Halon - Commission to propose remove aviation's critical use exemption
The European Commission (DG Environment) has issued proposals to remove the critical use exemption for certain halon based aviation safety applications. This will affect all halon based aviation safety applications for handheld fire extinguisers, APU/ engine nacelle and cargo compartments. Both military and civil aeroplanes would be affected.
EU deadlines, outside the ICAO framework, are proposed by DG-Environment for new production aeroplanes as well as for retrofitting all existing aeroplanes.
The EU Member States (at the level of Ministries of Environment represented in the Regulation 2037/2000 ‘comitology’ Committee) have been asked submit their written comments to the European Commission (DG Environment) by 31st May 2009 r. Based on those comments, the European Commission plans to make a new proposals to be voted through comitlogy in October 2009.
DG Environment has ignored the concerns of the entire aviation industry in relation to our safety concerns (all existing alternatives to Halon are less effective in fire fighting capabilities), huge cost impact and questionable environmental benefits (increased weight and Co2 emissions) if aviation would be forced to face out halon based safety applications before viable and safe alternatives are available.
In particular the Commision does not recognize the fact that no viable alternatives available for handheld extinguisher in aircraft (the Commission proposes a 2011 mandate for new production aeroplanes with retrofit of in-service aeroplanes proposed by 2020). All existing alternatives are less effective in fire fighting capability (=safety concern) and have additional weight (and as a consequence extra fuel burn and Co2 emissions which means that the environment justification is also questionable in respect of EU anti-climate change objectives). Therefore no dates should be decided (even not for new production aeroplanes) before safe and viable alternatives are available and the focus should be on further research. Retrofit by 2020 is even more questionable since retrofit probably would mean a complete retrofit of aircraft cabins (due to different size of the bottles etc). ICAO is not discussing any retrofit in this context so why should EU airlines alone be burdened?
In conclusion it seems DG-Environment is willing to comprise aviation safety, does not care about cost impact on the aviation industry and indeed is even willing to comprise its own anti-climate change objectives for a purely political agenda on halon replacement ref ozon layer protection (even although halon based aviation safety applications are only used in real safety emergency cases which means they impact on the ozon layer of their use by civil aviation is negligible). We therefore need to make sure that the EU Member States reject those proposals.