come and i serve also as a national safety coordinator. i'm also a fedex pilot and captain of flies the 18 hundreds. we are the world's largest professional airline pilots union and we have more than 52,000 members who fly the 31 airlines in the united states and canada. i would like to give the view on the epa proposed finding regarding the greenhouse gas emissions and its advanced notice of public rulemaking. first however i would like to provide some context about why we are passionate about the subject. i've also talked about a positive difference that the u.s. airlines are making to reduce emissions while safely transport in more than 2 million passengers and more than 63,000 tons of freight and mail each day. airline pilots literally said at the intersection of technology. aircraft operating procedures come aircraft traffic control procedures and techniques and varying aircraft capabilities.

this gives us a unique bandage point. from which to manage the aircraft capabilities in such a way as to her burden less fuel while operating as safely and efficiently as possible. the principle was to help further the advances they've already made towards reducing greenhouse gas emissions and improving the efficiency of the industry while maintaining or improving the current level of safety. improved technologies have resulted in significant reductions in harmful emissions. increased reliance on satellite navigation. it's to ensure the ongoing viability and sustainability of the airline industry. fuel is the largest single expense the airline employers face and in addition to the need to act responsibly to the environment, airlines have a

very strong motivation to safely find ways to use as little fuel as possible and look for alternative fuels are not only less expensive but also have less effect on the environment. the simple fact is that whatever affects our employers also affects pilots as well. we have a similar financial incentive to help them conserve fuel. pilots work with companies in air traffic and air traffic control on a dalia basis to reduce the fuel burned while airborne and on the ground. additionally the membership is cognizant of the need to protect the environment. this is of course our primary focus. we strongly support reducing aviation's already strong percentage of the contributions to greenhouse gases while preserving the viability of the airline industry. these goals are complementary as

fuel and efficiency continue to improve, economic viability is enhanced. air transportation is a significant portion of the transportation system here in north america. u.s. airlines transport about 775 million passengers and carry it out 23 million tons of freight and mail each year. aviation arguably has the most successful record of any in the economy limiting its impact on the environment while simultaneously increasing productivity. airlines have greatly reduced carbon-based emissions forever advancing technology that reduces fuel burned in emissions of the gases and particulates. we also use the frames that are lighter, stronger and create less fuel burning drag. as compared to 1972, the north american airline industry now carries six times more payload

using 60% less fuel per flight. it's reduced by 95% the number of people significantly impacted. because of these advances be domestic travel accounts for 2% of all greenhouse gas emissions by accounting for about 5% of the gross national product. the bottom line is that we are strong advocates sustained when it comes to improving fuel efficiency. airlines must be able to afford to invest in a more efficient aircraft engines that reduce the impact on the environment which has been the key to their success. we are pleased to the the agency is working with the committee on aviation and environmental environmental protection and is engaged in developing a future aircraft certification standard for the carbon dioxide. we urge the agency not to exceed that standard slated to be

considered for approval february february 2016. as the epa knows, it's a unique position to bring together government and world airlines to develop a standard that will be adopted by member states including the united states and canada. going beyond these could have a very detrimental effect on the airlines. we are a strong proponent of a level playing field for all airlines into the creation of the specific standard that is more stringent would put the carriers that a distinct financial disadvantage without a commensurate benefits to the environment. regarding the advancement any standard requirement for the aircraft should involve retrofitting of in-service aircraft were already on order. at the standards should apply only to new types of aircraft that are yet to be certified for the harm to the airline

industry. i wish to thank you again for the opportunity to speak today. i would be pleased to take any questions that you might have. thank you. >> i'm from south carolina. why is the epa claiming that those are a threat to human health under the clean air act while doing nothing to address ongoing lawsuits over aviation gasoline or the real health concerns of the stakeholders worldwide? cancer-causing heavy fuels and additives and eva shin induced cloudiness. the epa claimed to regulate the emissions under the clean air act that should protect us from the poisonous pollution however the definition is being what can only be called a violation of

the spirit of the law. air pollution that may reasonably be anticipated to endanger public over welfare. the aluminum and trade secrets toxic chemicals present a danger greenhouse gas them and how much client to the coup climate science evacuate. the data in aviation fuel almost always contain the same morning do not jump in the water yet burning the chemicals and then dumping them in the water is somehow safe. finally despite the great efforts to define the accumulation or the magnification studies on the precipitated aviation pilots and none seem to exist. the epa and the obama administration are ignoring the outrage over the most visible climate change concerns from cloud creation.

do a search for the word you will see millions of concerned citizens who look up and wonder despite what you may think of the maladies attributed to these the global outrage is nonetheless clear they are right to be worried and we should all be concerned. the epa claimed it's a greater threat to the cloudiness that is based on incomplete data that affects the climate. the fourth assessment in the radiation accounted for the linear trails manning any that spread out wasn't accounted for. how significant is this heat trapping conundrum? those formed can devolve into serious clouds indistinguishable from those born naturally. the spreading contrails may be causing more climate warming

today than then all the carbon dioxide emitted by the aircraft since the start of aviation. another stated a single aircraft operating in the conditions favorable appears to exert some 5,000 times greater than the estimates of the average force from the entire civil aviation fleet. although this research is incorporated into the model and down in my opinion the claims highlight the climate change as 2013 the interactions are one of the main uncertainties in climate research. scientific understanding is how the transition is severely lacking but evil men in the

latest research showing they are filled with aerosols from human sources. quote, the big one we found his way coming from things like fuel still used today i might aviation so that is the biggest metal that we find the most frequent but we find that we find a whole host of different metals. apparently small amounts of particular had a major effect. it would seem you'd have to change all of the atmosphere to get a big affect on the cloud but because the particles are such a small amount of the particulars matter, just a percentage or two teams you only have to change about the percentage or two of the particles to get a big affect on the clouds. the latest research casts doubt and requires serious consideration addressing the climate change impact of

aviation. they are likely coming from gas and the jet exhaust. they are make them small changes in atmospheric metal the atmospheric metal that have large impacts on the cloud creation. they are likely to have a greater impact. the endanger future growth in solar energy affects tourism and spending and is projected to make astronomy and possible by 2050. geo-engineering scientists, nasa, the doe and international corporate partners are discussing the use of biofuels and sulfur jet fuel for contrails control.

they will mount the clouds away. the epa should be directly involved in the discussions. as a result of the filings i strongly encourage to consider the scope of the endangerment to include the particulars and cloud formation from jet exhaust if the epa compliance in the clean air act they will protect us from those attributed to alzheimer's, cancer and a plethora of other debilitating illnesses. if the epa is concerned about aviation induced climate change they will regulate the clouds but change the climate to a greater extent than the greenhouse is named in the proposal. regulating heavy metals in aviation cloudiness will be meaningless without proper verification. even though the members sign an agreement in the use of certain chemicals we all know the agreements and regulations are useless without proper verification. therefore i request mandatory

random testing of the jet exhaust. this is the most important step the epa can take to follow the spirit of the law to do its due diligence to protect us from harmful pollution than that to get real-world data to improve future regulations. most of the data behind this comes from research and highly controlled environments where most variables are now. we need verification of nine ideal situations where the contamination and improper maintenance and the end of the vastly different particular to ban are seen in the last settings. to achieve the verification i proposed that we attached to both foreign and the mystic flight and conduct and analyze the results to determine the real-world exhaust constituents. alternatively, ground-based observations may be possible over the high traffic areas.

either way you choose, we need verification and protection. in conclusion, they should expand to include the cloud creation and verification system that includes all aircraft and protects us from aviation pollution can hold violators accountable and commits the scientific inaccuracies of the future determinations. thank you for the opportunity to speak on behalf of so many that couldn't be here. and thank you for listening to the lay person's views on the subject. while i appreciate the biological diversity to get the eta to hold the aviation industry accountable, the poor for people like myself have to live near these airports under these crowded skies. i hope something can be restored by your actions here and now.

tell them that they will meet your demand in our demand, not the other way around. thank you very much. [applause] >> thank you for all of your comments. >> yes, thank you. then for the group panelist at this point this would be, and i apologize if i don't pronounce someone's name. lastly, doug wolf and michael. >> i'm the director of the

environmental policy at the aerospace industry association. thank you for the opportunity to testify on the epa proposed endangerment finding an and advanced notice of proposed rulemaking under the aircraft greenhouse gas emissions. we are the largest aerospace trade association representing the nations defense manufacturers. we represent more than 300 manufacturing companies with nearly 1 million skilled employees. in the uncompromised aircraft that connects passengers and cargo and helps defend the national security. our industry is heavily regulated in months past the criteria on any new aircraft or changes to existing aircraft. aviation is a global industry and works under the united nations international civil aviation organization which has

been setting the standard for the environment and safety for over 50 years. this model has worked well for the united states. the aviation industry has thrived on the global playing field as evidence by the impact we play on the trade balance and we hope to continue to build on this model as we develop the standards for aircraft. the commercial aviation industry has a strong environmental track record including technology improvements in reducing aircraft carbon dioxide emissions over time. today's commercial aircraft are 70% more fuel efficient and aircraft flying 50 years ago. greater fuel efficiency translates into the reductions in air their craft fuel consumption and co2 emissions. the commercial aviation industry has achieved greater fuel efficiency and lower emissions even as it has grown.

today more than 3% of the global gross domestic product is supported by aviation and only 2% of the global co2 emissions are attributable to aviation. it's for this reason the commercial aviation industry is committed to building upon its strong environmental track record. the industry understands the climate change is a serious global environmental challenge requiring the credible action. in 2008 the industry agrees to a set of environmental targets to combat the carbon emissions. they include improving fuel efficiency by the average of 1.5% per year from 2009 to 2020 stabilizing emissions from 2020 with carbon neutral growth and reducing the net carbon emissions in aviation by 50% by 2050 compared to 2005 levels. the industry will meet these goals through and improved

efficiency it could improve the efficiency and aircraft models with the latest fuel saving technologies and advanced propulsion systems operational efficiencies, air traffic management system modernization and improvement such as nexgen and greater use of sustainable aviation biofuels. in addition the industry by the way of competition and regulation must make certain achieving the co2 reduction goal we reduce other environmental considerations such as particular matter and as well as noise. we are the only international body in which aviation specific technological feasibility of economic viability and environmental benefits can be evaluated together in shaping policy. it takes a comprehensive approach to respond to the environmental challenges facing the commercial aviation industry. including aircraft co2 emission

standards. these interdependencies are critical to consider when any new regulation is proposed and incorporated into domestic law. the u.s. has agreed is one of the hundred 90 parties to the chicago convention that we have the authority to establish environmental standards for aircraft. the epa practice has been to adopt standards as its own renewed commercial aircraft engines. the federal aviation administration with support from the epa and other federal agencies followed a similar approach in setting aircraft noise standards. we see no reason for the epa to deviate from the well-established practice and addressing the standards. the committee on aviation environmental protection is expected to adopt the final emission standards in february, 2016 with full ratification by

the assembly in september of 2016. this recommendation will be the result of years of data input, and houses and careful consideration. our members along with aviation colleagues, government officials and ngos have been working on the co2 standard for civil aircraft for over six years to ensure that this is done in the most educated and effective manner. as it has in the past epa should follow the well-established path and adopt the standards into the u.s. domestic law under section 231. doing so will ensure that the engine manufacturers are not placed in a competitive disadvantage in the international competitors. moreover, it will avoid the disruptions to air travel from the u.s. having to enforce the aircraft co2 emission standard that is different from that adopted by other countries.

again on behalf of the members i think you for the opportunity to testify today. it will also be submitting comments to the docket related to the rulemaking. >> good afternoon. thank you so much for having this important hearing. while greenhouse gas emissions may be 2.5% of the global co2 emissions almost equals the amount of the co2 put outside the country of germany. others have talked about how it's trapped in the atmosphere and causes warming in the earth, so i believe more of that to them. but the fact is the more that is put into the atmosphere that results in more combustion.

and i think one of the biggest concerns in the forecast that will grow reaching a billion passengers by 2029 and the issue has the modernization act that was passed in 2012 essentially allowing the faa through the provision navigation to save fuel on dissent that what they but they are not telling you is allowing the airlines to cost the usa. and the reason they are doing this is through the provision

-based navigation. they are allowing the airline to pack more planes in the title formation of much lower altitudes. and we know from nasa aircraft operations below 2,000 feet of air quality and that is saying i am submitting my testimony untold docket has all the references, so you can feel free to look them up yourself. so, we have all around this country the faa allowing to change the highway in the sky across the usa and they haven't found one and environmental impact. that's it. you can change the highway over the entire continental u.s. if there's not one environment to win back that will impose on anyone or any person. that's absolutely ridiculous. but the most important issue and the reason why into the reason why this needs to be investigated further is that the

more combustion we have the more takeoffs every year and people that live had people that lived down the band in airports across the united states. now what's the difference from living downward downward in the highway to living on down in the airport but certainly both will give you downwind pollution into the difference is the highway is have pollution barriers and they've done studies on this but the sound barriers with the education prevent highway pollution from going down into the communities. where is the barrier to the downward pollution from aviation? and most of that is through the approach. i listed several studies that have done a bunch of different studies that have shown that in fact airport particulars can reach as far as five to six.

we know the vaccines do not cause autism. the largest organization in february 2012 came out and said that they do not cause autism and why do they see that? because every journal that was published refuted that and in fact proved the opposite. we have 12 review studies and i cited in my references that there is an increased risk of autism associated in the air pollution around consumption and/or pregnancy. the vast authority command i talked to harvard scientists and personal communication that is not genetic. the environment of a produced pollution is what is causing autism and we will see the spike in autism across the usa and they can change the diagnosis or hide the incident but the fact of the matter is more children

are receiving the services today than they were and they will continue to see more services in the next ten years. that's why the vaccines were pointed out. the heavy metal load in the vaccine and air pollution can affect deposit in the hair and nails of the children and in fact when they do look back at the children they will find that the heavy metal deposition is significantly higher than typically developing so we know that they are being exposed and that's from environmental pollution. >> we just came out with a new study that said the 2015 cost of autism related expenses were $268 billion, and by the year

2025, it can be anywhere between $502 trillion in the end related cost. we know that aviation emissions have traced heavy metals and buy products is sold for. the aviation fuel contains 100 times more than diesel trucks. and we can talk about all of them but also the high pollution areas also decrease the iq of children. and very interesting thing about that is that even when the children had six or 7-years-old they still do not catch up to the peers. for this damage that is being caused and it does have an effect on one of the most important things i will tell you if you want to know how dangerous they are pollution is you just have to look at the trends in the changes.

what they did is they exposed to jet fuel and what they found is that it didn't change the gene that it changed the way that it was expressed. and that the change in the way that was expressed for obesity got into the genome and was passed on to subsequent generations. so my nieces and nephews and children could potentially very somebody else's kids who are in the heavy environment command change in the genome gets into the loophole so your children and great-grandchildren could in fact develop these changes through environmental pollution. ..

>> and i'll just end with another a scientist also talked about con trails, and he's using data from, i think, the 1990s to early 2000s. so this is old data, but what he says is that increase in surface and lower atmospheres' temperatures by .36 or .5 degrees fahrenheit per decade --

so that's what he's saying the contribution the contrails could be to warming -- .36-.54% degreestarian heat per decade -- fahrenheit per decade. and the other thing you should know about contrails is we have more combustion, more aircraft, more airplanes, you're going to get more contrails and more warming. so it's this whole vicious cycle. the thing about contrails is they produce clouds that morph into cirrus, okay? they do not study the whole life of that artificial cloud that's produced. and that artificial cloud that is produced would not have formed if there would not have been a contrail in that area. so these clouds that are being induced are producing clouds that would not naturally be there. that changes the hide prological

cycle, which is rain. and the other thing you should know the way it can change the rain is when the engine at high altitude freezes the ice crystals in the atmosphere, it is actually changing the vapor content in the atmosphere. okay? so that vapor content will have a change on regional climate change. and i thank you very much for having this open hearing. >> my name's doug wolf, i'm representing the center for biological diversity. thank you for con vehicling this hearing and for soliciting further public input concerning agencies' crucial effort to promulgate emission standards for aircraft. the center for biological diversity appreciates the opportunity to comment. with these -- oops.

the center for biological diversity is a nonprofit organization with more than 800,000 members and online activists. the center's climate law institute seeks to reduce u.s. greenhouse gas emissions and other air pollution to protect biological diversity, the environment and is human health and welfare. specific object is include securing protections for species threatened by global warming, insuring compliance with applicable laws to reduce greenhouse gas emissions and oh air pollution and -- other air pollution and educating and mobilizing the public on global warming and air quality issues. climate change is already upon us. with unprecedented temperature increases, rising sea levels, extraordinary rates of species extinction and more extreme weather events. efforts to quickly and sharply curb and then eliminate carbon pollution are essential if we are to avoid the worst effects of climate change. science tells us that this

requires the u.s. reduce emissions in the range of 35-65% by 2030 from 1990 baseline levels. to begin to approach those levels, every significant carbon emission source must reduce its emissions, and the aircraft industry has too long evaded every attempt to make it contribute its fair share. in fact, if global aircraft co2 emissions were compared to those of countries, they would rank seventh just behind germany, outranking about 150 other countries in the world. aviation emissions are growing rapidly and could triple within just a few decades unless epa puts in place stringent standards to reduce greenhouse gas emissions. increased aviation traffic will cause the sector to become one of the fastest growing sources of harmful emissions. within the global community, the united states is by far the largest emitter of aircraft carbon pollution. with its domestic and

international flights contributing 29% of the total, dumping that amount into the global skies absolutely unchecked. in other words, u.s. aviation emissions harm the global community in a hugely disproportionate fashion. the u.s. must reverse the situation and cut emissions quickly and steeply and must reject the patently insufficient measures proposed by the international civil aviation organization oicao to. we -- or icao. we believe, however, that this proposed finding was much too late in coming, and we urge the agency to make up for lost time by finalizing it forthwith and no later than november 2015, three months after the close of the current comment period. we also urge epa to follow up its anpr with propose toed standards at the same time it

finalizes its endanger. finding. there's no reason to await the outcome of negotiations at icao as even the most stringent measures under consideration there would hardly make a dent in the problem. in fact, under the likely outcome of the international negotiations, in 2030 only 5% of the global aircraft fleet would even be regulated. and by a standard based on technology in existence in 2016 or some 14 years behind 2030 technology. moreover, the icao proposals set no cap on emissions. in other words, icao's proposals do next to nothing to affect business as usual, an outcome utterly incompatible with epa's duties under the clean air act, the president's climate action plan and the demands of climate science. epa should seize the opportunity to issue proposed emission standards in time to make a difference at the paris climate negotiations in december of this

year. we are pleased to see epa's acknowledgment that the clean air act authorizes it to regulate not just aircraft engines, but the entire aircraft. we add that the act delegation of authority to epa under section 231 is extraordinarily broad and that epa is explicitly authorized to set emission standards for all classes of aircraft. moreover, as epa recognized in 2008, epa's regulations can encompass aircraft operations and air traffic management. finally, the standards epa settles on should be technology-forcing, not following. with these premises in mind, epa should set emission standards not just for new types of aircraft, but also for aircraft currently in production and in service. it should base them on currently existing as well as under development technology and should include operational and

air traffic management requirements that reduce emissions. aircraft failing to retrofit to meet achievable standards should be phased out. we urge epa to craft these standards by employing an approach similar to standards for vehicle ises, setting fleet-wide averages for new and in-service aircraft. these standards should be sufficiently stringent not only to hold total emissions at a set cap, but to actually reduce them for the entire u.s. aviation sector within the coming decade. the center will be submitting written comments at the close of the comment period. we're working with other organizations. we thank you for this p opportunity to be here. >> thank you very much. thank you for all, all speakers. appreciate your comments and thoughts. i will now move to the next group of speakers. after i call your name, please come up to the table. we have kathy kinsey from the northeast states or if coordinated air use management, sue valdez, a member of the

public, and andres restrepo, a member of the sierra club. thank you. [inaudible conversations] >> kathy, please. >> thank you. good morning. my name is kathy kinsey, i'm a senior policy adviser with the northeast states for coordinated air use management. we'd like to thank you today for the opportunity to be here to testify on epa's proposed endangerment finding and on the advanced notice of proposed rulemaking. nescom is an organization of eight states, six northeast states and new york and new jersey, and my testimony today here reflects the majority view of our states and does not

necessarily reflect views of all of our individual state members. so nescom supports epa's proposed finding under the clean air act 231, the aircraft greenhouse gas emissions endanger public health and welfare. this support is consistent with the support, our support in 2009 for epa's proposed or endangerment finding for mobile sources. since the 2009 rulemaking, climate science has only grown stronger. the latest science as summarized in the 2014 international panel on climate change establishes that climate-related threats are already affecting our states, our nation and the world. nescom also supports epa's determination that aircraft emissions from certain classes of aircraft are contributing to the mix of greenhouse gases that are subject to this rulemaking.

we support the development and adoption of aircraft greenhouse gas emission standards for u.s. aircraft. in this regard, we support a whole-aircraft approach to adopting standards that doesn't focus solely on the engines. whole-aircraft approach recognizes that emissions are influenced by aircraft weight, aerodynamics and the engine-specific fuel consumption. we urge e, a to adopt -- epa to adopt greenhouse gas standards for new aircraft and in-production aircraft. that approach will begin to materially reduce greenhouse gas emissions in the next five to ten years from the projected business-as-usual levels. and it should be based on a reference scenario that reflects current aircraft performance. a reference scenario that is based on outdated aircraft performance will only lead to inflated estimates of greenhouse gas emission reductions from current reductions.

and finally, nescom urgings epa to take -- urges epa to take the opportunity with this rulemaking to advise the current aircraft emission standards. given the continuing ozone problems in our region, the northeast region and the nation as a whole, and the fact that under its current process icao is unlikely to adopt new aircraft knox standards prior to 2022 if then, epa should take the opportunity to act now and establish a production cutoff date of december 31, 20189, after which tier viii knox standards will apply to newly-manufactured aircraft in lieu of the tier vi standards. nescom intends to submit more detailed comments before the close of the record, but we thank you very much for the opportunity to be here today.

>> thank you. my name is andres restrepo, and i'm an associate attorney with sierra club's environmental law program. sierra club was founded in 1892 and stands today as one of the largest and most active grass roots environmental organizations in the united states. with over 2.4 million members and supporters as well as 64 affiliated chapters nationwide, the club works to secure a cleaner, healthier and more sustainable environment for today's world and for future generations alike. one of the club's most urgent goals is working to curb the effects of climate change, and we strongly advocate for steep and immediate cuts to greenhouse gas emissions from all sectors of the economy. unless governments act now, we will be unable to avoid the worst impacts of climate change which include rising sea levels, more extreme temperatures and is weather events, mass displaitsment of peoples -- displacement of peoples and widespread extinctions of plant and animal see cease. the sierra club strongly supports gas regulations for

aircraft to help mitigate the harms posed by climate change. for far too long, u.s. aircraft have been released unlimited amounts of pollutants into the atmosphere, contributing nearly 30% of the world's co2 emissions in aircraft, far more than any other country. in fact, more greenhouse gases than the entire economies of all but eight countries with none with a population below 80 million. furthermore, these emissions will increase by as much as 50% over the next two decades unless mandatory restraints are imposed. epa's finding that gas emissions end danger public health and welfare is, therefore, entirely sound. the effects of climate change as well as the climate-disrupting effect of greenhouse gas emissions are so well documented that they require no additional discussion here. under section 231, an endangerment finding triggers the agency's -- given the size and scope of this problem, epa must not delay the regulatory process. in particular, the agency must forge ahead with these regulations without awaiting the

greenhouse gas standards forthcoming from the international civil aviation organization. the most stringent proposal currently under consideration by that body would cover only 5% of global aircraft, would rely on 2016 technology for aircraft built in 2030 and would not impose a total cap on emissions from the global fleet. accordingly, even under a best case scenario the icao standards will do little to curb the intensifying rob of emissions -- problem of eau missions. epa should move forward with strong, effective standards. to that end, epa must adhere to several principles. first, the agency must cover all aircraft under any final standard. this requires regulation not only of new designs or newly-constructed aircraft, but of aircraft currently this use as well. epa's correct to assert the authority for entire aircraft rather than for engines and may address all categories in its regulations. notably, section 231's broad mandate does not constrain the

agency's authority to regulate existing aircraft, and the epa must take advantage of this aspect of the statute in it expects to achieve meaningful reductions from the u.s. fleet. second n keeping with the purpose of the clean air act, epa's standard must be technology-forcing rather than technology-following. the language of the statute makes clear that congress intended for section 231 standards not merely to reflect what aircraft are capable of achieving at a gift point in time, but to enhance those capabilities above what they would have been otherwise. hence, section 231 provides that regulations shall take effect on a time frame that would permit the development in application of the requisite technology. epa must, therefore, base its forthcoming standards not only on existing technology, but on in-development technology as well. next, epa should consider a fleet-wide averaging program also permitted under section 231. a regulation of this nature would allow the agency to achieve the greatest emission reductions at the lowest cost. the agency should also address operational and air traffic management rackses in its final d practices in its final rule.

finally, epa must require any aircraft that cannot be designed to meet the requisite final standard or cannot be retrofitted to phase out and ultimately retire. it is critical that epa prohibit old and outdated aircraft from continuing to contribute to climate change while better, more efficient designs are readily available. sierra club appreciates epa's effort to move forward with the greenhouse gas regulations for aircraft, and we urge the agency to promulgate a standard that is technology-forcing. while epa must take the time necessary to develop an appropriate and well-considered final rule, time is particularly of the essence. in december president obama and administration officials will travel to paris to negotiate an international climate accord with leaders from around the world. strong are our commitments to reduce gleanhouse gases nationally, the more effective our position will be with other countries. we strongly encourage epa to move swiftly ahead to help achieve the best possible outcome in paris.

i thank you for the opportunity to speak on this issue and look forward to submit comments on the agency's proposal in the near future. thank you. >> thank you both for your comments and thoughts. before i turn to bill to introduce the next group, i want to make one last call. is sue valdez here? no. okay, thank you both. >> thank you. we're now going to move on to group number five. so could we please hear from kate deangelis, amanda bass and david baake. thank you. [inaudible conversations] >> thank you for the opportunity to testify on this important

issue. my name is kate deangelis, and i am a climate and energy campaigner at friends of the earth. we must keep 80% of the world's fossil fuel reserves in the ground to have a good chance of avoiding the worst impacts of climate disruption. as the world's largest historical emitter, the united states must shoulder the greatest share of the burden for making emission reductions. in order to achieve the necessary emission reductions to avert cats t pick climate disruption -- catastrophic climate disruption, the united states must take significant strides to reduce carbon pollution from every sector of the economy including aircraft. the epa has already taken action to reduce emissions from cars, trucks and power plants. now the epa needs to show the same leadership and limit aircraft carbon dioxide emissions. globally, airline operations produce 705 million metric tons of carbon dioxide in 2013. to put that in perspective, the global aviation emissions industry would rank seventh if included in country emission

rankings just after germany's total country emissions. this sector is too big to leave unregulated, so the epa must take immediate action to reduce carbon pollution from aviation. greenhouse gas emissions from aircraft are currently responsible for more than 3% of the total united states emissions. while this may not seem significant, emissions from the aviation sector are one of the fastest growing sources of greenhouse gases in the world. they are also the largest emission source that is unregulated in the united states. without regulation to limit the emissions, carbon pollution from this sector is expected to triple by 2050. regulation is especially important because of the potentially disproportionate climate impact of high altitude aircraft emissions. when emissions are higher in the atmosphere, they can have greater warming impact than at ground level. the united states must take the lead in reducing emissions from our aircraft since we account for a large portion of the world's aviation emissions. the united states' domestic

flights account for 24% of the world's commercial aircraft carbon dioxide emissions and 35% of carbon dioxide emissions from international commercial flights. when the epa first began analyzing measures to reduce carbon dioxide from aviation in 2008, it estimated greenhouse gas reductions available from engine and airframe changes alone at 13.3%. despite this, research shows that from 2012 to 2013 united states airlines overall did not make any net fuel efficiency gains. yet there are plenty of improvements that could be made as evidenced by the fact that there's a gap of 27% from the most to least fuel efficient domestic airlines. this demonstrates that the industry is already implementing retrofits that are effectively reducing carbon dioxide emissions. epa regulations would force all airlines to adopt similar measures. the epa has the legal authority under section 231 of the clean air act to address emissions from aircraft.

this authority to act is broad. the clean air act requires that epa put forward emission standards for pollution from any class or classes of aircraft engines that it determines may endanger public health. the only substantive restriction that the law places on this authority is that any rules cannot significantly increase noise or hinder safety. the epa first set pollution standards for future and existing engines in 1973, but these standards did not address carbon pollution. at the time these standards were introduced, the understanding of the impacts and urgency of climate change was minimal. since then the scientific evidence for the need to address this pollution has become irrefutable. the epa must take this opportunity to put forward new rules that reflect the need to take fast and meaningful action to reduce our global warming-inducing emissions. the united states cannot wait for the international civil aviation organization to take action. it's only succeeded -- icao has

failed to set any policies. they were finally expected to put forward some standards in early 2016, but they are likely to be incredibly weak and insufficient. if in part because they will not apply to in-use aircraft. the epa has the legal authority and the emission reduction potential exists to make far greater reductions than icao is expected to mandate. the e be, a should adopt its proposed finding that aircraft emissions endanger public health within no more than three months of the close of the comment period. in addition, epa must adopt regulations that are broad in scope. rather than focusing only on new aircraft engines, any rules that epa puts forward should include existing aircraft and not limit coverage to just engines, but the entire aircraft. epa should set emission standards for all classes of aircraft in a way that is technology-forcing to insure the great itself emission -- greatest emission reductions possible. epa should follow the example it

has set for passenger and medium heavy duty vehicles and establish fleet-wide averages for new and existing aircraft including those in service. these standards must be sufficiently stringent to significantly reduce them for the entire united states aviation sector over time. furthermore, the epa should work with the federal aviation administration to develop complementary standards to promote the use of low carbon jet fuels. thank you for taking the time to consider my comments. >> good morning. my name is amanda, and i live in virginia beach, virginia. thank you for giving me this opportunity to speak to you today. for the past five years, i have documented aircraft emitting trails across the sky. i've taken hundreds of videos and thousands of photographs of these persisting emissions. many of the aircraft i have witnessed appear to be spraying something into the atmosphere. uneasy with my observations, i wanted to know exactly what was causing the aircraft to leave

visible trail ares that did not dissipate -- trails that did not dissipate. i reached out to local, state and federal government agencies for information and assistance. what i experienced was disillusioning, to say the least. when i called the epa, i was told that the faa handled aircraft a emissions. when i called the faa, they told me to call the epa. i was shuttled from office to office with no agency ever accepting responsibility or accountability. my calls were not returned, nor were my concerns ever addressed. the sage advice i finally received from an epa -- from the epa was to hire a plane and do my own testing. this was especially disheartening since i had been led to believe that the environmental protection agency was the ultimate protector of the environment. additionally, the epa advised me to contact the department of environmental quality for the state of virginia. not surprisingly, the deq informed me that they do not regulate mobile sources of

emissions, don't go to airports and don't check what is being loaded on planes. as for my request for my yard to be tested for heavy metal, chemical or biological contamination, i was told that the virginia deq could not use state money to test for those materials. furthermore, my complaint was an in area that they had no authority to investigate, another dead end. i reported naval station, naval air station oceana military jets and spoke with at least 30 individuals at the base. i finally spoke with terry chamberlain, head of the environmental office. he bluntly informed me that the military regular lates itself. needless to say, they continue to dump unburnt fuel over the residents living close to the base. for several years i electronically reported on airplane pollution using the environmental violations form on epa's web site epa.gov/tips.

it was referred to me by an afrc federal contractor working for the epa. i have always included my contact information on the tip report and identified specific aircraft that can easily be traced. no one from the epa has investigated any of my formally-filed complaints. since i became interested in the possible dangers of chemicals spraying in the environment, i've contacted the virginia pollution control board, oceana, noaa, nasa, the department of defense, brook haven national laboratory, the department of energy, the department of homeland security, fema, the health department, the department of travel, countless federal agents and operators, the virginia beach police department and even the white house all to no avail. to date, no one from any agency has investigated my complaints. i was told to talk to my local

representatives. every agency i contacted responded to my reports by telling me that i was seeing condensation from engine exhaust. aircraft engines do emit water vapor, of course, but vapor that quickly dissipates. what i was witnessing was persistent and long lasting. how can anyone reasonably conclude that a particular aircraft emission is merely a contrail without testing it? that is both unscientific and irresponsible. chem trails is the term used to describe persistent aircraft emissionings. there's a rising international concern about the existence of airborne chemicals spraying bolstered by a growing body of scientific evidence. what is in the air that we are breathing? one activist from california decided to have -- excuse me -- decided to have his hair tested for heavy metals at his own expense. high levels of bariume