(13 pages) 

 CAEPSG.20093.WP.039.6.en.doc

 COMMITTEE ON AVIATION ENVIRONMENTAL 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 for emission standards will confirm that 

CAEP is serious about providing meaningful emission reductions from all 

production aircraft engine models within 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 CAEP/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 readiness 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 standards and production cut-offs were 

unbalanced in the sense that the stringency of the standards was based on 

application of technology of a high readiness level, but there were no 

provisions ultimately requiring that all current production engine models 

eventually adopt such technology. Based on discussions at CAEP Working 

Group 3, manufacturers now state that all 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 asking 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 which the standards were set. 

International Civil Aviation Organization

WORKING PAPER 

CAEP-SG/20093-WP/39 

8/6/09
CAEP-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 latest 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 all 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 provide 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 are 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, specific flexibilities for the engine manufacturers should also 

be established that could, under certain circumstances, 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 NOx emission standards. Furthermore, because a production 

cut-off is such a fundamental element of any standard, we recommend that production cut-offs be fully 

assessed and adopted for all future ICAO emissions standards. This should begin with the CAEP/8 NOx

emission standard. We also recommend that CAEP 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 studies 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 the 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) 
- 3 - CAEP-SG/20093-WP/39 

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 Committee 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 standards 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 years 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 industry view that market forces are the primary drivers 

of the development and incorporation of new technology, and thus generally noted that in most cases 

reliance on these drivers (an indirect form of voluntary 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 compliance 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 indicated 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 situation so warranted” (CAEP/6 Report, Letter of Transmittal to the 

President of the Council from the Chairman of the 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 standard. CAEP-SG20022-WP/20 from September 12, 2002, FESG 

Economic Assessment of Applying a Production 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, approximately 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 effect 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 the 
CAEP-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 allowed to act. While we recognize the value of market 

forces, we believe there is enough experience with 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 the environmental gain intended by the new standards. 

Furthermore, the development and adoption 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 value of existing in-use aircraft (also mentioned as a 

possibility in CAEP/6-IP/13). This effect on asset value could occur, for example, if a future operational 

requirement prevents the use of aircraft with engines that do not meet the latest standards or if it were to 

affect the resale value of an aircraft. Specifically, in the past, the air transport 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 meeting 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 with noncompliant (previously certified) engines, nor 

would it otherwise regulate engines that have been manufactured and actually placed in service before the 

effective date of the requirement. Furthermore, flexibility 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 accommodate reasonable business practice, the U.S. EPA 

incorporates various provisions to ensure an orderly 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 have been used at times in the aviation sector. As 

discussed in CAEP-SG/20071-WP/26, ultimately, for the U.S. and the nations of many participating 

CAEP members, the aviation sector stands as the only source that is currently allowed to indefinitely 

produce existing engines that do not meet the latest 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 flexibilities such as the low- volume exemptions 

mentioned above. 
- 5 - CAEP-SG/20093-WP/39 

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 deliveries/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 information 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 database.) 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 certified engine models, which comply with a cut-off, still 

apply and are valid for demonstrating compliance after a cut-off (e.g., for engine models meeting the 

CAEP/6 NOx emission standards certification test data 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 emissions. 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 manufacture 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 expectation 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 benefits. 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 (relying 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 associated 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 requirements for an entire sector. Based on past experience 

with U.S. environmental regulations, the appropriate way to accommodate a few noncompliant engines 

when establishing new standards for a sector is to provide flexibilities to provide for an orderly transition, 

such as by applying the exemption provisions described 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 structure of the entire program or the effectiveness 

of the standards themselves. The current CAEP practice of allowing indefinite production of 
CAEP-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 potentially need some additional flexibility in 

meeting a production cut-off, criteria should be established 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 and 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). Exemption provisions should ensure that existing 

certification data for previously certified engines still apply, are valid, and can be utilized to show 

compliance under these provisions. For further discussion of potential exemption provisions, see the 

working paper presented by the U.S. EPA at the Working Group 3 meeting in London, England, April 1-

3, 2009 (CAEP8-WG3-WP6-16) on revisions to the Annex 16 (Volume II) language on exemptions and 

ETM. 

4.3 Annex 16, Volume II applies to engines fitted to aircraft engaged in international civil 

aviation and it is inherent that the Volume II provisions do not apply to engines intended for use in 

powering military aircraft. Yet, there are cases where aircraft engines that have undergone civil 

certification are subsequently also utilized on military aircraft. 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 certificated engines (including those 

previously certified) utilized in military applications may not meet the existing or future CAEP NOx 

emission standards. For the purposes of any State’s national security interests, we believe that Volume II 

needs to explicitly exclude engines intended for military 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 slope of 2 (pressure ratio greater than 30) for large 

engines and the 10%/10% and 15%/15% options for the 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, Tables 
- 7 - CAEP-SG/20093-WP/39 

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 was an end of 2017 production cut-off, based on this 

information, a limited number of engines would be affected. This is mostly illustrative, since we would 

expect that most of these potentially affected models would respond to the 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 utilizing flexibilities in the form of exemption provisions. 

5.2 To help CAEP succeed in accomplishing its environmental 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 available proven technologies across the design range as 

intended by CAEP, and that the new emission requirements 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 are 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 manufacturers 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 engines), 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 production cut-off could be three to four years after the 

implementation date for newly certified engines (or seven to eight years from adoption of a standard – 

whichever occurs first). This is consistent with the manufacturers’ interest in relying on market forces 

since it is based on experience over three CAEP 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 backstop 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 subsequent 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 factors such as statements of compliance 

from the engine manufacturers, information from databases such as the Ascend 

Online Fleets database, cost, and the fundamental 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 increase (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 state of compliance within the industry, 

information from databases such as the Ascend Online Fleets database with 

regard to the utility of current exemption 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 flexibilities 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 cut-offs and their associated flexibilities be 

considered for inclusion as part of all ICAO emission standard-setting 

requirements, including any potential future 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 information 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 engines 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 Additional 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

CAEP/6

1 (-5% and 2 for OPR>30)

2 (-10% and 2.2 for OPR>30)

3 (-10% and 2 for OPR>30)

3a (-11% and 2.2 for OPR>30)

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

3c (-12% and 2.2 for OPR>30)

3d (-12% and 2 for OPR>30)

3e (-13% and 2.2 for OPR>30)

3f (-13% and 2 for OPR>30)

3g (-14% and 2.2 for OPR>30)

3h (-14% and 2 for OPR>30)

4 (-15% and 2.2 for OPR>30)

5 (-15% and 2 for OPR>30)

6 (-20% and 2.2 for OPR>30)

CAEP/8 Option

Number 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 engine 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 standard 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 Manufacturer 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 Option

Number 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 engine 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 CAEP/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 Compliance 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 Compliance 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 PW306A 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) 

— END —