(10 pages) 

 CAEPSG.20093.IP.19 [FESG NOx production cut-off].doc

 COMMITTEE ON AVIATION ENVIRONMENTAL PROTECTION (CAEP) 

STEERING GROUP MEETING 

Salvador, Brazil, 22 to 26 June 2009 

Agenda Item 3: Forecasting and Economic Analysis Support Group (FESG)

CAEP/6 NOX PRODUCTION CUT-OFF COST ANALYSIS 

(Presented by the FESG NOX Stringency Task Group) 

SUMMARY 

This paper presents a high level estimate of the cost impact resulting from a 

production cut-off to the CAEP/6 NOX standard. The information presented in 

this paper builds upon the FESG assessment presented at the 2nd CAEP 

Steering Group meeting1

. The cost and the benefits are highly dependent on 

the way the production cut-off rule is implemented (with or without 

exemptions) and the response the one manufacturer will make in 

implementing this rule. If the engines affected are made compliant, FESG 

estimates non-recurring cost impacts of approximately $100 million, with 

some additional recurring costs. If the engines are not made compliant serious 

consequences will arise for the airlines that have aircraft in-service powered 

with these engines. They could be faced with operational problems and 

substantial costs due to the loss of resale value. These are likely to result in 

overall costs of up to $1 B. Recent B777 aircraft from airlines of China, Japan, 

Korea and the United States could be affected under this scenario. Even 

though the analysis only provides broad orders of magnitude, FESG is of the 

view that sufficient information is given to base a solid policy decision on.

1. INTRODUCTION

1.1 The purpose of ICAO NOX stringency requirements is to ensure that all newly developed 

airframes and engines incorporate the latest commercially available proven technologies across the entire 

product line, mindful that no single technology can be applied across the entire fleet2

. Unlike the CAEP/2 

standard set to ensure new NOX reduction technologies were incorporated into new engine designs as well 

 

1

 Ref. [CAEP-SG/20082-WP/06] “Production Cut-Off for Engine NOX standards”. Working paper submitted at the second Steering Group 

meeting of the CAEP/8 cycle held in Seattle (United States) on September 22-26, 2008. 2

 Ref. [CAEP/7-IP/2]. “Report of the FESG Industry Response Task Group”. Information paper submitted at the CAEP/7 meeting held in 

Montreal (Canada), from February 5 to 16, 2007. 

International Civil Aviation Organization

WORKING PAPER 

CAEP-SG/20093-IP/19 

02/06/09
CAEP-SG/20093-IP/19 - 2 -

as in-production engines by a certain date, the CAEP/4 and CAEP/6 NOX standards did not mandate a 

production cut-off for non-compliant engines. The CAEP/4 decision was based on the limited number of 

engines affected at the date of implementation and their expected future market share. The decision made 

at CAEP/6 was based on evidence that market forces were sufficient to bring non-compliant engines into 

compliance across the entire engine family.

1.2 Following the presentation of a working paper by the United States in November 20073

, the 

CAEP Steering Group directed WG3 and FESG to begin work to assess a production cut-off for the 

CAEP/6 NOX standard at a date 4 and 6 years after the implementation date for newly certificated 

engines, 31 December 2007, such that it can be considered at the CAEP/8 meeting. This suggestion was 

predicated on the notion that market forces did not appear to be working and the only way to assure 

compliance of non-compliant engines was through the introduction of a production cut-off. In response to 

a paper presented by ICCAIA at the same meeting4

, the Steering Group agreed to follow a step process to 

the assessment of a CAEP/6 production cut-off. They agreed that if sufficient evidence was produced to 

support the assertion that market forces had driven compliance then they would consider not continuing 

with a second phase to a full cost benefit assessment. However, if such evidence was not forthcoming, the 

Steering Group could decide to task FESG with a full assessment of the effects of a CAEP/6 production 

cut-off.

1.3 Although both FESG5

 and WG36 were tasked to look into the issue, it was agreed that FESG take 

the lead on providing a qualitative analysis that would provide sufficient evidence that market forces have 

driven compliance of in-production engines with the CAEP/6 NOX standard. 

1.4 At the second Steering Group meeting of the CAEP/8 cycle7

, FESG presented a working paper8

that provided detailed information on the status of the list of engines that were labelled as “in-production” 

as of 2004 that did not meet the CAEP/6 standard. In summary, the FESG assessment informed the 

Steering Group that all but 2 engine families currently in production had either already been made 

compliant or were nearing the end of a development program to become compliant with the CAEP/6 NOX

standard. FESG also presented data showing that the 2 non-compliant engine families have very low 

volume of sales and will soon be out of production. The environmental benefit from implementing a 

production cut-off to the CAEP/6 NOX standard would be negligible, as 99+% of in-production engines 

sold will meet the CAEP/6 NOX requirements by 2009. 

1.5 The information presented by FESG in this working paper did not sufficiently address the 

concerns of some CAEP members and the Steering Group directed FESG to produce a report on the costs 

that would be attributed to a production cut-off. One CAEP member stated that if FESG was going to take 

on this additional task that the costs should be analyzed and reported to present a detailed distributional 

analysis of costs by region, State and airline in addition to reporting the total cost impact. FESG reminded 

the Steering Group of the heavy workload it already had regarding the cost-effectiveness analysis of the 

NOX stringency options under consideration for CAEP/8 and other CAEP analysis tasks. FESG agreed to 

conduct a scoping analysis of the process and data that would be required to complete the cost analysis of 

 

3

 Ref. [CAEP-SG/20071-WP26]. “Production Cut-Off For CAEP/6 Engine NOX Standards”. Working paper submitted by United States at the 

first Steering Group meeting of the CAEP/8 cycle held in Zurich (Switzerland) on November 26-30, 2007. 4

 Ref. [CAEP-SG/20071-WP27]. “Production Cut-Off For CAEP/6 Engine NOX Standards”. Information paper submitted by the International 

Coordinating Council of Aerospace Industries Associations (ICCAIA) in response to [CAEP-SG/20071-WP26]. 5

 Ref. FESG work programme for CAEP/8. Task F.08 “Conduct appropriate analysis on the projected number of engines that will not meet the 

CAEP/6 NOX standards and reasons why any in-production engines remain non-compliant. The analysis should provide current and forecast 

sales as well as assessment of engines still “in-production” as spares or new engines”. 6

 Ref. WG3 work programme for CAEP/8. Task E.08.1.b) “Working with FESG, conduct appropriate analysis to assist decision making 

regarding a CAEP/6 Production cut-off provision.” 7

 Held in Seattle (United States) on September 22-26 2008. 

8

 Ref. [CAEP-SG/20082-WP/06] “Production Cut-Off for Engine NOX standards”. Working paper submitted at the second Steering Group 

meeting of the CAEP/8 cycle held in Seattle (United States) on September 22-26, 2008. 
 - 3 - CAEP-SG/20093-IP/19 

the production cut-off, however, it would be given low priority due to the other tasks that were considered 

to be higher priority. 

1.6 This paper provides information based on the analysis the FESG was able to do in the time 

available. The analysis provides some quantification by making comparisons with previous analyses 

conducted by FESG. However given the fact that the production cut-off would affect only one 

manufacturer, more specific and detailed information would be needed to perform a comprehensive 

analysis. Given the resources and the time available, the analysis presented here is the best FESG could 

deliver, but it should provide sufficient information to inform a policy decision. 

2. ENGINES IMPACTED BY PROPOSED PRODUCTION CUT-OFF 

2.1 Summary of in-production engine models that will not meet the CAEP/6 NOX standard by 2009. 

Engine Family Engine Model 

PW4x60 (PW4000 

with 94inch fan) 

PW4056 Phase 3 * 

PW4060 Phase 3 * 

PW4062 Phase 3 * 

PW4090 

PW4074D 

PW4077D 

PW4084D 

PW4090 

* TALON II combustor that is certified on PW4158 

could be installed and certified on PW4056/60/62. 

2.2 Table 1 in Appendix A provides an update to the projected delivery dates for the engine families 

listed in the table above. 

2.3 Table 3 in Appendix A provides information on the in-service aircraft powered by the affected 

engines sorted by aircraft type, country of domicile and by airline. 

3. COST IMPACT ANALYSIS 

3.1 This proposal would only be directly applicable to newly manufactured aircraft engines inproduction at the time of the proposed production cut-off date that did not meet the CAEP/6 NOX standard 

requirements. The in-service aircraft engines would not be required to comply with the new (CAEP/6) 

NOX emissions standard at any future date. However the costs and the methods to evaluate the proposal 

are highly dependent on the way the production cut-off is handled in practice. 

3.2 The results will depend critically on whether or not exemptions are granted. Given the limited 

number of engines affected (22 plus possibly a number of spare replacements for the existing fleet), in the 

past for comparable numbers of engines, exemptions have been granted. If this was to be the case for the 

implementation of a production cut-off for CAEP/6 NOX standard then this measure would not result in 

any significant costs nor any environmental benefits. 
CAEP-SG/20093-IP/19 - 4 -

3.3 In the case where no exemptions are granted either for engines fitted to new aircraft or for spares, 

two sub-cases can be distinguished; one where the manufacturer will take the necessary steps to make the 

engines concerned compliant and one where the decision is made not to on the grounds that it would not 

be a financially viable option. 

3.4 The decision is made to bring the engines into compliance

3.4.1 The method used for the CAEP/6 NOX stringency cost-effectiveness analysis was employed to 

estimate the cost impact from a production cut-off to the CAEP/6 NOX standard. Both engine families 

listed in the above table would require a TL2 technology response. From the FESG CAEP/6 NOX

stringency cost-effectiveness analysis9

, a TL2 technology10 response is where an engine manufacturer 

applies its best proven combustor technology, certified in at least one other engine family into 

another engine type, which would otherwise fail the proposed standard. A TL2 change requires 

modification and certification activities that are estimated to cost $50 million per engine family in 

2002 dollars. For the CAEP/8 NOX stringency analysis, ICCAIA has stated that the new MS2 

technology response11 is equivalent to the TL2 response and the non-recurring cost for the MS2 in 

2008 dollars has been estimated at $50 to $75 million per engine family.

3.4.2 The total non-recurring cost for a CAEP/6 NOX production cut-off is therefore estimated to be 

between $100 and $150 million in 2008 dollars. The cost impact may be closer to the lower estimate of 

$100 million since one engine model of the PW4x60, the PW4158, had been certified with the TALON II 

combustor and is now compliant with the CAEP/6 NOX standard. However, there are still incremental 

certification analysis and tests that need to be performed for each model within the engine family. This 

cost impact would be incurred by one engine manufacturer. 

Estimated Non-Recurring Cost Impact = $100 million (2008 dollars) 

This means an additional cost (depending on the moment the production 

cut-off would be implemented) of more than $4 million (2008 dollars) per 

engine, with a resulting increase in the price of these engines if these costs 

are passed on to customers (e.g. airlines). 

 

9

 Ref. [CAEP/6-WP/19] “Executive Summary of the Economic Analysis of NOX Stringency Options”. [CAEP/6-IP/13] “Economic Analysis of 

NOX Stringency Options”. Papers submitted by FESG at the CAEP/6 meeting held in Montreal (Canada) on February 2-12, 2004. 10 TL2 – Technology Level 2. Five technology levels to achieve compliance were considered in the CAEP/6 analysis: TL1 to TL5 (this latter 

level being further subdivided in TL5A and TL5B). “The technology level (TL) concept used in the CAEP/3 economic analysis of noise and 

emissions options was further developed and refined by WG3 based on actual and expected technologies available to manufacturers in the 

relevant time period. Specific TL are established on the basis of the nature of the technology change, and the effect on the combustor and 

engine design necessary for a non compliant engine to meet a given stringency option. The Fourth Steering Group Meeting endorsed the 

engine technology level matrix”. The TL definitions used in the economic analysis was provided by WG3. A TL2 level was defined as a 

“Major change with scaled proven technology. A change where known technology is applied within the exiting combustor envelope and is 

compatible with the engine thrust and pressure ratio characteristics, and could be implemented within the existing engine casing. A full engine 

certification program and aircraft flight test would be required to prove airworthiness. Reductions with a major change might typically be in 

the 5 to 15 percent range.” Ref. [CAEP/6-IP/13] “Economic Analysis of NOX Stringency Options”. Information paper submitted by FESG at 

the CAEP/6 meeting held in Montreal (Canada) on February 2-12, 2004, section 3, starting on p.11. 11 MS2 – Modification Status 2: Scaled proven technology. The “Modification Status (MS)” methodology for assessing engine technology 

responses to the proposed CAEP/8 NOX stringency options includes Minor Changes (MS1), Scaled Proven Technology (MS2) and New 

Technology (MS3). The approach is similar to that from CAEP/6, while avoiding the potential confusion between the use of the previous term 

“Technology Level (TL)” with the research orientated “Technology Readiness Level (TRL)”. Ref. [CAEP-SG/20082-WP/18] “NOX

Stringency Technology Response Assessment”. Working paper presented by WG1 and WG3 at the second Steering Group meeting of the 

CAEP/8 cycle held in Seattle (United States) on September 22-26, 2008. Section 3, paragraph 3.1, p.2. 
 - 5 - CAEP-SG/20093-IP/19 

3.4.3 There may also be some recurring costs impacts from additional production and maintenance 

costs, but these are expected to be limited. Similarly where the affected engines are made compliant, any 

losses of resale value should be limited. 

3.5 The engines are not made compliant

3.5.1 The situation is very different in the case engines are not made compliant, as the recurring cost 

impacts would be much higher. The aircraft and airlines that would be affected are given in Table 3 in 

Appendix A. This shows that there would be significant impacts for B777 aircraft operated by airlines 

from China, Japan, South Korea and the United States. 

3.5.2 If the engines mentioned in Table 1 in Appendix A are not made compliant and no exemptions 

are granted, the airlines that have aircraft in their in-service fleet powered by these engines are faced with 

a serious problem. First of all it would not be possible for them to acquire any new engines, with the risk 

of having aircraft out-of-service due to the inability to acquire spare engines to support the fleet. This risk 

becomes higher as the large fleets operated by a few carriers are sold and redeployed as smaller fleets to 

other carriers. If the new carriers operating smaller fleets are unable to acquire spare engines to be used as 

the installed engines are rotated through maintenance overhaul shops, then the risk of aircraft being outof-service becomes even larger. There are many operating costs associated with this type of event, such as 

lost revenue, costs associated with flight delays or even worse, flight cancellations. In the worst case it 

would mean cannibalisation of their existing aircraft. Furthermore it would become virtually impossible 

for them to sell their aircraft, with a significant loss of resale value. 

3.5.3 If the implementation date for the production cut-off was before 2014, there would be significant 

costs to operators taking the remaining few deliveries of aircraft with the affected engines. There would 

be significant cost to the engine manufacturer of the affected engine as well in term of lost sales. The 

remaining aircraft to be delivered would have to have alternative engines installed on the aircraft, which 

in turn, creates a commonality problem for these operators taking delivery of the remaining few aircraft. 

They would incur additional costs in the purchase of additional spare engines and incremental training 

costs. 

3.5.4 The CAEP/6 analysis of NOX stringency included estimates of recurring cost impacts of the 

stringency options examined. As shown in Table 2 in Appendix A, these recurring costs were higher than 

the non-recurring costs by factors of between 4 and 9, depending on whether losses of resale value were 

included or not. In the case where the affected engines are not made compliant, FESG considers that a 9 

fold factor would provide only a minimum estimate of these cost impacts. 

4. LIMITATIONS TO COST ANALYSIS 

4.1 Despite limited time and resources to devote to this task, FESG has been able to provide 

information on the in-service aircraft fleet that would be affected by a production cut-off. The distribution 

of the aircraft powered by the engines affected by this measure, shown in Table 3 in Appendix A, 

provides information on how these costs would be distributed between airlines. FESG has also been able 

to quantify the non-recurring costs that would be incurred by one engine manufacturer to respond to the 

production cut-off and bring these 2 engine families into compliance. 

4.2 FESG could only produce a rough assessment of the recurring costs. There would also be 

incremental manufacturing costs for increased complexity of design, if the engines were to be made 

compliant with the CAEP/6 NOX standard. Should the 2 engine families not be made compliant due to 
CAEP-SG/20093-IP/19 - 6 -

projected low sales volume, the incremental operating cost impacts to airlines having aircraft powered by 

the affected engines have not been analyzed. These costs include loss resale value. 

4.3 In summary, the estimated non-recurring cost impact of making affected engines compliant with a 

production cut-off to the CAEP/6 NOX standard has been estimated to be approximately $100 million in 

2008 dollars. In the event that the decision is made to bring the affected engines into compliance, 

recurring cost impacts would arise. A broad analysis of recurring costs, based on the analysis of the NOX

stringency options performed for CAEP/6 suggests that these may be higher by factors of between 4 and 

9, depending on whether loss of resale value is included. In the case where airlines would not be able to 

acquire additional engines for spares, these costs could be significant, with serious implications for the 

continued operation and resale value of the affected aircraft. In these circumstances a 9 fold factor giving 

an overall cost impact of $900m provides a minimum estimate of these costs. At the same time the 

environmental benefits will remain so small that it has not been possible to quantify them accurately. 

– END –
CAEP-SG/20093-IP/19 

Appendix A 

A-1

APPENDIX A 

Table 1 – Review of Orders for In-Production Engines That Do Not Meet the CAEP/6 NOX standards – Low 

Volume of Orders (Revised to update the projected delivery dates) 

Firm Order Backlog as of May 2009 – Number of Installed Engines 

Engine Aircraft 

Total 

Backlog 2009 2010 2011 2012 2013 2014 2015 

PW4062A 747-400F / -400ERF 8 4 4 

PW4090 777-200 / -200ER 14 6 4 2 2 

(Source: ACAS)12

Table 2 – Comparison of Recurring to Non-Recurring Costs from CAEP/6 Cost-effectiveness Analysis 

From CAEP/6 Cost-Effectiveness Analysis of NOX Stringency Options 

CAEP/4 – 10%: Mainly a TL2 technology response requirement

Recurring Costs Ratio of Recurring to

Discount Non-Recurring Costs 

Rate 

NonRecurring 

Costs Without Lost 

Resale Value 

With Lost 

Resale Value 

Without 

Resale Value 

With

Resale Value 

0% $360 $2,607 $3,258 7.2 9.1 

3% $324 $1,963 $2,508 6.1 7.7 

7% $284 $1,386 $1,820 4.9 6.4 

9% $267 $1,178 $1,566 4.4 5.9 

Note: TL2 – Technology Level 2 

 

12 ACAS – AirCraft Analytical System, by Reed Businesses Information, is an aviation market information system database. 
CAEP-SG/20093-IP/19 

Appendix A 

A-2

Table 3 – In-service Aircraft Fleets powered by PW4090 and PW4x60 Engine Families 

Data as of 1 April 2009 

Number of Aircraft PW4090 PW4x60 Engine Family PW4x60 Grand 

Country Operator 777 747 767 A300-600 A310 MD11 Subtotal Total 

ARGENTINA AEROLINEAS ARGENTINAS 1 1 1 

ARMENIA BLUE AIRWAYS (ARMENIA) 3 3 3 

AUSTRIA AUSTRIAN 4 4 4 

 LAUDA AIR 2 2 2 

BANGLADESH BIMAN BANGLADESH AIRLINES 2 2 2 

BRAZIL OCEANAIR (BRAZIL) 2 2 2 

 VARIG - VRG LINHAS AEREAS 2 2 2 

 VARIG LOG 1 1 1 

BRUNEI ROYAL BRUNEI AIRLINES 6 6 6 

CAMEROON CAMEROON AIRLINES 1 1 1 

CANADA AIR CANADA 7 7 7 

CHILE CHILEAN AIR FORCE 1 1 1 

 LAN AIRLINES 4 4 4 

CHINA AIR CHINA 10 12 7 19 29 

 AIR CHINA CARGO 5 5 5 

 CHINA CARGO AIRLINES 6 6 6 

 CHINA SOUTHERN AIRLINES 2 6 8 8 

 GRANDSTAR CARGO 1 1 1 

 GREAT WALL AIRLINES 4 4 4 

 HAINAN AIRLINES 3 3 3 

 SHANGHAI AIRLINES 7 7 7 

CHINA, HONG KONG CATHAY PACIFIC AIRWAYS 16 16 16 

 DRAGONAIR 2 2 2 

CHINA, MACAO AIR MACAU 2 2 2 

 VIVA MACAU 1 1 1 

COLOMBIA AVIANCA 7 7 7 

CZECH REPUBLIC CZECH AIRLINES 1 1 1 

EGYPT EGYPTAIR 5 2 2 7 

ETHIOPIA ETHIOPIAN AIRLINES 9 9 9 

FIJI AIR PACIFIC 2 2 2 

FRANCE CORSAIRFLY 6 6 6 

GERMANY AIR CARGO GERMANY 1 1 1 

 CONDOR FLUGDIENST 9 9 9 

ICELAND AIR ATLANTA ICELANDIC 1 2 3 3 

 AVION AIRCRAFT TRADING 1 1 1 

 ICELANDAIR 1 1 1 

INDIA AIR INDIA 4 6 3 9 13 

 DECCAN CARGO 3 3 3 

IRELAND AIRBUS FINANCIAL SERVICES 2 2 2 

 AWAS 1 1 1 

ISRAEL EL AL ISRAEL AIRLINES 5 5 10 10 

ITALY BLUE PANORAMA AIRLINES 4 4 4 
CAEP-SG/20093-IP/19 

Appendix A 

A-3

Table 3 – In-service Aircraft Fleets powered by PW4090 and PW4x60 Engine Families 

Data as of 1 April 2009 – continued

Number of Aircraft PW4090 PW4x60 Engine Family PW4x60 Grand 

Country Operator 777 747 767 A300-600 A310 MD11 Subtotal Total 

JAPAN ALL NIPPON AIRWAYS 30 30 

 GALAXY A/L (JAPAN) (CSD OPS) 1 1 1 

 JAPAN AIR SELF DEFENCE FORCE 1 1 1 

 JAPAN AIRLINES INTERNATIONAL 22 22 22 44 

LATVIA SMARTLYNX 2 2 2 

LIBYA LIBYAN AIRLINES 2 2 2 

LUXEMBOURG GLOBAL JET CONCEPT 1 1 1 

MADAGASCAR AIR MADAGASCAR 2 2 2 

MALAYSIA MALAYSIA AIRLINES 15 15 15 

 TRANSMILE AIR SERVICES 4 4 4 

MEXICO AEROMEXICO 6 6 6 

NETHERLANDS ARKEFLY 3 3 3 

 MARTINAIR HOLLAND 4 6 7 17 17 

PAKISTAN PIA 6 6 6 

PAPUA NEW GUINEA AIR NIUGINI 1 1 1 

PORTUGAL EURO ATLANTIC AIRWAYS 1 1 1 

 SATA INTERNATIONAL 1 1 1 

QATAR QATAR AIRWAYS 3 3 3 

REUNION AIR AUSTRAL 3 3 

ROMANIA TAROM 2 2 2 

RUSSIA TRANSAERO AIRLINES 4 4 4 8 

SAO TOME AND PRINCIPE STP AIRWAYS 1 1 1 

SAUDI ARABIA ASASCO AVIATION 1 1 1 

 KINGDOM HOLDINGS 1 1 1 

 SAUDI ARABIAN VIP 1 1 1 

SINGAPORE SINGAPORE AIRLINES 13 13 13 

 SINGAPORE AIRLINES CARGO 13 13 13 

SOUTH KOREA ASIANA AIRLINES 10 10 

 KOREAN AIR 22 44 10 54 76 

SPAIN AIR COMET 1 1 1 

 EADS CASA 1 1 1 

 PULLMANTUR AIR 3 3 3 

SUDAN SUDAN AIRWAYS 3 3 3 

SWITZERLAND BELAIR (SWITZERLAND) 1 1 1 

TAIWAN CHINA AIRLINES 9 9 9 

THAILAND ROYAL THAI AIR FORCE 1 1 1 

 THAI AIRWAYS INTERNATIONAL 13 13 13 

UKRAINE AEROSVIT AIRLINES 4 4 4 

UNITED ARAB EMIRATES DUBAI AIR WING 3 3 3 

MAXIMUS AIR CARGO 2 2 2 
CAEP-SG/20093-IP/19 

Appendix A 

A-4

Table 3 – In-service Aircraft Fleets powered by PW4090 and PW4x60 Engine Families 

Data as of 1 April 2009 – continued

Number of Aircraft PW4090 PW4x60 Engine Family PW4x60 Grand 

Country Operator 777 747 767 A300-600 A310 MD11 Subtotal Total 

UNITED STATES AIRCASTLE INVESTMENT 1 1 1 

 AIRCRAFT FINANCE TRUST 1 1 1 

 BOEING AIRCRAFT HOLDING CO 1 1 1 

 DELTA AIR LINES 35 35 35 

 EVERGREEN INTERNATIONAL 3 3 3 

 FEDERAL EXPRESS 26 19 18 63 63 

 GLOBAL PRINCIPAL FINANCE CO 2 2 2 

 GUGGENHEIM AVIATION INV FUND 1 1 1 

 HAWAIIAN AIRLINES 14 14 14 

 JT POWER LLC 1 1 1 

 MONTROSE GLOBAL CAPITAL 3 3 3 

 NORTHWEST AIRLINES 16 16 16 

 PALS 1 1 2 2 

 RYAN INTERNATIONAL AIRLINES 1 1 1 

 UNITED AIRLINES 52 30 35 65 117 

 UNITED PARCEL SERVICE 27 27 27 

 WELLS FARGO BANK NW NA TRUSTEE 2 2 2 

 WORLD AIRWAYS 2 11 13 13 

UZBEKISTAN UZBEKISTAN AIRWAYS 5 3 8 8 

VIETNAM VIETNAM AIRLINES 4 4 

YEMEN YEMENIA 4 4 4 

ZIMBABWE AIR ZIMBABWE 2 2 2 

Grand Total 166 229 212 94 53 77 665 831