HomeMy WebLinkAboutSS6 - John Wayne Airport (JWA) — NextGen Update; Letter to the U.S. EPA; Performing Additional Air Quality Analyses Relating to Emissions from JWA PlanesP_ CITY OF
NEWPORT BEACH
FoP City Council Staff Report
May 10, 2016
Agenda Item No. SS6
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: City Manager's Office
Dave Kiff, City Manager
949-644-3001, dkiff@newportbeachca.gov
PREPARED BY: Dave Kiff, City Manager
TITLE: John Wayne Airport (JWA) — NextGen Update; Letter to the U.S.
EPA; Performing Additional Air Quality Analyses Relating to
Emissions from JWA Planes
ABSTRACT:
Three issues are of note here: (1) The Federal Aviation Administration (FAA) is going
down the path of implementing more precise arrival and departure procedures, in the
name of greater airspace safety and efficiency (an initiative called NextGen); (2) last
year, the City Council voted 7-0 to discuss whether to ask a consultant to perform
additional air quality studies associated with takeoff emissions from commercial aircraft
leaving John Wayne Airport (JWA); (3) at the same time, the US Environmental
Protection Agency (US EPA) in Summer 2015 announced new rulemaking on
greenhouse gases (GHG) associated with aircraft operations.
RECOMMENDATION:
Offer any comments or direction on any of the three issues.
FUNDING REQUIREMENTS:
Sending a letter to the US EPA has only minimal costs. The two study approaches
discussed in the staff report would run up to $106,000 (the top end of a Phase II of Dr.
Karleen Boyle's review) or into several million dollars for a rigorous Health Risk
Assessment. Staff is not sure at this time as to the costs involved in testing a
dust/particle suppression program at or near JWA.
DISCUSSION:
JWA is one of the community's most important neighbors, given the way that it impacts
both our economic base and our quality of life. The City, the County of Orange, Stop
Polluting our Newport (SPON), and the Airport Working Group (AWG) have worked
collectively since the 1980s to ensure that JWA remains a neighborhood -friendly airport,
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all the while complying with federal law regarding local restrictions on noise and
capacity.
A Settlement Agreement exists to maintain a noise -based curfew, caps on the annual
amount of passengers that can come through the airport, and caps on the average
number of daily departures for generally the loudest commercial flights. Living
underneath the departure path for a large airport certainly has its disadvantages,
centered primarily around noise but also relating to aircraft emissions.
Click on the hyperlink for more background about Settlement Agreement.
NextGen
NextGen is a national effort to use technology to narrow flight arrival and departure
corridors. For JWA, NextGen (locally referred to as the Southern California MetroPlex
effort) would merge JWA's two remaining Conventional Standard Instrument Departures
(SIDs) for commercial carriers into precise technology -guided "Area Navigation" or
"RNAV" paths that will generally overlay each other.
JWA already has one RNAV SID — the STREL — which is for flights going south and
east of Las Vegas. The STREL would transition into a similar RNAV SID called the
PIGGN.
As far as we can tell, all three new RNAV SIDs would fly coastward off the runway, then
one small turn to the pilot's left, then straight over the Newport Dunes and Noise
Monitoring Station #7, then over Balboa Island at about Ruby Street, over the Peninsula
between Peninsula Point and the Balboa Pier, then offshore, at which time a turn north
or south would occur. In addition to the PIGGN RNAV SID (covering about 50% of all
commercial flights), the FINNZ would be generally for some flights going north and to
Las Vegas or Salt Lake City (<10% of flights) with the HHERO for all other flights
headed north (about 40%).
The brief update for the Council is that the FAA is still reviewing the public and agency
comments sent in (including the City's 20+ page letter) to the FAA's Draft Environmental
Assessment (EA) for the Southern California MetroPlex effort. While it remains difficult
to ascertain, it appears to be more likely than not that the FAA will respond to some of
the submitted comments. Recall that the City offered three main comments — that a
flyover waypoint over Newport Dunes remain in place for all three departures, that a
flyby waypoint offshore called the STREL become a flyover waypoint, and that the FAA
allow a six-month testing period for the adopted SIDs versus a 90 -day period.
PIGGN and FINNZ/HHERO are tentatively planned to be finalized in January 2017 and
April 2017, respectively. The old CHANNEL Conventional SID would remain in place
for the few planes that do not have the technology to fly an RNAV route.
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Outside of NextGen, the FAA has told JWA staff that any westerly drift on flights using
the CHANNEL or MUSEL Conventional SIDs that may be occurring since Fall 2014 is
likely to be fully resolved with the implementation of PIGGN, FINNZ, and HHERO.
Further, a staff member at the FAA in charge of MetroPlex/NextGen for Southern
California has expressed an interest in speaking more with the City about a possible
"curved" departure for HHERO, and City staff is preparing for that discussion.
Air Quality/Emissions Studies
In August 2015, the Citizens Aviation Committee asked Committee Chairman Petros to
bring an item before the City Council that would inquire as to whether one or more air
quality or water quality studies, supplemental to one done in 2009, might be appropriate
to consider. More could be done to drill down more deeply on the data from 2009.
Also, a larger Health Risk Assessment might be appropriate to consider. The Council
later (on September 8, 2015), voted 7-0 to bring these matters back at a future agenda.
Prior to bringing the issue back to Council, the Aviation Committee discussed these
issues again at a December 2015 meeting. At the meeting, the Committee moved to
support asking the Council to: (1) consider whether a "curved" departure path in the
Upper Newport Bay might work well for certain NextGen Departures; (2) to further study
altitudes (JWA's most recent altitude analysis is now public and can be found on the
City's website under April 2016 Monthly Reports); and (3) consider sending a letter to
the US EPA in support of rulemaking for new regulations of certain aircraft emissions,
such as GHG. The Committee discussed supporting the rulemaking in the context of an
alternative to additional emissions studies or a health risk assessment, but did not
directly address the studies themselves. As such, this discussion comes back now
before the City Council.
What have we done previously regarding emissions?
In April 2009, the City entered into a contract with Dr. Karleen A. Boyle to "collect
detailed air sampling to test for airport -associated polycyclic aromatic hydrocarbons
(PAHs) and metals." Dr. Boyle completed her study (Air Quality in Newport Beach —
Field Measurements of Ambient Particulates and Associated Trace Elements and
Hydrocarbons) in September 2010.
The study looked at:
Six field locations where ambient PM2.5 (Particulate Matter of 2.5 microns) was
measured. The locations were:
o Two on the JWA approach corridor (roughly the northerly edge of the
commercial runway ["Runway"] and at the Main Street parking lot ["Parking"]).
o One just coastward of SR 73, at NB Fire Station #7 (Santa Ana Heights)
o The Boys and Girls Club at Eastbluff
o The NB Lifeguard HQ near the Newport Pier
o The intersection of the 22, 57, and 5 Freeways near Orange.
Concentrations of particle -associated metals, trace elements, and hydrocarbons.
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Chemical profiles of locations, comparing them to determine whether different
emission sources may be distinct.
Boyle's 2009 study noted that:
There are many sources of Urban PM, such as vehicles, tire and brake wear,
construction, wood smoke, and more.
Airport -associated PM sources are engines, ground equipment, power units, tire and
brake wear, generators, fuel storage, and more.
JWA has emission -control practices in place, such as the use of electrical power,
CNG, and low -emission vehicles.
The results of the Study included the following, though noting that the Study was
designed as a "preliminary assessment" with "minimal sample sizes employed (n=3)"
and that "more data (is) needed for definitive results":
Several statistically significant trends were detected, even at a very low level of
replication.
(This) suggests that real differences are present in PM2.5 characteristics between
locations.
Generally, PM2.5 concentrations were highest at the Fire Station, Runway, and
Parking locations.
Dr. Boyle's conclusions included:
Ambient PM2.5 concentrations in Newport Beach are within federal air quality
standards.
PM2.5 at Runway and Freeway locations differs in chemical composition and relative
concentrations of certain elements.
With more study, one might be able to determine "fingerprints" to allow particulate
emissions to be associated with their source.
Previous studies (at other airports) have documented real-time peaks in aircraft -
related UFP (ultra -fine particulates) over 900 meters downwind of airports.
This study's results suggest that peaks for individual take -offs and landings translate
into measurably increased concentrations of particle -associated metals and PAHs
when averaged over hours.
Data suggests that aircraft particulate emissions may persist a significant distance
from the airport (up to 10 kilometers for particle -associated sulfate and some light
PAHs).
As Dr. Boyle concluded her work, the City and Dr. Boyle released the report and her
conclusions, and made some presentations associated with what she found. Dr. Boyle
made "future research" suggestions but the City at the time did not move forward on
these. Readers who wish to review the 2009-2010 study or the presentation associated
with it can go to http://www.newportbeachca.gov/government/departments/city-
manager-s-office/aviation-committee/special-reports.
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What would "future research" or a Phase II of Dr Boyle's study look like?
In 2010, Dr. Boyle concluded that "future research" from her Study could provide a more
robust data set (among other things) and involve: (1) more sampling periods at the
same locations; (2) more sampling stations at crosswind and downwind locations to
better define the transport of aircraft -associated PM; (3) adding sampling locations of
concern to the community, such as the Upper Newport Bay; and (4) a design of a
"before/after" field sampling study to assess the effectiveness of mitigation strategies.
Following a more recent conversation with Dr. Boyle by Assistant City Manager Carol
Jacobs, Dr. Boyle submitted a preliminary proposal that would have "two primary
objectives" (see Attachment A for the scope of work):
1. To expand the air quality database collected during Phase I by using the same
methods to sample original locations and additional locations of concern for public
health. The measurements of ambient PM2.5 obtained will give us data on exposure
in residential areas of the City which can then be compared to results of
epidemiology studies to assess whether these levels have the potential to adversely
impact public health.
2. To evaluate the effectiveness of a potential low-cost mitigation strategy that might be
employed to remove aircraft -generated particulates from the air near the airport,
such as the installation and operation of a dust/particle suppression system on or
near the end of the runway.
The proposal's cost, depending on the sampling quantities, ranges from $77K to $106K.
What about a "Health Risk Assessment" — what would that entail?
A Health Risk Assessment (HRA) can be a significantly complex effort that looks at a
fixed population's health over what can be a long period of time. It can be less than that
as well — but in our specific case, some residents have inquired as to whether their
health has been impacted because they live near an airport. The effort to affirmatively
or negatively determine that could be extensive, and could involve:
Determining and securing a statistically -significant number of residents willing to
participate, including giving detailed medical information.
Effectively screening -out other factors, from other environmental factors (freeways,
Coast Highway, work and job locations), to previous residences, to family
predispositions and more.
Conducting far more detailed air quality tests than we have done before, including
attempting to isolate adverse air quality impacts solely associated with aircraft
takeoffs from JWA (versus local auto traffic, freeway traffic, buses, trucks, boats,
wood -burning fireplaces, construction, and even aircraft going over the community
unrelated to JWA departures or arrivals).
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Conducting the actual medical research, including questionnaires and one-on-one
visits with the sample group.
Following, testing, and interviewing the group over multiple years.
Arguably, and at the same time and expense, doing all of this with a similar cohort
that is NOT near an airport like JWA, if we could find that group and a similar
number of willing participants.
The above could last for multiple years and cost millions of dollars, if willing participants
could be determined. I am sure that something less substantive could be done, but
arguably with less value from the end product.
The CDC suggests that HRAs generally involve a "systematic approach to collecting
information from individuals that identifies risk factors, provides individualized feedback,
and links the person with at least one intervention to promote health, sustain function
and/or prevent disease." A HRA would collect data such as:
Demographic characteristics — age, gender.
Lifestyle — exercise, smoking, alcohol intake, diet.
Personal and family medical history (where such questions are legal).
Physiological data — weight, height, blood pressure, cholesterol.
Attitudes and willingness to change one's behavior in order to reduce risk.
If the above is the case, I'm not sure what the intervention or behavioral change could
be — possibly to move to an area where there is perceived to be less ambient air
pollution (even though, as Dr. Boyle's Phase I study notes, air quality in our region
continually meets federal thresholds for particulate matter).
Finally, to what end would additional emissions studies or a Health Risk Assessment be
used? Medical officials can say "don't do a test unless you are prepared to act on the
results." One community's efforts to limit an airport's operations because of air quality
isn't likely to be successful. The FAA and the US EPA have worked jointly on aircraft
emissions standards that apply nationwide, and these standards are met in modern
planes that fly from JWA.
In the coming few years, fleets will begin operating the Boeing 737 -MAX (Southwest
expects deliveries of its 737 -MAX orders in 3rd Q of 2017) and the Airbus A320neo
(already in some fleets). These are planes that appear to have distinctly lower
emissions as well as greater fuel efficiency and somewhat less noise. There is not yet a
definitive local understanding as to whether these planes will be used at JWA.
US EPA Rulemaking on Aircraft GHG
In June 2015, the US EPA announced that it will look at additional "rulemaking"
regarding aircraft emissions, specifically in regards to GHG. Rulemaking is an
executive branch action that suggests gathering additional research, public input, and
related data about a proposed change, and is relatively early in any process. This
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follows a notice of intent to sue filed against the EPA by the Center for Biological
Diversity and Friends of the Earth, (represented by Earthjustice) for failing to reduce
aircraft GHG pollution.
In the June 2015 announcement by US EPA, it stated:
The EPA Administrator is proposing to find that GHG emissions from certain classes
of engines used primarily in commercial aircraft contribute to the air pollution that causes
climate change and endangers public health and welfare. Specifically, she proposes to find
that GHG concentrations in the atmosphere endanger the public health and welfare of
current and future generations within the meaning of section 231(x) of the Clean Air Act.
She proposes to make this finding specifically with respect to the same six well -mixed
GHGs -- carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and
sulfur hexafluoride -- that together were defined as the relevant air pollution in the 2009
Endangerment Finding under section 202(a) of the Clean Air Act. The Administrator is also
proposing to find that GHG pollutant emissions from certain classes of engines used in
aircraft are contributing to this mix of GHGs in the atmosphere.
Rulemaking can be a precursor of additional regulation, but such regulation is likely to
be opposed by air carriers and some members of Congress. The official comment
period for the rulemaking ended by September 2015.
At the Committee's December 2015 meeting, it focused on asking the City Council to
send a letter to the US EPA supportive of additional review of, and possible regulations
over, aircraft emissions (see Attachment B). At the same time, some members of the
Committee requested further Council discussion of whether to go further in our air
quality testing and/or embark upon a larger HRA.
Aviation Committee member Bonnie O'Neil, a Dover Shores resident who is also a
member of Air Fair and the Airport Working Group (AWG) puts it this way (in an e-mail
to me on March 31, 2016):
My objective (is) a path that determines the facts, specifically as to what extent
plane emissions have on our health due to living with JWA's flight path over our
homes. Dr. Boyle's previous study indicated there was cause for concern. Therefore, it
seems prudent and reasonable that since we know there is a probable health risk, it is
not wise to ignore it. It seems more responsible to glean more information as to the
actual extent of risks. Hopefully they are low risks, but at this point we do not
know. Doing nothing could prove problematic in several ways, not the least of which
can be seen in what is happening with the recent cities who knew there was lead in their
city's water supply but did not do enough to protect citizens from the known danger.
... It seems risky to have planes fly in a more deliberate, narrow departure pattern,
thereby causing a much higher impact on thousands of residents and their
families. That is what Next -Gen will do. If we had proof our health was or could be
negatively impacted (and maybe Dr. Boyle's report alone would accomplish that),
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wouldn't it be prudent for our city and maybe county to formally point the risk factor out
to the FAA and EPA? ... A letter from our city could give the FAA pause to consider
and possibly mitigate the problem by using higher altitudes and/or fanning planes to
alleviate the excessive damage to a specific community...
1 attended a conference several years ago in our area that was conducted by the
FAA. Experts explained in detail the numerous noise studies that have proved without
any doubt that excessively loud noises, particularly planes during take -off patterns and
those flying at low altitudes directly overhead have proven to be responsible for
detrimental impacts on one's health. Obviously, the more flights over a specific
community increases that risk.
One more problem is the possibility that the Bay itself and surrounding wildlife areas are
also impacted by plane pollution. Residents who study plant and animals (even bird
watchers) in the area claim they have witnessed and documented unusual behaviors,
which they attribute to the onset and/or increase of planes overhead. Some species
known to have occupied the area for many decades are totally absent from the Bay
area now. That may have occurred naturally and not caused by planes, but it is another
issue that could be explored. While that is not my area of expertise, I suspect there are
others who might have helpful information on the subject.
I appreciate Ms. O'Neil's perspective, and typically agree that more data is always
helpful. I am not as optimistic here in thinking that more data will attain any meaningful
change in the FAA's or the air carriers' actions. To me, the best progress on air quality
can be made via a nationwide effort to increase the efficiency of modern airplanes —
efficiency that can relate in less fuel being burned, less noise, and a safer airport -
adjacent environment. One perspective might argue that this move towards greater
efficiency is happening already (such as with the 737 -MAX and the A320neo), as air
carriers seek to save on fuel costs and lessen impacts on neighborhoods full of
residents who are their customers, too.
Council has a variety of options here. They could authorize sending a letter to the US
EPA regarding GHG rulemaking, in accordance with the thoughts of the Aviation
Committee. Council may wish instead to embark upon Phase II with Dr. Boyle and/or
something more significant. Staff certainly would implement that direction if it is made.
Before concluding, I would note that the proposed study from Dr. Boyle would not be a
study of whether our Federal government is "geo-engineering" us all by placing climate
change -slowing chemicals in jets, then crisscrossing the country, spraying them
randomly (as suggested by the "chemtrails" theorists). These allegations have been
debunked by every reputable scientific source. Jet contrails are, as they have always
been, accumulations of frozen water vapor from jet engine combustion that tend to
remain in the atmosphere longer and disperse more slowly if atmospheric humidity is
high.
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ENVIRONMENTAL REVIEW:
Staff recommends the City Council find that this action is not subject to CEQA pursuant
to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable
indirect physical change in the environment) and 15060(c)(3) (the activity is not a
project as defined in Section 15378) of the CEQA Guidelines, California Code of
Regulations, Title 14, Chapter 3, because it has no potential for resulting in physical
change to the environment, directly or indirectly.
NOTICING:
The agenda item has been noticed according to the Brown Act (72 hours in advance of
the meeting at which the City Council considers the item).
Attachments: A — Draft Scope of Work for Phase II Air Quality Study
B — Draft Letter to the U.S. EPA
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Attachment A
Proposal for Phase II Field Sampling of Air Quality in Newport Beach, California
December 11, 2015
Requested by: The City of Newport Beach
Submitted by: Karleen A. Boyle, Ph.D.
Project Background: In December of 2009, concerns about increased air pollution associated with the
proposed expansion of John Wayne International Airport (JWA) prompted The City of Newport Beach to
commission an air quality study by Karleen A. Boyle, Ph.D. This study used portable air sampling devices
to measure ambient concentrations of airborne particulates- and the trace metals and hydrocarbons
associated with these particles- in areas of concern. The specific component of air pollution measured
was PM 2,5 (particles with an aerodynamic diameter smaller than 2.5 micrometers).
The results of this study indicated that, while ambient PM2.5 was within federal air quality standards,
aircraft -associated particulate emissions persisted much farther from airport operations than air quality
models would predict, with elevations persisting up to 10km away from the airport in some cases. Data
from Phase I showed that the field air sampling methods used were successful in detecting statistically
significant differences in the amounts and chemical composition of PM2.5 at locations of concern. That
study recommended that a larger -scale sampling project employing these methods be used to address air
quality concerns in the community.
Based on resident's complaints of "soot" deposition on their property and concerns about air quality
impacts to their health, the City of Newport Beach has requested this proposal to build on the database
established by the initial air quality study and to measure PM2.5 levels in residential areas of the city to
assess exposure levels.
Proposed Research: The proposed Phase 11 Air Quality Study will have two primary objectives:
1. To expand the air quality database collected during Phase I by using the same methods to
sample original locations and additional locations of concern for public health. The measurements
of ambient PM2.5 obtained will give us data on exposure in residential areas of the city which can
then be compared to results of epidemiology studies to assess whether these levels have the
potential to adversely impact public health.
2. To evaluate the effectiveness of a potential low-cost mitigation strategy that might be employed to
remove aircraft -generated particulates from the air near the airport.
Budget Overview: To maximize planning flexibility, the project budget is divided into 3 general options:
1. Core Data Set
2. Mitigation Tests
3. Residential Sampling Locations
Costs are estimated for each of these options incrementally so that the City of Newport can target field
sampling to best meet its needs.
Research Outline
Core Data Set — The core data would consist of approximately 30 air samples (n=30). Samples will be
taken at several of the original study sites to allow comparisons of residential measurements with
baseline data from Phase I of the research (see maps in Phase I Final Report). An apartment complex
immediately adjacent to, and downwind of, JWA's runways will be sampled.
Core Sampling Locations:
Runway
Airport Parking Lot
Apartments on Skyline Drive
Coastal Control
Freeway
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Mitigation Tests - This option can be added to the core data set to test whether a low-cost mitigation
strategy deployed at sites of concern is effective in reducing the concentrations of PM2.5 measured at the
apartment sampling location.
Residential Sampling Locations- This option allows the addition of sampling locations in residential
areas of concern to the City. Ideally, these locations will be selected based on consultation with the City,
resident complaints, and research needs. It is most informative if locations are added in pairs on opposite
sides of the flight path. This allows data on the margins of emission plumes to be collected.
Recommended additional locations:
East Bluff Residence
Back Bay Residence
Fire Station
Lifeguard Tower
This sampling design pairs two of the original sampling locations with two residential locations not
previously sampled in order to give us measurements of PM2,5 exposure near homes and schools.
Comparing residential PM2.5 levels to data from Phase I air sampling will provide context for our findings
and allow more tests for statistical significance to be applied to the data set.
Recommendations
The air quality data obtained in Phase I of this study showed that these methods were able to reliably
measure and compare concentrations of PM2,5 on a regional scale. They also identified significant
differences in emission profiles between the runway, parking and freeway sampling sites which allowed
aircraft emissions to be distinguished from background urban and automotive emissions. The fact that
aircraft -associated PM2.5 elevations were detected up to 10km from the airport by the Phase I study
supports resident's concerns about potential adverse impacts of these emissions on their health. Further
air sampling in residential areas of Newport Beach will help to determine whether these concerns are
justified. If field tests demonstrate that particle -scrubbing mitigation is able to reduce PM2.5
concentrations in areas of concern, this would provide a low-cost mitigation option that could be
employed to reduce potential human health and environmental impacts.
Summary Budget Estimates
Newport Beach Air Quality Study - Phase II
Item Description
Amount
Amount
Amount
Study Design and Field Sampling
ContractDr: Applied Ecological Research, Inc.
Labor and Materials $
16,450.00
Labor and Equipment $
2,335.00
Labor and Materials $
1,430.00
Chemical Analyses
Contractor: Desert Research Institute n =
30
n=6
n=10
Inorganics: $
37,934.42
Inorganics: $
3.624.00
Inorganics: $
6,040.00
Hydrocarbons $
22,762.00
Hydrocarbons $
8.592.00
Hydrocarbons $
7160.00
Mitigation Subtotal $
14,551.00
Mitigation Subtotal $
14.551.00
Core Subtotal $
77,146.42
Core Subtotal $
77,146.42
Core Subtotal $
77,146.42
Study options: Core Data Set (30 samples) $
77,146.42
Core Data Set+ $
91,697.42
Core Data Set+ $
106,327.42
Mitigation Test
Mitigation Test+
2 Residential Locations
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Attachment B -- DRAFT
May 11, 2016
US Environmental Protection Agency
Air and Radiation Docket and Information Center (6102T)
1200 Pennsylvania Avenue NW
Washington, DC 20460
RE: Rulemaking regarding GHG and aircraft emissions
To Whom it May Concern:
The City of Newport Beach, California, is supportive of the US EPA's additional review of
the possible environmental impacts, including of air quality, regarding emissions of specific
greenhouse gases (GHG) that can both contribute to climate change and to "endanger the
public health and welfare of current and future generations within the meaning of Section
231(a) of the Clean Air Act."
These gases may include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons,
perfluorocarbons, and sulfur hexafluoride.
Our community does not seek to further limit air carrier operations nor the important
commerce and transportation provided by air transit. However, we believe that the aircraft
manufacturing industry should be doing all it can to modernize engine technology to reduce
fuel use, emissions, and to improve resultant air quality.
We realize that this letter comes to you past the official time period for comments on the
rulemaking endeavor, but transmit it in the spirit of our concern that this effort continue to
move forward.
We look forward to improvements in these technologies in the years ahead, either by self -
initiated change by air carriers or by additional regulation that accommodates the wishes of
all affected parties.
Sincerely,
DRAFT
Diane Brooks Dixon
Mayor of Newport Beach
CC' Members of the Newport Beach City Council
The Honorable Michelle Steel, Vice -Chairman of the OC Board of Supervisors
The Honorable Dana Rohrabacher, Member of Congress
The Honorable Dianne Feinstein, Member of the US Senate
The Honorable Barbara Boxer, Member of the US Senate
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