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How Might REACH (European Environmental Regulations) Affect Your Business?

The U.S. Commerce Department will hold a webinar on November 29 to discuss the effect of European Evironmental Regulations on  U.S. Aerospace companies.

The European Union has a regulation called the REACH regulation.  REACH stands for Registration, Evaluation, Authorisation & restriction of CHemicals.

REACH imposes certain obligations on companies that manufacture certain chemicals in Europe, and on companies that import certain chemicals into Europe.  Under REACH, the continued marketing of substances of Very High Concern (SVHCs) requires an authorization. Businesses active in the aerospace marketplace use a number of substances that are being considered for SVHC classification, and unauthorized import into Europe of such substances could violate REACH.

For more information, see the notice on the Commerce Department website.

PBDE Ban Could Affect the Flame Retardants in Aircraft Parts

Are your flame retardant chemicals about to be banned?

Earlier this year, EPA proposed a rule banning certain polybrominated diphenylethers (PBDEs).  These are flame retardant chemicals used in certain plastics, including in aircraft interiors.  There have been a number of studies focused on the whether passenger or crew exposure  to PBDEs in the aircraft could pose a danger.

Earlier this year, the US government published a proposed rule that would ban the manufacture, importation, and processing of decaBDE, a flame retardant.  The rule could impact manufacturers and suppliers of aviation parts that contain decaBDE.

The proposed rule was published in the Federal Register on April 2, 2012, and the comment period closed on July 30, 2012.  You can find information here:

If you have an interest in this rule or would like to hear more about it, please contact Sarah Breslin  of the Small Business Administration at (202) 292-3410 or sarah.bresolin@sba.gov.

Boeing Takes on Environmental Leadership

On July 19, Boeing’s Vice President of Environmental, Health and Safety, Mary Armstrong, was a keynote speaker at the 2011 ASA/AFRA Conference.

Armstrong spoke at a joint session of the memberships of both the Aviation Suppliers Association (ASA) and the Aircraft Fleet Recycling Association (AFRA).  Her speech made it clear that Boeing is acting as a leader in aviation’s efforts to  achieve better environmental performance.

Boeing has been taking steps to reduce energy use, and to reduce the production of hazardous materials.  This has lead to significant measurable reductions in both areas at Boeing.  Boeing is now working on reducing the waste-to-landfill to zero.  They have already achieved this at four locations (Huntsville, Philadelphia, Salt Lake City and South Carolina.  In South Carolina, the Boeing facility has gone to 100% renewable energy, including a ten acre solar roof and using biomass for remaining energy needs.

She discussed Boeing and AFRA’s efforts at lifecycle environmental footprint reduction.  The aerospace industry has taken a cradle-to-grave approach, trying to minimize environmental footprint throughout the aircraft’s lifecycle.

Armstrong explained that for Boeing, environmental performance starts with design.  Boeing is focused on increasing the use of recycled materials in products and in tooling.  They are designing their Aerospace products to reduce or eliminate the use of hazardous materials and the generation of hazardous wastes.

They are switching to non-chromated paints and primers for their aircraft.  This is a significant change from traditional coatings that used chrome, which is a hazardous material.

Boeing is participating in a new group known as the International Aerospace Environmental Group.  This group is made of aerospace manufacturers working together to share best practices that will permit them to achieve better environmental performance.  One of their goals is to create a consistent process for suppliers to list their chemical bill of materials.  This will provide the framework against which the manufacturers can reduce their adverse environmental impact.

Armstrong explained that aviation produces about 2% of the global carbon emissions, if you take into account all of the aviation-related sources.  Therefore the industry feels compelled to focus on control and limitation of carbon growth.  The 787 and 747-8 aircraft will both be cleaner and quieter.  The 787 is designed to reduce carbon emissions by 20% and the 747-8 should reduce carbon emissions by 16%.

Boeing is testing biofuels in an effort to identify sustainable biofuels.  By sustainable, they mean crops that will not compete for water or land with food crops.  They have been engaged in test flights since 2008, and are identifying fuels that will work as well as or even better than pure Jet-A.  They are working to develop 50/50 blends and the standards for this have been recently approved by ASTM.

Boeing is also working with the FAA on the development of modern air traffic management systems.  Implementation of improvements in this area could cut 12% or more off of aviation’s carbon emission total.

Boeing wants to be an environmental leader, so the next step, which Boeing and AFRA are both taking together, is to undertake a cradle-to-cradle approach.  This means thinking about where the recycled materials from an aircraft will go, and undertaking strategies that will permit the aviation industry to recover recycled aerospace materials for use within the industry.

Boeing is working with AFRA and ASA to develop better strategies for reclaiming materials.

Armstrong praised AFRAs BMP efforts.  She explained that she expects the draft Recycling BMP to lead to an effective mechanism for improving effectiveness and efficiency in recycling of aircraft materials.

Between 2010 and 2030, the aviation industry is expected to add 33,500 new airplanes and half of these will replace existing aircraft.  In the next ten years, the industry expects a significant number of aircraft retirements, all over the world.  These older aircraft will yield to more economical and environmental aircraft, but their retirements create a recycling challenge.

Boeing is engaged in a number of pilot projects for environmental improvement.  These projects include:

  • Recycling carbon fiber, for interior components, for non-structural applications and for tooling
  • Recycling interior materials, like aircraft carpet to reduce landfill materials

Boeing is working on technologies that will permit creation of carpet tiles from recycled carpet.  There is a pilot project for testing these carpet tiles with Southwest Airlines right now.

Boeing is asking its supply base partners to adopt environmental management systems similar to ISO 14001 (although they need not be registered to ISO 14001).  Boeing expects to address environmental responsibility, in the future, as an element to consider for awarding contracts to partners.

One thing that Armstrong did not mention in her speech is that Boeing is one of the founding members of AFRA, and AFRA’s goals include a variety of environmental and recycling efforts.  Through AFRA Boeing has achieved some significant advances by publishing Best Management Practices related to aircraft materials recycling.

Boeing is expanding its understanding and expanding its collaborations in order to create new value for customers and for the environment.

Making Aircraft More Environmentally Friendly

Jeanne Wu, Boeing’s Director of Environmental Performance, addressed strategies for improving environmental performance in aircraft during the ASA/AFRA Conference on June 29, 2010.

The 18,800 aircraft in the 2008 fleet are expected to grow to 36,000 aircraft by 2028.  Wu explained that the aviation industry accounts for about 2% of CO2 emissions.  Without intervention, it is estimated that this could rise to 3% over the next twenty years.  As a consequence, Boeing is working with the rest of the industry: taking proactive steps to reduce aviation’s environmental impact.

Aviation has had tremendous success in reducing its environmental impact.  From the 1950s to the 1990s, aviation achieved a 90% reduction in noise footprint and a 70% increase in fuel efficiency, with a correlative reduction on CO2 emissions.  Wu explained that the aviation community wants to build on this history of success and to further reduce emissions.

75% of Boeing’s R&D is focused on developments that benefit environmental performance

  • Next generation materials reduce weight which decreases fuel burn
  • Aerodynamic improvements to reduce drag and increase fuel efficiency
  • Less energy intensive electric systems, like reducing pneumatic systems

Boeing is researching biofuel viability.  Current biofuel testing involves mixtures that include:

  • 20% coconut & babassu
  • 50% jatropha
  • 50% algae & jatropha

Boeing has set a goal to make each generation of their aircraft 15% more fuel efficient.  These “green” technologies are being implemented in the 787.

Improving the worldwide fleet efficiency

  • Implement airplane modifications like winglets
  • Develop operational efficiency strategies for air carriers
  • Optimize worldwide airspace efficiency and navigation

100% of Boeing major manufacturing sites are maintained to the ISO 14001 environmental management system standard.  This applies to the facilities as well as to the processes that are used for building aircraft.  Boeing also uses LEAN theories to reduce waste, which reduces Boeing’s environmental impact.  Finally, Boeing is strong supporter of AFRA, the non-profit organization that works on how to efficiently recycle aircraft at the end of their life-cycle.

AFRA is a big part of Boeing’s environmental plan for aircraft.  Through AFRA, Boeing is working with its peers to develop recycling technologies that will achieve 90% recyclability in the world fleet by 2016.  She estimated that the existing advances that have been developed could reduce aviation’s contribution to landfills by 75% by 2012.  AFRA’s members are identifying, accelerating and integrating promising recycling solutions.  She explained that one example of the advantages that can be realized is that there is a 90-95% reduction in energy use (and a correlative reduction in CO2 emissions) when using recycled carbon fiber, instead of creating virgin fiber.

Wu explained that joint action allows us to create a better future together.

EASA Executive Director Goudou Briefs on the Activities of EASA

EASA Executive Director Patrick Goudou welcomed the community to the FAA EASA International Safety Meeting with some very brief comments.  The FAA EASA International Safety Meeting opened in New Orleans on June 8, 2010.  The FAA EASA International Safety Meeting is an opportunity for the government of the world to coordinate their aviation safety regulatory and implementation efforts.

The recent Icelandic volcano issue has shown how important it is for the aviation authorities of the world to work together on aviation safety.  He expressed his appreciation for the focus of the Conference on safety management.

EASA is working on several operations-based rulemaking activities, based on its 2008 mandate for EASA to regulate Flight Crew Licensing.  They are reviewing stake holder comments on Flight Crew Licensing, Authority and Organization Requirements, Operational Suitability/Safety Directives, and Air Operations of [European] Community Operations.  EASA opinions are scheduled to be published by mid-2011 and implementing rules should be adopted by April 2012.

They are also working with Eurocontrol on Air Traffic Management and Air Navigation System rules, and they plan to have implementing regulations adopted by the end of 2012.

EASA has signed agreements with all of the ECAC states that are not part of the European Community, so that they will be following the EASA regulations.

EASA has been creating electronic courses to provide technical training on European regulations as well as the European bilateral.  The aim of these projects is to provide better (and more readily available) education on the requirements of the EASA rules and governing documents.

Europe has been implementing a State Safety Program (European Aviation Safety Programme) to meet the ICAO SSP requirements.  The objective of this plan will be to have a framework for dealing with common high level issues in Europe.  They will use safety risk analysis to focus their resources on the most important safety issues, and they will coordinate their efforts with the SSPs of each of the member states.  One goal of this program is to encourage a “just culture” paradigm in Europe.

EASA has formed a European Aviation Safety Advisory Committee to advise the Management Board of the Agency on safety strategy issues.

EASA will host an International Air Safety and Climate Change Conference in Cologne on September 8-9, 2010.  The focus will not be on the impact of aviation on climate change; rather the focus will be on the impact of climate change on civil aviation.  One focus area will be an examination of how certification standards need to change to reflect climate change issues.

EASA has been standardizing its internal processes, and they plan for the entire organization to be ISO 9001 certified by the end of 2010.  The FAA’s Aviation Safety organization is ISO 9001 certified.

Will the New Energy Legislation Affect Aviation?

The US House of Representatives has promulgated sweeping new energy legislation that would affect aircraft and their emissions.

The House bill is known as H.R. 2454.  It was passed in the House on June 26, 2009.  The next step is for the legislation to be taken up by the Senate.

The House legislation includes new standards for aircraft engines:

(c) Aircraft and Aircraft Engines-

`(1) Pursuant to section 231(a), the Administrator shall promulgate standards applicable to emissions of greenhouse gases from new aircraft and new engines used in aircraft by December 31, 2012. Notwithstanding any requirement in section 231(a), the Administrator, in consultation with the Administrator of the Federal Aviation Administration, shall also promulgate standards applicable to emissions of greenhouse gases from other classes and categories of aircraft and aircraft engines for such classes and categories as the Administrator determines appropriate and in the timeframe the Administrator determines appropriate. The Administrator may revise these standards from time to time.

`(2) Standards under section 231(a) applicable to emissions of greenhouse gases from new aircraft and new engines used in aircraft, and any later revisions or additional standards, shall achieve the greatest degree of emissions reduction achievable based on the application of technology which the Administrator determines will be available at the time such standards take effect, taking into consideration cost, energy, and safety factors associated with the application of such technology. Any such standards shall take effect after such period as the Administrator finds necessary to permit the development and application of the requisite technology.

The EPA would be required to promulgate new emissions standards for aircraft engines. These new standards would apply to new aircraft and also to new engines as of December 31, 2012. The legislation also requires the EPA to promulgate new emissions standards for all aircraft engines (including existing engines), without any particular time limit on when those standards would apply.

The word “notwithstanding” in this legislation is important. Under the current law, the EPA already has the power to set emissions standards for aircraft engines; but the existing law requires the EPA to make a finding that the class of engines affected “causes, or contributes to, air pollution which may reasonably be anticipated to endanger public health or welfare.” This means that under current law, the EPA may not impose emissions standards on engines that do not have an appreciable affect on public health or welfare. The limits of the existing law also forbid the EPA from changing “the aircraft engine emission standards if such change would significantly increase noise and adversely affect safety.” By imposing the new power to regulate engines “notwithstanding any requirement in section 231(a),” the new legislation would permit EPA to impose new emissions standards even if those standards would require engines to increase in their noise or if the changes would adversely affect safety.

The new aircraft standards are required to “achieve the greatest degree of emissions reduction achievable based on the application of technology which the Administrator determines will be available at the time such standards take effect, taking into consideration cost, energy, and safety factors associated with the application of such technology.” This gives the EPA the mandate to push the emissions standards to the limits.  Politically, many people have always viewed the aviation community as a rich potential source for emissions reduction, despite the fact that the aviation community has already achieved significant emissions reductions on its own.

While the current legislation forbids the emission standards from adversely affecting noise and safety, the new standard would only need to take those factors into consideration, but after taking them in to consideration, the EPA would be permitted to make the decision that the trade-off was acceptable.

In fact, if the EPA were to impose a new standard that affirmatively jeopardized air safety, the way to fight it would be to apply to the Secretary of Transportation for a finding that the EPA standard jeopardized safety, and then apply to the White House for a Presidential Order overturning the standards. The FAA would have NO independent power to avoid these standards for safety reasons.

Waxman to Energy: Congressional Shift May Signal Significant Change

In a close and hard-fought leadership challenge, Congressman Henry Waxman (D-CA) won the Chairmanship of the House Energy and Commerce Committee from Congressman John Dingell (D-MI) on Thursday.  Dingell had Chaired the Committee or served as Ranking Member (when the Republicans were in the majority) since 1981.

The Waxman coup is expected to accelerate passage of energy, climate and health legislation backed by President-elect Obama.  Dingell has been a champion of archetypical Democratic causes but he does have ties to business (his wife is a GM senior executive). Waxman has been known as an advocate of more extreme legislation, as a believer that current legislation has been inadequate in these areas.

More details are available from the NY Times Article.

Waxman’s Leadership may have an effect on the aviation community.  Because of its high profile, Aviation is a frequent target for environmentalists.  For PMA manufacturers who are able to demonstrate environmental improvements through their PMA parts, this could be a particularly lucrative market.  Environmental improvementsrecognized through PMA parts could include improved engine fuel economy, increased noise reduction, and/or reduced emissions.

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