MARPA Files Comments to Protect PMA Manufacturers

Last month, MARPA filed comments regarding the FAA’s Airplane Fuel Efficiency Certification Notice of Proposed Rule Making (“NPRM”). The NPRM seeks to implement a 2009 ICAO program that is designed to reduce CO₂ emissions from aircraft and engines. The EPA has already implemented aircraft emissions regulations and the FAA rule would similarly establish emissions standards.

Although the rule as drafted is clearly intended to apply only at the Type Certificate level, MARPA filed comments to ensure that the rule would not inadvertently be used to target PMA parts for their effect on carbon emissions from Type Certificated products. A requirement that PMA manufacturers perform CO₂ emissions analyses for each part to determine how the part would affect the overall CO₂ performance of the aircraft would be unduly burdensome on industry and impose excessive costs on PMA manufacturers. Moreover, a piece-part level analysis of CO₂ emissions is clearly outside the scope and intent of the NPRM.

MARPA’s comments asked that the FAA simply clarify and confirm that the rule applies only at the TC level and not to PMA parts. This is consistent with the language of the NPRM and the objectives of the ICAO program. MARPA appreciates the feedback from its members in helping us draft these comments. If you wish to review MARPA’s comments you can find them here.