(13 pages) CAEPSG.20093.WP.039.6.en.doc 

### COMMITTEE ON AVIATION ENVIRO NMENTAL PROTECTION (CAEP)

STEERING GROUP MEETING

Salvador, Brazil, 22 to 26 June 2009

Agenda Item 6: Emissions Technical – WG3

PRODUCTION CUT-OFFS AND ASSOCIATED FLEXIBILITIES FOR ICAO ENGINE EMISSIONS STANDARDS

(Presented by U.S. Representative)

SUMMARY
Implementation of production cut-offs fo r emission standards will confirm that CAEP is serious about providing mean ingful emission reductions from all production aircraft engine models with in established timeframes, when new emission standards are adopted. This working paper recommends that at CAEP/8, CAEP adopt a production cut-off for CAEP/6 NOx standards of December 31, 2010; that during the CA EP/9 cycle, CAEP assess and consider a production cut-off for the CAEP/8 NOx standards; and that CAEP include consideration of production cut-off in all future CAEP standards.

CAEP decisions regarding stringency of new emission standards are based on the application of high technology readin ess level approaches, so there is no barrier to implementation of provisions ultimately requiring that all current production engine models eventually incorporate such technology. Recent CAEP decisions regarding emission sta ndards and production cut-offs were unbalanced in the sense that the stri ngency of the standards was based on application of technology of a high readiness level, but there were no provisions ultimately requiring that a ll current production engine models eventually adopt such technology. Based on discussions at CAEP Working Group 3, manufacturers now state that a ll production engine models will meet the CAEP/6 NOx standards by the end of 2010. Therefore, we recommend that a production cut-off for the CAEP/6 NOx standards be established for December 31, 2010. We are also aski ng that CAEP assess and consider a production cut-off for the potential CAEP/8 NOx emission standards during the CAEP/9 cycle. Moreover, we are requesting that consideration of production cut-off be formally incorporated as part of all future ICAO emission standard-setting programs and that this action be taken in the CAEP cycle following the cycle in wh ich the standards were set. International Civil Aviation Organization



### WORKING PAPER CAEP-SG/20093-WP/39
8/6/09CAEP-SG/20093-WP/39 - 2 -

In addition, for manufacturers who may potentially need some flexibility in meeting a production cut-off as part of an orderly transition to new standards, flexibilities in the form of exemption provisions should be established that could permit on a case-by-case basis temporary relief for a low-volume production of engines not meeting the la test standards (provisions should be adopted for a permanent exclusion for engine units used in military applications). These provisions should be applied to all future emission standards with production cut-offs, including CAEP/6 NOx.

Action by the CAEP-SG is in paragraph Error! Reference source not found.

.

1. INTRODUCTION

1.1 A production cut-off is a date after which a ll in-production engine models must meet a given emission standard. A production cut-off is an essential element of any emission standard because it ensures that an emission standard will actually prov ide the expected air quality improvements within an established timeframe. Without a production cut-off, there is no guarantee as to when full compliance with a given emission standard will be achieved. Even though emission standards normally have substantial lead time and phase-in periods, there ar e situations where a manufacturer may need some limited flexibility to continue to produce noncompliant engines after the production cut-off date. Toward that end, along with any production cut-off, specifi c flexibilities for the engine manufacturers should also be established that could, under certain circumstance s, allow a limited number of noncompliant engines to continue to be produced. Based upon our technical analysis, we specifically recommend a production cutoff of December 31, 2010, for the CAEP/6 NO
x emission standards. Furthermore, because a production cut-off is such a fundamental element of any sta ndard, we recommend that production cut-offs be fully assessed and adopted for all future ICAO emissions standards. This should begin with the CAEP/8 NO x emission standard. We also recommend that CA EP develop and recommend to ICAO manufacturer flexibilities related to production cut-off provisions.

2. BACKGROUND

2.1 A similar working paper was presented by the U.S. Environmental Protection Agency (EPA) at the Working Group 3 meeting in London, England, April 1-3, 2009 (CAEP8-WG3-WP6-14, Production Cut-Off ). As stated in that paper, at the September 2008 Steering Group Meeting in Seattle, the meeting agreed to proceed with further studies of a production cut-off for the CAEP/6 NOx standards in FESG and MODTF (CAEP-SG/20082_SD/4). These st udies would focus on the analysis of costs and benefits of a CAEP/6 NOx production cut-off. We look forward to seeing the results of the studies.

2.2 The table below gives a synopsis of th e timing of the CAEP emission standards.

NOx Standard Year Adopted Effective Year Lead time Years (Adoption to Effective) Phase-In Years (Effective Year to Production Cut-Off)CAEP-SG/20093-WP/39 - 3 -

CAEE (baseline – all pollutants) 1981 1986 (all) 5 0

CAEP/2 NOx (20% red) 1992 1996 (newly certified) 2000 (previously certified) 4 4

CAEP/4 NOx (16% red) 1998 2004 (newly certified only) 6 n/a (7)*

CAEP/6 NOx (12% red) 2004 2008 (newly certified only) 4 n/a (3)*



### * Based on manufacturer assertions that they will fully comply by the end of 2010.

2.3 In 1981, the predecessor to CAEP, the Co mmittee on Aircraft Engine Emissions (CAEE), adopted emission standards (including NOx standards) that included a production cut-off, which became effective in 1986. At CAEP/2 in 1992, new NOx sta ndards were adopted with different implementation dates for newly certified (newly designed) engines and newly manufactured (or previously certified) engines: 1996 for newly certified engines and 2000 for newly manufactured engines. Consequently, the CAEP/2 standards had a production cut-off date 4 year s after the implementation date for newly certified engines, and 8 years after the standards were adopted.

2.4 For the first time at CAEP/4 in 1998, new NOx standards were adopted without a production cut-off. At the time, CAEP noted the indust ry view that market forces are the primary drivers of the development and incorporati on of new technology, and thus generally noted that in most cases reliance on these drivers (an indirect form of volunta ry compliance) should suffice. Again at CAEP/6, production cut-off provisions were not included with the more stringent NOx standard. It appears that the accommodation made at CAEP/4 for just a few engine models grew much larger in CAEP/6 since about twice as many production models were not in co mpliance with CAEP/6 NOx standard when adopted. This action was taken without examining the merits of retaining the production cut-off provision applied in CAEE and CAEP/2. Also, in 2004, CAEP/6 indicat ed that there was an understanding at CAEP/4 that a production cut-off would not be introduced in the future. CAEP/6, after reviewing the commitment, decided that “... this should not be interpreted as meaning that production cut-offs would not be introduced in the future if the s ituation so warranted” (CAEP/6 Repor t, Letter of Transmittal to the President of the Council from the Chairman of th e Sixth Meeting of CAEP, CAEP/6-WP/57, Report on Agenda Item 1).

2.5 When the CAEP/4 NOx standard was adopted, CAEP/4-WP/4 – Economic Assessment of the EPG NOx Stringency Proposal (March 1998) – indicated that about 8 engine families or 17 percent of the engine models did not meet the standa rd. CAEP-SG20022-WP/20 from September 12, 2002, FESG Economic Assessment of Applying a Producti on Cut-Off to the CAEP/4 NOx Standard , showed that at that time two in-production engine families (about six engines) did not comply with the CAEP/4 NOx standard. When CAEP/6 was adopted in 2004, approxi mately 30-40% of in-production engines did not meet the new standard (CAEP/6-IP13 – Economic Analysis of NOx Emissions Stringency Options – February 2004). When the CAEP/6 standards took e ffect in January 2008, about 20% of in-production models were not in compliance, and one year later, about 18% of in-production models were still not in compliance (These results are according to versions of the ICAO Engines Emissions Databank at theCAEP-SG/20093-WP/39 - 4 -

time. The Databank is not a living document, but it is subject to periodic updates. Thus, the Databank may not be as up to date as the later engine plans and status reports from FESG). Discussions with the manufacturers and information in CAEP SG/ 20082 WP6 (and earlier in CAEP/7-IP02 – Report of the FESG Industry Response Task Group – February 2007) indicated plans either to bring many of these remaining models into compliance or, perhaps, to drop them from production by 2010. At the Working Group 3 meeting in London, England, April 1-3, 2009, ICCAIA presented a flimsy in response to the U.S. EPA working paper on a production cut-off ( Response to U.S. EPA Papers 14 and 16) , stating that “[f]or CAEP/6 ICCAIA can state with confidence that it is highly likely that all commercial engines in production by the end of 2010 will meet CAEP/6 NOx standards.”

2.6 Some may suggest that a production cut-off for the previous standards should be considered only after market forces have been allowe d to act. While we recognize the value of market forces, we believe there is enough experience wi th CAEP/2, CAEP/4, and CAEP/6 to show that production cut-off periods such as those described above can provide adequate time for engine manufacturers to assess and respond to market demands and can provide a very reasonable phase-out period, similar to that provided to other sectors with similar sales volumes. In addition, establishing the production cut-off prospectively permits for certainty for both engine manufacturers and their customers and is a balanced approach which helps to ensure th e environmental gain intende d by the new standards. Furthermore, the development and adop tion of flexibility provisions within 

### Annex 16, Volume II and within the Environmental Technical Manual (ETM) will ensure that special circumstances can be addressed in a consistent way to allow for the continued production of a limited number of noncompliant in-production engines.

2.7 As described in CAEP-SG/20071-WP/26, it has been suggested by some in the past that applying a production cut-off will affect the asset valu e of existing in-use aircraft (also mentioned as a possibility in CAEP/6-IP/13). This effect on asset valu e could occur, for example, if a future operational requirement prevents the use of aircraft with engines th at do not meet the latest standards or if it were to affect the resale value of an aircraft. Specifically , in the past, the air tran sport industry has expressed concern that individual states or countries may seek to apply local restrictions at their airports, potentially restricting operations of aircraft with engines not me eting the latest emission standards. A production cutoff for future emission standards would basically be structured as it was for CAEP/2. It would not contain any use restrictions on existing aircraft wi th noncompliant (previously certified) engines, nor would it otherwise regulate engines that have been ma nufactured and actually placed in service before the effective date of the requirement. Furthermore, flex ibility provisions should be developed and adopted to address situations such as the use of spare or replacement engines.

2.8 In domestic U.S. programs, for all mobile source sectors (except aircraft), manufacturers must recertify their product lines each year, thus creating some form of a production cut-off on the first year of a new emission standard. To accommod ate reasonable business practice, the U.S. EPA incorporates various provisions to ensure an orde rly product phase-in and phase-out, etc., but in no case are previously certified engine models allowed to be produced indefinitely into the future. Such provisions are very workable in other sectors, and ha ve been used at times in the aviation sector. As discussed in CAEP-SG/20071-WP/26, ultimately, for th e U.S. and the nations of many participating CAEP members, the aviation sector stands as the only s ource that is currently allowed to indefinitely produce existing engines that do not meet the late st emission standards (based on the last two NOx standards for aircraft engines). Given appropriate flexibilities, nothing precludes returning to the past practice of establishing a production cut-off as new ICAO emission standards are put in place. The need for transition flexibility in the implementation date for a new standard can be met through a phase-in period as was done in CAEP/2, as well as through fl exibilities such as the low- volume exemptions mentioned above.CAEP-SG/20093-WP/39 - 5 -

3. CAEP/6 NOX EMISSION STANDARD PRODUCTION CUT-OFF

3.1 Based on the discussion in paragraph 2.5 and recent queries we have completed from the Ascend Online Fleets database on the build date and deliver ies/orders of new aircraft and their engines, it appears that for CAEP/4 NOx standards it took industry about 2 to 4 years after the implementation date for newly certified engines to almost fully adjust to the market demand for CAEP/4-compliant engines (a few engine models not meeting CAEP/ 4 will be produced until the end of 2010, which is seven years after the implementation date). In addition, for CAEP/6 NOx standards, paragraph 2.5 – particularly the statement from the ICCAIA flimsy – and informat ion from the Ascend Online Fleets database make it clear that within three years after the implementation date of newly certified engines, industry will have completely responded to the market demand for CAEP/ 6-compliant engines. (See Table 1 in Appendix A for information from the Ascend Online Fleets datab ase.) Given these circumstances, a production cutoff of December 31, 2010, for CAEP/6 NOx standards would appropriately codify current practice into Annex 16, Volume II. In addition, a production cut-off should be accompanied by provisions that ensure that existing emission test data for previously certifie d engine models, which comply with a cut-off, still apply and are valid for demonstrating compliance afte r a cut-off (e.g., for engine models meeting the CAEP/6 NOx emission standards certification test da ta from 2009 or earlier would still be valid for compliant engine models after a CAEP/6 production cut-off of December 31, 2010).

3.2 While it appears that market forces have driven the implementation of new technology to a large but not complete extent, as declared in the above referenced ICCAIA flimsy and as stated in CAEP-SG/20071-WP/26 dated November 23, 2007 ( Production Cut-Off for Engine NOx Standards

, presented by U.S. Representative), it still holds true that applying a production cut-off ensures progress in reducing aircraft engine NOx emis sions. While plans are in place, as of mid-2009, not all production models meet the CAEP/6 NOx emission standards. Allowing current production engine models to continue to meet only previous standards in the future lessens the benefit from the latest standards, as this would not prohibit the continued, indefinite manufactu re of already-certified engines that do not comply with the latest standards, and possibly do not even comply with the last two rounds of CAEP standards. Such a situation is difficult to reconcile with the CAEP expectati on that technology improvement is necessary and appropriate, and would reinforce market forces to ensure that the CAEP standard-setting process achieves its full potential in emission benef its. Implementing a CAEP/6 NOx emission standard production cut-off for December 31, 2010, captures the past technology gains in new production as envisioned in the CAEP standards setting process (rel ying on a high technology readiness level) and sets the stage for decisions on the CAEP/8 NOx emission standards.

4. FLEXIBILITIES: EXEMPTION PROVISIONS

4.1 In the past, CAEP has evaluated production cut-offs by analyzing a few noncompliant engines and the cost and emission reductions associ ated with these engines (for example, see CAEPSG20022-WP/20 from September 12, 2002, FESG Economic Assessment of Applying a Production CutOff to the CAEP/4 NOx Standard ). It is not reasonable to assess a few engines on the margin in such a manner when designing the basic structure of requireme nts for an entire sector. Based on past experience with U.S. environmental regulations, the appropria te way to accommodate a few noncompliant engines when establishing new standards for a sector is to prov ide flexibilities to provide for an orderly transition, such as by applying the exemption provisions describ ed later in this section or in CAEP8-WG3-WP6-16, Revision of Exemption Provisions . Exemption provisions should provide flexibility to manufacturers for a few noncompliant engines without undermining the stru cture of the entire program or the effectiveness of the standards themselves. The current CAEP practice of allowing indefinite production ofCAEP-SG/20093-WP/39 - 6 -

noncompliant aircraft engines is not reasonable when considering that flexibilities such as exemption provisions have been proven to work for all other sectors.

4.2 Therefore, for manufacturers who may poten tially need some additional flexibility in meeting a production cut-off, criteria should be establi shed that would permit for evaluating on a case-bycase basis temporary relief for a low-volume production of engines not compliant with the latest standards, under certain terms a nd conditions. Toward that end, CAEP Working Group 3 has taken on the task to review the Annex 16, Volume II language on exemptions and to develop text to add to the ETM (See paragraph 3.3 from CAEP-SG/20093-WP/18). Exem ption provisions should ensure that existing certification data for previously certified engines s till apply, are valid, and can be utilized to show compliance under these provisions. For further discu ssion of potential exemption provisions, see the working paper presented by the U.S. EPA at the Work ing Group 3 meeting in London, England, April 1- 3, 2009 (CAEP8-WG3-WP6-16) on revisions to the Annex 16 (Volume II) langua ge on exemptions and ETM.

4.3 Annex 16, Volume II applies to engines fitte d to aircraft engaged in international civil aviation and it is inherent that the Volume II provi sions do not apply to engines intended for use in powering military aircraft. Yet, there are cases wh ere aircraft engines that have undergone civil certification are subsequently also utilized on military airc raft. In addition, since military aircraft may last several decades, States’ militaries tend to want to be able to purchase engines for these aircraft over a similar period time, thus subjecting the purchasing process to the possibility that engines of a wide variation in technology are required. Thus, in some cases, civil certif icated engines (including those previously certified) utilized in military applicatio ns may not meet the existing or future CAEP NOx emission standards. For the purposes of any State’s nati onal security interests, we believe that Volume II needs to explicitly exclude engines intended for mili tary application from any production cut-off. If a production cut-off is adopted, provisions should be added to Volume II that state the following: “a production cut-off shall not apply to individually manufactured engines that have undergone a civil certification in accordance with the provisions of Annex 16, Volume II, that are intended for use on military aircraft.” However, this does not mean that the same engines utilized in commercial applications would be able to avoid meeting any production cut-off.

5. PRODUCTION CUT-OFFS FOR FUTURE EMISSION STANDARDS

5.1 CAEP/8 is now considering more stringent NOx emission standards for future engines. We request that CAEP consider and assess a production cut-off for the potential CAEP/8 NOx emission standards during CAEP/9. Stringency decisions have not been made and analyses are not yet complete. Further stringency options ranging from 5% to 20% increased stringency relative to CAEP/6 are being considered for the 2013-2017 timeframe. At this point, the analysis underway does not include assessment of the potential effects of a production cut- off. Figures 1 and 2 of Appendix A to this paper show the effect of potential new standards on each of the six engine manufacturers for the engines that they say will be produced in the era when CAEP/ 8 NOx emission standards would apply – including additional options for large engines of 11%, 12%, 13 %, and 14% further stringency, which we thought were useful to analyze. Depending on the slope of the pressure ratio vs. Dp/Foo line in each option, the 11-14% options may affect more, less, or the same number of engines as the 10% and 15% options. Utilizing the Ascend Online Fleets database (orders), Tables 2 through 5 show the potential number of engines effected by the 10% and 15% options with a sl ope of 2 (pressure ratio greater than 30) for large engines and the 10%/10% and 15%/15% options for th e small engines for a 2013 or later implementation date. If there was a production cut-off for these options 3 to 4 years after the implementation date, TablesCAEP-SG/20093-WP/39 - 7 -

2-5 show the potential number of engines impacted by such a production cut-off. If the implementation date for newly certified engines was 2013, and there w as an end of 2017 production cut-off, based on this information, a limited number of engines would be aff ected. This is mostly illustrative, since we would expect that most of these potentially affected mo dels would respond to th e CAEP/8 requirements as indicated by the manufacturers in CAEP-SG/20082-WP18. Nevertheless, as discussed earlier, the appropriate way to accommodate a limited number of engines not meeting the potential CAEP/8 NOx emission standards by a cut-off date is by utilizi ng flexibilities in the form of exemption provisions.

5.2 To help CAEP succeed in accomplishing its e nvironmental objectives, we need to be sure that its future emission standards achieve the reductions expected at the time they are adopted, that future production engines adopt the best commercially av ailable proven technologies across the design range as intended by CAEP, and that the new emission requi rements do not include provisions that undermine these objectives. Also, we need to assure the public that they are receiving the environmental benefits from the standards (and in the U.S., that states ar e obtaining the creditable aircraft engine emission reductions needed to attain the national ambient air quality standards). A production cut-off will help to meet these objectives.

5.3 Furthermore, we understand that manufactur ers desire adequate time to recoup their investment for recent certifications (e.g., noncompliant engines certified within a few years prior to the latest standard’s effective date for newly certified e ngines), to assess which engines should be modified to meet new standards, and to bring those engines into compliance. As discussed in paragraphs 2.2-2.4, based upon past experience with CAEP/4 and CAEP/ 6 NOx standards (and even CAEP/2 standards, which had a production cut-off), the time for a productio n cut-off could be three to four years after the implementation date for newly certified engines (or sev en to eight years from adoption of a standard – whichever occurs first). This is c onsistent with the manufacturers’ inte rest in relying on market forces since it is based on experience over three CA EP cycles as illustrated in the table above.

5.4 A production cut-off is an important part of an appropriate regulatory construct in general and specifically since CAEP sets standards based on a high technology readiness level rather than on a technology forcing concept. It is needed as a back stop for the CAEP process for standards setting to be certain that future CAEP emission standards achieve their expected environmental objectives, Therefore, within a reasonable period of time after standards become effective for newly certified engines, we support consideration of a production cut-off (not only for NOx standards, but for all pollutants – including any potential future greenhouse gas and/or particulate matter standards). Going forward from this time, a production cut-off provision should be evaluated with each new emission standard. A production cut-off should be considered in the next CAEP meeting after the standard is adopted and should give a phase-out period after a new standard becomes effective to provide for an adequate opportunity for manufacturers to bring currently certified engines into compliance with the new standards. Moreover, CAEP needs to formally incorporate the practice of establishing production cut-offs for new standards in the CAEP cycle following the adoption of these new standards. This action would ensure that production cut-offs accompany new standards at some point after they have been adopted. If there is not a current mechanism to codify this practice in CAEP proceedings, then ICAO or CAEP needs to create such a mechanism. Therefore, the only item that CAEP would need to consider on a production cut-off (for future new emission standards) at s ubsequent CAEP meetings -- after new CAEP standards are adopted -- is the timing of a production cut-off, and not whether there should be a production cut-off.

6. ACTION BY THE CAEP-SG

6.1 The CAEP-SG is invited to:CAEP-SG/20093-WP/39 - 8 -

a) recommend, at CAEP/8, a production cut-off for CAEP/6 NOx standards of December 31, 2010, taking into account f actors such as statements of compliance from the engine manufacturers, informat ion from databases such as the Ascend Online Fleets database, cost, and the funda mental need to ensure full compliance with a standard within a finite timeframe;

b) during the CAEP/9 cycle, assess and consider a production cut-off for the CAEP/8 NOx standard stringency incr ease (e.g., consider a CAEP/8 NOx emission standard production cut-off of 3 to 4 years after the implementation date for newly certified engines, or 7 to 8 years after CAEP/8, starting January 1 of the relevant calendar year – whichever occurs first). This decision should be based on factors such as the current st ate of compliance within the industry, information from databases such as th e Ascend Online Fleets database with regard to the utility of current exempti on provisions, cost, the fundamental need to ensure full compliance with a standard within a finite timeframe, and other relevant technical and policy information;

c) during the CAEP/8 cycle, support the continued work of Working Group 3 to develop production cut-off-associated fl exibilities in the form of exemption provisions (which would apply to a potential production cut-off for CAEP/6 NOx standards and any production cut-offs for new standards in the future);

d) recommend, at CAEP/8, that if a production cut-off is adopted for CAEP/6 NOx standards, provisions should be added to Annex 16, Volume II that state the following: “a production cut-off shall not apply to individually manufactured engines that have undergone a civil certification in accordance with the provisions of Annex 16, Volume II, that are intended for use on military aircraft;” and these provisions would apply to all future production cut-offs as well;

e) in the future, plan that production cu t-offs and their associated flexibilities be considered for inclusion as part of all ICAO emission standard-setting requirements, including any potential fu ture greenhouse gas and/or particulate matter standards. Consider factors such as those listed in recommendation b) above; and

f) formally incorporate the practice of considering establishing production cut-offs for new standards in the CAEP cycle following the adoption of these new standards. This action would ensure that production cut-offs accompany new standards at some point after they have been adopted.

— — — — — — — —CAEP-SG/20093-WP/39 Appendix

APPENDIX

Table 1

Review of Deliveries and Orders for In-Production Engines that Do Not Meet CAEP/4 and CAEP/6 NOx Standards

World Fleet Engine (CAEP/4 non-compliant) 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

PW4168A 20 6 14 14 PW4077 2 PW 4084 4 2 PW 4090 2 8 10 12 6 2 4 PW4168A 2 6 8 6 18 PW 4062 12 10 8 2 4 4 Engine (CAEP/6 non-compliant) RB Tay 611-8C 12 50 64 52 48 30 28 6 2 2 4

V2530-A5 8 8 V2533-A5 48 16 24 52 58 GE90-94B 26 10 10 8 2 2 Number of Aircraft Engines Delivered (or expected to be delivered/ordered)*

* would exceed a four year production cut-off from the CAEP/6 standard * would exceed a four year production cut-off from the CAEP/4 standard

(Source: Ascend Online Fleets Database as of April 2009)

Note: Discussions with the manufacturers and in formation in CAEP SG/20082 WP6 (and earlier in CAEP/7-IP02 – Report of the FESG Industry Response Task Group – February 2007) indicated plans to either bring many of these remaining models into compliance or perhaps to drop them from production by 2010. Thus, we understand that after 2008 most engi nes in the table that do not meet CAEP/4 or CAEP/6 NOx standards will have engine upgrades to enable them to meet these standards.CAEP-SG/20093-WP/39 Appendix A-2



### Figure 1

Large Engines That Will Respond to CAEP/ 8 NOx Standard and Do Not Meet CAEP/8 Further Stringency Options – Including Additi onal Options of 11%, 12%, 13%, and 14% Further Stringency (Based on Data in Appendix E of CAEP-SG/20082-WP18)

Noncomplying Engine Families by Manufacturer per CAEP/8 Option - Large Engines

0 5 10 15 20 25 30 35 40

C A EP/6

1 (

-5 % and 2 for OP R >30)

2

(-1

0%

and 2.

2 f or

OP

R>30)

3

(-10% and 2 for OPR>30)

3 a (- 11

% and 2 .2 for OP

R>30)

3 b (-11% an d 2 for OPR>30)

3c

(-12% a nd 2. 2 f o r OP

R>

30)

3 d

(- 12

% and 2 for O P R>

30)

3 e (- 13

% and 2 .2 for OP

R>30)

3f (

- 13% and 2 f or

OP

R >30

)

3g

(- 14

%

and 2 . 2 f or

OPR >3

0)

3 h (-14% and 2 for OPR>30) 4 (-15% an d 2.2 for OP

R >30)

5

(-1

5%

and

2

for

OPR >30)

6

(-2

0%

and 2. 2 for OP

R>30)

CAEP/8 OptionNumber of Engines Int'l Aero (7) RR (7) PW (9) EA (2) CFM (15) GE (25)

Note: Appendix E of CAEP-SG/20082-WP18 has a column labeled, Respond to CAEP/8 NOx standard?

, and where there was a “No” in this column, the e ngine model was not included in Figure 1. (For example, for option 1, the column labeled, percent to Option 1 NOx limit , includes 16 engines that do not meet option 1 (text with red font), but since 8 of these engines will not respond to the CAEP/8 NOx standard, only those 8 remaining engines that will respond to the CAEP/8 NOx st andard were shown in Figure 1 for this option.)

Note: The parenthetical for each manufacture in the legend of Figure 1 indicates the total number of engines that will respond to the CAEP/8 NOx standard, but not the number of engines that do not meet a stringency option. The bars show the number of engines that do not meet a stringency option.A-3 CAEP-SG/20093-WP/39 Appendix



### Figure 2

Small Engines That Will Respond to CAEP/8 NOx Standard and Do Not Meet CAEP/8 Further Stringency Options (Based on Data in Appendix E of CAEP-SG/20082-WP18)

Noncomplying Engine Families by Manufact urer per CAEP/8 Option - Small Engines

0 1 2 3 4 5 6 7 8 9

1 (-5/-5) 2 (-5/-15) 3 (-10/-10) 4 (-10 /-20) 5 (-15/-15) 6 (-15/-20) 7 (-20/-20) CAEP/8 OptionNumber of Engines CFM (1) PW (3) GE (14) BMW/RR (2) Honeywell (1) Allison (6)

Note: Appendix E of CAEP-SG/20082-WP18 has a column labeled, Respond to CAEP/8 NOx standard?

, and where there was a “No” in this column, the e ngine model was not included in Figure 2. (For example, for option 1, the column labeled, % to Option 1 NOx limit , includes 2 engines that do not meet option 1 (text with red font), but since 1 of these engines will not respond to the CAEP/8 NOx standard, only the 1 remaining engine that will respond to the CA EP/8 NOx standard was shown in Figure 2 for this option.)

Note: The parenthetical for each manufacture in the legend of Figure 2 indicates the total number of engines that will respond to the CAEP/8 NOx standard, but not the number of engines that do not meet a stringency option. The bars show the number of engines that do not meet a stringency option.CAEP-SG/20093-WP/39 Appendix A-4



### Table 2

Number of Large Engines on Order from 2012-2018 That Do Not Meet 10% CAEP/8 Further Stringency Option

Number of Large Engines on Order not in Complia nce with CAEP/8 Option 3 (-10% and 2 for OPR>30) Manufacturer Engine 2012 2013 2014 2015 2016 2017 2018 GE CF6-80E1A2 6 2 GE CF6-80E1A3 26 14 6 10 GE CF6-80E1A4 16 8 GE 90GE-115B/115BL 90 50 42 42 14 10 2 GE GE90-90B 4 Int'l Aero V2524-A5 46 38 20 12 10 18 Int'l Aero V2527-A5 292 242 194 122 104 48 36 Int'l Aero V2527E-A5 20 22 Int'l Aero V2527M-A5 18 18 10 12 10 12 Int'l Aero V2533-A5 68 22 18 20 20 8 PW PW4062 4 4 RR Trent 772 116 54 16 10 10 2 (Source: Ascend Online Fleets Database as of April 2009)



### Table 3

Number of Large Engines on Order from 2012-2018 That Do Not Meet 15% CAEP/8 Further Stringency Option

Number of Large Engines on Order not in Complia nce with CAEP/8 Option 5 (-15% and 2 for OPR>30) Manufacturer Engine 2012 2013 2014 2015 2016 2017 2018 EA GP7270 80 76 48 8 GE CF6-80E1A2 6 2 GE CF6-80E1A3 26 14 6 10 GE CF6-80E1A4 16 8 GE 90GE-110B1/110B1L 30 28 28 26 22 18 6 GE 90GE-115B/115BL 90 50 42 42 14 10 2 GE GE90-90B 4 GE GE90-94B 4 Int'l Aero V2524-A5 46 38 20 12 10 18 Int'l Aero V2527-A5 292 242 194 122 104 48 36 Int'l Aero V2527E-A5 20 22 Int'l Aero V2527M-A5 18 18 10 12 10 12 Int'l Aero V2533-A5 68 22 18 20 20 8 PW PW4062 4 4 RR Trent 772 116 54 16 10 10 2 (Source: Ascend Online Fleets Database as of April 2009)A-5 CAEP-SG/20093-WP/39 Appendix



### Table 4

Number of Small Engines on Order from 2012-2018 That Do Not Meet 10%/10% CAEP/8 Further Stringency Option

Number of Small Engines on Order not in Compliance with CAEP/8 Option 3 (-10/-10) Manufacturer Engine 2012 2013 2014 2015 2016 2017 2018 Honeywell HTF 7000-7000 40 10 16 PW PW306 A 18 16 16 20 (Source: Ascend Online Fleets Database as of April 2009)



### Table 5

Number of Small Engines on Order from 2012-2018 That Do Not Meet 15%/15% CAEP/8 Further Stringency Option

Number of Small Engines on Order not in Compliance with CAEP/8 Option 5 (-15/-15) Manufacturer Engine 2012 2013 2014 2015 2016 2017 2018 Honeywell HTF 7000-7000 40 10 16 PW PW306A 18 16 16 20 RR BR700-710C4-11 14 14 12 12 8 (Source: Ascend Online Fleets Database as of April 2009)

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