“With this proposed rule the EPA is moving toward global initiative to adopt the ICAO CO² standard,” explained Stewart J. D’Leon, NBAA director, technical operations. “NBAA supports this effort, but in speaking with industry colleagues, we all seem to have the same concern with some elements of the proposed rule that are different than the ICAO standard. The most concerning of these differences is the requirement of manufacturers to submit reference geometric factor (RGF) data.
“RGF data and three specific air range (SAR) points are part of the mathematical calculation used to determine the CO² standard metric. SAR data is the definition of the fuel burn of a product and is considered highly commercially sensitive,” D’Leon said, adding that when someone has the RGF data, they can easily reverse the math and calculate the SAR.
“That SAR data is proprietary and if that becomes made available to the public, then that’s a real concern for manufacturers,” he said. This was a point of discussion during the development of the ICAO standard and ultimately led to it being excluded from the reporting requirements in that process. NBAA supports the EPA adopting the same mindset.
NBAA, in its comments, also noted the association and its members have long supported efforts to address aircraft emissions. This includes work through the Business Aviation Commitment on Climate Change, an aggressive collaborative program designed to address the industry’s carbon emissions.
D’Leon urged NBAA members wishing to submit comments to do so before the closing date of Oct. 19.