usda to extend its Regulatory Authority further at the top a co2 emissions standard that will be forwarded, that will for Technology Development and provide accelerated reduction. There are a variety of both aircraft design and aircraft Engine Technologies under development which showed tremendous promise in furthering national and california in ghg Emission Reduction goals. Due to the importance of collecting data to ascertain Regulatory Compliance as well as policy decisions on future co2 Emission Reduction opportunities. The reporting requirements can be stand alone or in conjunction with the Emission Standards for new engine production aircraft types. Further , as a complement to the co2 Emission Standards, usepa is encouraged to take reduction opportunities including retrofit requirements for aircraft with fuelefficient technologies and reducing auxiliary power units on aircraft. And encourages u. S. Bpa to further reduce aircraft engine criteria pollutants particularly oxygen and nitrogen. Mitigation of aircraft related emissions remains a critical part of the mission reduction strategies and working to do its part by ensuring other aviation related emissions reduction opportunities pursuing other aviation related emission opportunities. For instance in the nearterm, up we will consider emissions for Ground Support equipment, Airport Shuttle buses and other airport related emissions. In the event that iko fails to adopt an Emission Standard by next february, standards go far beyond business as usual. Were review s e p a to act independently of iko in establishing Strong National see is the emissions standards without further delay. California believes it is clear u. S. E d a has more stringent regulations on u. S. Aircraft and engine manufacturer and we believe the overwhelming Scientific Data has proven aircraft the h g e missions in danger Public Health. Therefore u. S. Epa has the obligation under section 231 of the Clean Air Act to study Emission Standards expeditiously as possible. With time the regulation of major sources is critical to meet our national g h g goals. Thank you, joe depete. Thank you for the opportunity to present this public hearing which i served as the first Vice President of the airLine Pilots Association international and also served as National Safety coordinator. I am also affects pilot, capt who flies the airbus a 300. Alpha is the Worlds Largest professional Airline Pilots union. We have more than 52,000 members who fly 31 airlines in the United States and canada. I would like to give a view on what epa proposed finding regarding Greenhouse Gas emissions and advance notice but first i would like to provide some context about why we are passionate about this subject and also talk about the positive difference u. S. Airlines are making to reduce the emissions while safely transporting 2 million passengers and 63,000 tons of freight and mail each day. Airline pilots literally sit at that intersection of technology. Aircraft operating procedures, aircraft Traffic Control procedures and techniques and varying aircraft capabilities. This gives us the unique Vantage Point from which to manage our aircraft capabilities in such a way as to burn less fuel while operating as safely and the efficiently as possible. The principal goal is to further the advance aviation has made towards reducing Greenhouse Gas emissions and improving the efficiency of the industry while maintaining or improving current levels of safety. Improved engine and aircraft technologies resulted in significant reductions of harmful emissions, increased reliance on satellite based navigation would lead to even more significant reductions. In addition these improvements contribute to the need to ensure ongoing viability and sustainability of the airline industry. Youll is the largest single expense our airline employers face. In addition to the need to act responsibly toward the environment airlines have a very strong motivation to safely find ways to use as little fuel as possible and look for alternative fuels that are not lessexpensive but also have less effect in our environment. The simple fact, whenever affects our employers ultimately affect pilots as well. We have similar financial incentive to help from conserve fuel. Pilots work with their companies and airTraffic Control on a daily basis to safely reduce the burden while additionally our membership is cognizant of the need to protect our environment just like the airlines. We strive to do that on every flight within the bounds of safety which is of course our primary focus. Al alpasupports the small percentage of contributions to Greenhouse Gases but at the same time preserving the economic viability of the airline industry. These two goals are complementary. As fuel and operationally efficiency continues to improve economic viability is enhanced. Airtran sprint haitian is a significant portion of the Mass Transportation system in north america. U. S. Airlines transport 775 million passengers and carryon about 23 million tons of freight and mail each year. Aviation arguably has the most successful record of any sector in the economy in limiting its impact on the environment while simultaneously increasing productivity. Airlines have agreed to reduce carbon based emissions through ever advancing Engine Technology that reduces fuel burn and the missions of gases and particulates. We have also use their frames that are lighter, stronger and create less fuel burning drag. Compared to 1972, north American Airline industry now carries six times more payload using 60 less fuel per flight. It is reduced by 95 the number of people significantly impacted by aircraft noise. Because of these advances Airline Domestic travel accounts for only 2 of all Greenhouse Gas emissions while accounting for about 5 of Gross National product. The bottom line for alpa is we a strong advocates of staying the course when it comes to new fuel efficiency through technology. Airlines must be able to afford to invest in new more efficient aircraft engines that reduce the impact on the environment which has been the key to their success. Concerning the e p as announcement were pleased the agency is working with the iko committee on Environmental Protection and is engage in developing a future aircraft certification standards for co2, Carbon Dioxide. We urge the agency, to be slated to consider approval february 2016. Iko is in a position and bring together World Airlines to develop a standard that will be adopted by the United States and canada. Going beyond agreed on standards could have a detrimental effect on our airlines. Alpa is a strong proponent of a level Playing Field for all airlines, creation of the u. S. Specific emissions standard that is more stringent than that used by other iko nations putting in a distinct disadvantage without a commensurate benefit. Regarding advance in p r in, alpa does not leave new emissions standards would operate for a fitting of in Service Aircraft or aircraft on order. Or new types of aircraft that are yet to be certified so as not to cause financial harm. I thank you for the opportunity to speak with you today and i will take any questions you may have. My name is james lee from south carolina. Why is the epa claiming six Greenhouse Gases emitted from jet planes are threat to human health and to the Clean Air Act while doing nothing to address ongoing lawsuits over unleaded aviation gasoline or the real Health Concern stakeholders worldwide . Cancer causing heavy metals and fuels and their additives and aviation induced cloudiness. The epa claimed the authority to regulate aviation emissions under the Clean Air Act, the law that should protect us from the aforementioned pollution. However the definition of pollution is being perverted 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 of as you can see by wording of the Clean Air Act, lead, barium, aluminum and toxic chemicals prevent a greater danger to Public Health and Greenhouse Gases no matter how much Climate Science you accumulate. Furthermore material safety data sheets of aviation additive is almost always contain the same morning, do not dumped in water. Yet raw fuel dumping or burning these chemicals, dangerous chemicals and then dumping the in water is somehow safe. Finally despite great efforts on by accumulation and magnification said is understood the aviation pollutants none seem to exist. And visible Climate Change concern by airplanes, cloud creation. Search for cam trails on the internet and you will see millions of concerned citizens who look up and wonder what they are 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 shall all be concerned. Epas claimed the co2 is greater threat to human health and aviation in this cloudiness is based on incomplete i dcc dated the downplayed the effect of contrails on the climate. Their fourth assessment of confrere radiative forcing accounted for linear contrails meaning any contrail that spreads out and turns into spheres clouds was not accounted for. How significant is this heat trapping contrail conundrum . Quote, contrails form by aircraft can evolve into cirrus clouds and distinguishable from those that form naturally. These spreading contrails may be causing more climate warming to date on all the Carbon Dioxide emitted by aircraft since the start of aviation. Another researcher stated a single aircraft operating in conditions favorable for persistent contrail formation appears to exert a contrail industry reinforce 5,000 times greater than the estimates of the average persistent contrary radiative force from the entire civil each in fleet. Aviation fleet. All those is research has been incorporated into the ipc see computer models and revised tel aviv claims highlight gaping holes in Climate Science. In 2013, quote, aerosol clouds are the one of the main uncertainties in climate research. Scientific understanding of how contrails transition in choosers clouds severely lacking rapidly evolve in with the latest Research Showing cirrus clouds are filled with metal aerosol from human sources, quote, the big one we found is led coming from things like that dreadful lead in fuel so that is 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 metal particulates have major affect on cirrus clouds, quote, it would seem that you would have to change all of the aerosol in the atmosphere very radically to get a big affect on the clouds but because minerals and metallic particles are such a small amount of the particulate matter, just 1 or 2 in means you only have to change about 1 or 2 of the particles to get a big effect on these clouds. The latest research cast doubt on the ipccs contrail assumption and requires serious consideration when addressing the real Climate Change impact of aviation. Highaltitude metals and sears cloud condensation likely coming from leaded gas and jet exhaust. Contrails im making cirrus clouds and small changes in hemispheric metal have large impact on sears cloud creation. Cirrus clouds wrapped heat and are likely to have greater impact on Climate Change and co2. Finally aviation in this cloudiness endangers future growth in solar energy, affects tourism, and is projected to make terrestrial astronomy impossible by 2015. Geo engineering scientists, nasa, noaa, faa, the o e and International Corporate partners are discussing the use of biofuels and sulfur jet fuels for contrail control. This seeress cloud seeding to mills these clouds away. That epa should be directly involved in these discussions. As a result of these recent filings, i strongly encourage the epa to consider expanding the scope of is in danger and to include metal particulates and cloud formation from jet exhaust. If the iea complies with the spirit of the Clean Air Act will protect us from metal aerosol the treated to bossism, cancer and a plethora of other debilitating illnesses and regulate production of contrails and cirrus clouds would change our climate to greater extent than the sum of the Greenhouse Gases named in the proposal. Regulating heavymetal seen aviation in this cloudiness will be meaningless without proper verification. Even though members sign an agreement to use certain chemicals, and without proper verification. Request mandatory, random testing of jet exhaust immediately be implemented. This is the most important step the epa can take to follow the spirit of the law. Due diligence to protect us from harmful pollution and get realworld data to improve future regulation. Most of the data from this finding comes from research in highly controlled environments where most variables are none. And non ideal situations where fuel fowling, same contamination or improper maintenance, and exhaust particulates than seen in lab settings. To achieve verification i propose the epa at catch a trailing probe to foreign and domestic flights and collect and analyze the results to determine real world disaster constituents. Alternatively groundbased observations may be possible over high traffic areas to prevent possible terrorist attacks using aerosol. Either way you choose we need verification and protection. In conclusion, epa should expanded to endangerment to include edlundaerosols in cloud creation and all aircraft, protect us from aviation pollution, hold violators accountable and commit to better scientific accuracy for future determination. Thanks on behalf of people who could not be here and thanks for listening to a laypersons views on this subject. I appreciate the center for biological diversity and friends of the earth, get the epa joel the Aviation Industry accountable, up for people like myself have to live near these airports under these fuel dumps and under these clouded skies. I hope some face can be restored in our epa by your action here, tell the icao that they will meet your demands. Thank you for your comments. Second panel. Thank you. Call for red the group number 3 panel at this point so this would be, a apologize if im not announcing everyones name properly but leslie riegle, doug wolf and michael cerrecino. Im the director of environmental policy at the Aerospace Industry association. Thank you for the opportunity to testify on epas proposed endangerment finding and advance notice of proposed rulemaking on aircraft Greenhouse Gas emissions. E i a is the largest trade association representing the nations Major Aerospace and defense manufacturers. We represent more than 300 u. S. Manufacturing companies with near the 1 million skilled employees. Our members are recognized across the globe for manufacturing reliable, uncompromisingly save aircraft that connect passengers and cargo and help defend our National Security. Our industry is heavily regulated and must pass grueling safety and air worthiness 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 has been setting global aviation standards for 50 years. This globally harmonize model has worked well for the United States. The u. S. Aviation industry has thrived on the a global Playing Field as evidenced by the positive impacts the we play on the National Trade balance and hope to continue to build on this modelers we develop new fuelefficient the state is for aircraft. The commercial Aviation Industry has a strong environmental track record including Technology Improvements and reducing aircraft, and dioxide emissions over time. Todays commercial aircraft are 70 more fuel efficient than aircraft flying 50 years ago. Greater fuel efficiency translates into reductions in Aircraft Fuel consumption and co2 emissions. The commercial Aviation Industry has achieved greater fuel efficiency and lower emissions even as it has grown. Today morrison 3 of global Gross Domestic Product is supported by aviation. Only 2 of global co2 emissions are attributable to aviation. It is for this reason the commercial Aviation Industry is committed to build upon its strong environmental track record. The industry, Climate Change is a serious environmental challenge requiring credible action. In 2008 the industry agrees to a set of environmental targets to combat, and emissions. They include improving fuel efficiency by an average of the one. 5 per year from 2009 until 2020 stabilizing emissions from 2020 Carbon Neutral growth and reducing net Carbon Emissions from aviation by 50 by 2015 compared to 2005 levels. The industry will meet these goals for improved Aircraft Fuel efficiency such as introduction of new aircraft models with the latest fuel saving technologies in advanced propulsion systems, operationally efficiencies, airTraffic Management system modernization and improvements such as next gen and greater use of aviation biofuels. Our industry by way of competition and regulation must make certain in achieving co2 reduction goals we address other environmental considerations such as particulate matter. Economic liability environmental benefits can be evaluated together in shaping policy. It takes a comprehensive approach to respond to the environmental challenges facing commercial Aviation Industry including aircraft co2 emissions standards. These in dependencies are critical to consider when any new regulation is proposed and incorporated into domestic wall. 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. Gpas practice has been through icao standards as its own for commercial aircraft engines. The federal Aviation Administration was with support from the e p. M. And other federal agencies has followed a similar approach setting aircraft noise standards. We see no reason for the epa to deviate from this wellestablished practice in addressing aircraft co2 Emission Standards. The committee on aviation, Environmental Protection, is expected to adopt a final aircraft co2 Emission Standard in february of 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 on ceo to standards for civil aircraft for six years to ensure that this is done in the most educated and effective manner. As it has in the past epa should follow wellestablished fact in adopting icao standards in to u. S. Domestic law under section 231. Doing so will ensure that the u. S. Aircraft ending in manufacturers are placed and a competitive disadvantage about international competitors. And for air travel but the u. S. Having to aircraft co2 Emission Standards that is different from that adopted by other countries. On behalf of a i a and its members thank you for the opportunity to testify today. We will be submitting comments to the docket related to this rulemaking. Good afternoon. Thank you so much. For having this important hearing. My name is michael cerrecino and don imus is an. Greenhouse gases may be 2. 5 . And almost equals the amount of co2 put out by the country of germany. And others have talked about how co2 is trapped in the atmosphere causing warming of the earth. I leave more of that to them. I think one of the biggest concerns with more combustion from aviation, the increase in aviation, the f. A. A. Forecast, reaching 1 billion passengers by 2029. The issue whitmore combustion, more co2, but the act a modernization act passed in 2012 essentially is allowing the faa through navigation, to save fuel, not doing set down, and the reason theyre doing this is through next gen or precision bass navigation, they are allowing the airline to pack planes in tighter formation at lower altitudes and we know from nasa that Aircraft Operations below 3,000 feet decrease ground level air quality and i am submitting my testimony into the docket as well with the references so you can feel free to look them up yourself. We have all around this country the faa allowing, they changed the highways in the sky across you as a and have not found one Environmental Impact. You can change on highway over the entire continental u. S. And theres not one Environmental Impact that will impose on anyone or any person. That is absolutely ridiculous but the most important issue, the reason this needs to be investigated further is that the more combustion that we have, the more landings and take offs year over year impact people who live downwind from airports across the United States. What is the difference from living downwind from highway from living downwind to the airport . Certainly both of those situations will give you down wind pollution and the difference is highways have but noise barrier or pollution barriers and noah has done studies that those sound barriers with vegetation prevent highway pollution from floating downwind into communities. Where is the barrier to down wind pollution from aviation . Most of that is true approaches. Several studies, london heathrow, la guardia or a bunch of different studies that have shown that in fact airport particulates can reach as far as 5 to 6 and in some cases 10 nautical miles downwind from an airport. The Biggest Issue with that is we know vaccines do not cause autism, Largest Organization in february of 2012 came out and said vaccines to not cause autism. Why did they say that . Every scientific journal published on that refuted that and in fact proved the opposite of that. We now have 12 Peer Reviewed studies and i have cited references that there is an increased risk of losses associated with increased air pollution around conception and or pregnancy
comparemela.com © 2020. All Rights Reserved.