November
22,
2004
Mr.
Jeffrey
R.
Holmstead
Assistant
Administrator
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
Ms.
Sharon
L.
Pinkerton
Assistant
Administrator
Aviation
Policy,
Planning
and
Environment
Federal
Aviation
Administration
800
Independence
Avenue,
SW
Washington,
DC
20591
Dear
Mr.
Holmstead
and
Ms.
Pinkerton:

On
behalf
of
the
State
and
Territorial
Air
Pollution
Program
Administrators
(
STAPPA)
and
the
Association
of
Local
Air
Pollution
Control
Officials
(
ALAPCO),
we
write
to
formally
notify
you
of
our
associations'
withdrawal
from
the
stakeholder
process
facilitated
by
the
U.
S.
Environmental
Protection
Agency
(
EPA)
and
the
Federal
Aviation
Administration
(
FAA)
to
develop
a
voluntary
emission
reduction
program
for
the
aviation
sector.
As
part
of
this
decision,
STAPPA
and
ALAPCO
have
rejected
the
ground
service
equipment
(
GSE)
memorandum
of
understanding
that
was
proposed
through
this
process.

Emissions
from
the
aviation
sector
represent
an
important
and
growing
cause
of
concern
to
those
responsible
for
achieving
and
sustaining
clean,
healthful
air
across
the
nation.
Because
states
and
localities
are
restricted
in
their
ability
to
regulate
aircraft
emissions,
representatives
of
several
state
and
local
environmental
agencies
and
organizations
of
air
pollution
control
officials
entered
into
this
stakeholder
process
in
1999
with
the
strong
and
clearly
stated
desire
to
reach
agreement
on
an
appropriate
strategy
for
achieving
meaningful
reductions
in
emissions
from
aircraft
engines.
As
the
discussions
ensued,
industry
representatives
to
the
process
urged
that
other
aviation­
related
emission
sources,
particularly
GSE,
be
considered.
State
and
local
representatives
agreed
to
broaden
the
scope
of
the
2
evaluation
of
potential
additional
emission
reduction
opportunities
with
the
understanding
that
our
primary
objective
continued
to
be
reducing
emissions
from
aircraft
engines.
More
than
five
years
later,
we
are
extremely
disappointed
that
no
progress
was
made
concerning
the
primary
objective
of
reducing
aircraft
emissions.

With
regard
to
the
GSE
memorandum
of
understanding,
during
their
2004
Summer
Meeting,
the
STAPPA
and
ALAPCO
Boards
of
Directors
and
Committee
Chairs
unanimously
agreed
that
the
proposal
was
inadequate
and
voted
to
reject
it.
A
year
ago,
when
the
state/
local
representatives
to
the
GSE
negotiations
briefed
the
members
of
STAPPA
and
ALAPCO
at
the
associations'
2003
Fall
Membership
Meeting
on
the
status
of
the
negotiations,
our
members
identified
many
overarching
concerns
that
would
need
to
be
addressed
in
order
for
the
associations
to
support
a
GSE
MOU.
In
the
following
months,
the
state/
local
negotiators
continued
to
articulate
these
concerns
during
the
stakeholder
discussions.
While
we
understand
some
progress
was
made,
the
final
proposal
offered
this
summer
was
inadequate
in
terms
of
scope
and
stringency
and
placed
unacceptable
constraints
on
state
and
local
air
agencies'
abilities
to
protect
the
public
from
the
adverse
health
impacts
associated
with
aviation­
related
pollution.
Among
the
elements
of
greatest
concern
were
1)
the
inadequate
fleet
average
emission
standard
for
NOx,
2)
the
exclusion
of
other
pollutants,
especially
fine
particulate
matter,
3)
the
exclusion
of
airports
beyond
those
in
ozone
nonattainment
areas
and
4)
inadequate
protections
against
"
dumping"
old
equipment
at
nonparticipating
airports.

In
conclusion,
we
appreciate
EPA's
and
FAA's
efforts
in
trying
to
facilitate
an
agreement
to
affect
voluntary
reductions
in
aviation
emissions.
We
share
the
disappointment
of
other
stakeholders
that
the
group
was
unable
to
reach
agreement.
Although
STAPPA
and
ALAPCO
and
the
state/
local
representatives
have
decided
not
to
continue
to
participate
in
the
stakeholder
process,
the
issue
of
aviation
emissions
remains
a
critical
concern
for
state
and
local
air
agencies.
Accordingly,
we
are
committed
to
identifying
and
implementing
strategies
to
achieve
meaningful
reductions
in
emissions
from
the
aviation
sector.

Sincerely,

Nancy
L.
Seidman
Dennis
J.
McLerran
STAPPA
President
ALAPCO
President
