Submission on a CO2 standard for new aircraft

An efficiency standard is a key element of ICAO’s basket of measures and is intended to deliver emissions reductions beyond business-as-usual. But on current indications the ICAO standard for new aircraft types will not affect any new aircraft types and will only cover 5% of the world fleet in 2030. In this submission T&E outlines its position that the EPA should ensure that any standard adopted ensures efficiency improvements that go beyond business-as-usual.