UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

National Vehicle and Fuel Emissions Laboratory

2 000 Traverwood Drive

Ann Arbor, Michigan 48105

- 2498

March 27 , 2012

MEMORANDUM

SUBJECT: D iscussion with General Electric Regarding the Leadtime Associated the

Proposed Aircraft Engine Tier 6 NOx Production Cutoff

— January 4, 2012

FROM: Richard S. Wilcox , Environmental Scientist

Assessment and Standards Division

Office of Transportation and Air Quality

U.S. Environmental Protection Agency

TO: The Air and Radiation Docket

Docket No. EPA

- HQ

- OAR

- 2010

- 0687

We held a conference call on January 4 , 2012 to continue discussi ng a public comment

submitted by General Electric (GE) on our Notice of Proposed Rulemaking for new aircraft

engine NOx emission standards and other requirements (July 27, 2011, 76 FR 45012).

Specifically, GE expressed a concern that there may be inadequate leadtime for the FAA to

formally recognize Tier 6 compliance for the numerous engine models before the January 1,

2013 effective date of the Tier 6 NOx production cutoff. 1 Attendi ng the conf erence call for EPA

were Glenn Passavant and myself. Attending for the FAA was Ralph Lovine lli

. Attending for GE

was Will Dodds.

The purpose of the call was to provide an opportunity for the FAA to explain a process

they were developing to ensure that al l engines requiring a formal recognition of compliance

with the Tier 6 standards would receive such an acknowledgement for the FAA without affecting

normal engine production schedules after the January 1, 2013 cutoff date

. In advance of the

discussion , GE provided a list of questions via email. A copy of this email is attached.

The FAA generally described a pro cess that would begin after EPA’s final rule , and

conclude with either a letter to the engine manufacturer certifying an engine model as Tier 6 or

1 U.S. EPA, “Discussion with General Electric Regarding the Leadtime Associated with EPA’s Final Aircraft

Engine NOx Rule and the Proposed Tier 6 Production Cutoff

— January 3, 2012 ,” memorandum from Richard S.

Wilcox, Assessment and Standards Division, Office of Tran sportation and Air Quality, to docket EPA

- HQ

- OAR

2010

- 0687 , March 27, 2012.Tier 8 compliant based on existing certification reports, or a modification to the engine model’s

type certif

icate datasheet base on the same information. GE requested that the FAA initiate the

proc ess prior to EPA’s final rule to maximize the available leadtime to take the necessary action

.

attachmentattachment

From: "Dodds, Willard (GE Aviation, US)" <wi llard.dodds@ge.com>

To: Rich Wilcox/AA/USEPA/US@EPA

Date: 01/04/2012 01:17 PM

Subject: Questions on Tier6 certification procedures

Rich,

These are a few of the questions I have. It might be useful to get the manufacturers together to make

sure all th e issues are covered.

I don ’ t think this should really be a big deal, but if time is short, we should be prepared to complete the

process quickly.

Will the Engine Cert Data Sheets be updated to show compliance?

Can we show compliance with both Tier 6 and Tier 8 at the same time?

Will we have to try to correct for current measurement procedures (e.g. nitrogen vs. air zero gases)?

Will we have to update for current calculation procedures (e.g. revised standard hum idity)?

Will this just process just focus on NOx, and “ grandfather ” CO, HC and smoke?

Will there be a “ standard ” report format. Will a letter referring to the original report be sufficient?

When can we start the process? Do we have to wait until FAR par 34 is amended?

Thanks,

Will