Dassault- Aviation appreciates the opportunity to review EPA draft and would like these following comments to be considered:
The proposed modifications in §87.23« Exhaust emission standards for Tier 6 and 8 engines” and §87.48 “Derivative engines for emissions certification purposes “ imply that if an engine modification occurs after January 1, 2014 and it is not considered as an engine derivative (per criteria (2) (b) (1)), the applicant will have to comply with the latest Tier 8 NOx standard regardless if the modification decreases the current NOx characteristics levels.
The ETM Vol II Doc 9501 recommends to “retain the existing certification basis of the parent engine if the modification(s) :
…
b) results in a decrease of the absolute emissions levels;
…”
Therefore, the proposed text is more stringent than the ETM Vol II.
Such recommendation could have a negative environmental impact as some technology improvement might not be implemented on in-production engine because they do not allow to meet CAEP 8 standard.
Moreover, it does not allow to maintain consistency with other standard such as EASA that proposed in NPA2011-08 to incorporate the ETM text on the applicable requirement of such engine modification.
Finally, the cost impact and emission “benefit/penalty” of such proposal has not been evaluated within the CAEP6 and CAEP8 process.
Dassault-Aviation recommends to maintain consistency with the proposed ETM Vol II Doc 9501.
Comment submitted by Dominique Reneric, Dassault-Aviation
This is comment on Proposed Rule
Control of Air Pollution From Aircraft and Aircraft Engines; Proposed Emission Standards and Test Procedures
View Comment
Related Comments
View AllPublic Submission Posted: 09/13/2011 ID: EPA-HQ-OAR-2010-0687-0053
Sep 26,2011 11:59 PM ET
Public Submission Posted: 09/26/2011 ID: EPA-HQ-OAR-2010-0687-0055
Sep 26,2011 11:59 PM ET
Public Submission Posted: 09/26/2011 ID: EPA-HQ-OAR-2010-0687-0056
Sep 26,2011 11:59 PM ET
Public Submission Posted: 09/26/2011 ID: EPA-HQ-OAR-2010-0687-0057
Sep 26,2011 11:59 PM ET
Public Submission Posted: 09/27/2011 ID: EPA-HQ-OAR-2010-0687-0058
Sep 26,2011 11:59 PM ET