US aircraft and engine manufacturers have called on the new Biden administration to provide sustained government support to help achieve its climate goals. In an open letter to Transportation Secretary Pete Buttigieg, FAA Administrator Steve Dickson, Climate Envoy John Kerry and National Climate Advisor Gina McCarthy, the US Aerospace Industries Association (AIA) said action should be taken in three key areas: measures to accelerate the production and use of sustainable aviation fuels (SAF); enhancement of public-private partnerships to accelerate development of next-gen aircraft and engine technology; and delivery of national airspace modernisation. The letter says that while AIA members would be contributing to climate targets through more efficient aircraft technology, it calls for a “holistic approach” to tackling aircraft CO2 emissions through short-term tools such as SAF, operational improvements and market-based measures. The AIA recommends the administration supports a blender’s tax credit that would incentivise greater SAF production. The blender’s tax credit is a policy option included in the Sustainable Aviation Fuel Act legislation introduced in November by California Democrat Congresswoman Julia Brownley. Meanwhile, Boeing is seeking to intervene on behalf of the Environmental Protection Agency, which is being sued by 12 US states, the District of Columbia and three NGOs over the agency’s recent decision to finalise aircraft GHG emissions standards.
SAF, says the AIA, offers the most effective way of reducing the environmental impact of flying in the short-term but is not being produced currently in sufficient quantities to be an economically viable option for airlines today. As well as a blender’s tax credit, it recommends government support for SAF be provided through increased R&D funding, the adoption of policies to encourage sustainable fuel production specifically for aviation and increased military procurement and use of SAF by the government to help grow the market.
Although the FAA had already made significant progress in delivering enhancements to the National Airspace System, says the letter, the administration is asked to prioritise realisation of the improvements, which it says are expected to deliver 2.8 billion gallons of fuel savings through until 2030. This, it says, can be achieved by implementing performance-based navigation (PBN) routes to enable aircraft to fly shorter, more direct routes, and ensuring PBN implementation is complemented by continued efforts to promote community involvement in changes to airspace structure, “which will deliver improvements in both noise and climate impacts.”
The US aerospace industry was exploring a range of technologies for next-generation aircraft in the 2030s that would offer improvements in fuel efficiency of 15-25% compared to current aircraft, says the AIA, but “to realise these benefits, US aviation manufacturers will require support to remain competitive, given the impact of Covid-19 and the billions of dollars European governments are providing their industries to support similar efforts.”
The AIA calls for four areas of support:
- Advancing NASA’s work in enabling technologies for next-gen aircraft, such as new airframe and engine architectures, improved aerodynamics, advanced propulsion (including electrification), advanced manufacturing and lightweight materials;
- Accelerating the timetable of a NASA subsonic demonstrator ‘X-plane’ incorporating these innovations to ensure US companies can bring these technologies to maturity ahead of European competitors;
- Increasing funding for the FAA’s Continuous Lower Energy, Noise and Emissions (CLEEN) Program to accelerate near-term fuel efficiency improvements in conjunction with reductions in noise and other emissions that manufacturers need to balance; and
- Developing a comprehensive, long-term research agenda to secure US leadership in transformational aviation technologies, leveraging partnerships between industry and government agencies such as NASA, the Department of Transportation, Department of Defense and Department of Energy.
The AIA also stresses the importance of government, industry and NGOs working together through ICAO, and notes ICAO is continuing to assess the feasibility of a new long-term goal for international aviation emissions.
“To build upon achievements to date, we urge the administration to continue to prioritise multilateral solutions and maintain the leadership the US government has demonstrated in these activities,” says the letter, which mentions the aircraft CO2 standard established by ICAO in 2017 and now implemented by the Environmental Protection Agency (EPA) into domestic law.
“Following the finalisation of the EPA rule, we ask that the FAA develops regulations this year that will allow US manufacturers to certify their aircraft to the global CO2 standard.”
During the final days of the Trump administration in late December, the EPA finalised emissions standards for airplanes used in commercial aviation and large business jets that align them with the ICAO standards. Without the rulemaking, said the EPA, US manufacturers would have been at a significant disadvantage and could be forced to seek CO2 emissions certification from another country in order to market and operate their airplanes internationally.
However, the ruling is being challenged in an appeals court in Washington by the attorneys general from 12 Democrat-led states, including California, Illinois, Pennsylvania and New York, plus the District of Columbia, who contend it would not result in actual reductions of greenhouse gas emissions and is therefore unlawful.
The three environmental groups taking action are the Center for Biological Diversity (CBD), Friends of the Earth and Sierra Club, which are being represented by Earthjustice. They say the rule will not apply to in-service airplanes and will not apply to new in-production airplanes until 2028, when the EPA expects all airplanes to already comply with the standards or be phased out.
“We’re confident that we’ll stop this rule in court and we look forward to serious, science-based standards from the new Biden administration,” said Clare Lakewood, Legal Director of CBD’s Climate Law Institute.
According to a Reuters report, Boeing has asked the appeals court for approval to intervene on behalf of the EPA, noting that US participation in the work towards the ICAO CO2 emissions standard on which the ruling is based began under the Obama administration, in which Joe Biden was Vice President.
Boeing said in a statement it was essential rules should be reasonably achievable “given the billions of dollars it costs to design, build and certify new airplanes.”
It added: “Attempts to overturn regulation directly aligned with successful cooperative international efforts to combat climate change, supported by more than 190 countries, will only discourage future international agreements.”
In its ruling, the EPA said: “The ICAO Airplane CO2 Emission Standards have been adopted by other ICAO member states that certify airplanes. The action to adopt in the United States GHG standards that match them will help ensure international consistency and acceptance of US manufactured airplanes worldwide.”
It conceded though: “EPA’s assessment includes the expectation that existing in-production airplanes that are non-compliant will either be modified and re-certificated as compliant, will likely go out of production before the production compliance date of January 1, 2028, or will seek exemptions from the GHG standard. For these reasons, the EPA is not projecting emission reductions associated with these GHG regulations. However, the EPA does note that consistency with the international standards will prevent backsliding by ensuring that all new types design and in-production airplanes are at least as efficient as today’s airplanes.”
The Sustainable Aviation Fuel Act legislation introduced by Julia Brownley aims to incentivise SAF production and help the aviation sector reduce its carbon emissions. As well as creating a new blender’s tax credit for SAF, linked to carbon reductions, it would authorise $1 billion in federal funding for US projects that produce, transport, blend or store SAF and a further $175 million in research funding “to push the limits” of existing SAF technology. It would also require the EPA to establish an aviation-only Low Carbon Fuel Standard (LCFS) similar to California’s transportation-wide LCFS.
“As a member of the House Select Committee on the Climate Crisis and the House Transportation and Infrastructure Subcommittee on Aviation, I know the importance of, and challenges to, decarbonising the aviation industry,” said Brownley. “Aviation alone contributes 9% to US greenhouse gas emissions from the transportation sector and is therefore a critical target towards achieving our climate goals. Sustainable aviation fuel will go a long way to reducing aviation sector greenhouse gas emissions but it needs a focused federal response to make it a reality.”
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