UNITED STATES ENVIRONMENTAL PROTECTION AGENCY National Vehicle and Fuel Emissions Laboratory

2 000 Traverwood Drive Ann Arbor, Michigan 48105

- 2498

March 27

, 2012

MEMORANDUM

SUBJECT: D iscussion with Pratt & Whitney USA Regarding the Leadtime Associated the

Proposed Aircraft Engine Tier 6 NOx Production Cutoff

— December 1 9 , 2011

FROM: Richard S. Wilcox , Environmental Scientist

Assessment and Standards Division Office of Transportation and Air Quality U.S. Environmental Protection Agency

TO: The Air and Radiation Docket

Docket No. EPA

- HQ

- OAR

- 2010

- 0687

This documents a discussion we had on December 19, 2011 with representatives of Pratt
& Whitney USA (P&W) to clarify a public comment they submitted on our Notice of Proposed Rulemaking for new aircraft engine NOx emission standards and other requirements (July 27, 2011, 76 FR 45012). 1 Specifically, P & W expressed a concern that there may be inadequate
leadtime for the EPA and the Federal Avia tion Authority ( FAA ) to establish and review exemption requests by the January 1, 2013 date of the proposed Tier 6 production cutoff for engines that were originall y certified to the Tier 4 standards

. They suggested that a small number
of automatic low

- volume exemptions be included in the final rule to prevent any potential interruption in engine production.

Attending the call for EPA were Mike Samulski, Glenn Pass avant, John Mueller, and myself. Attending for P & W were Alan Epstein, Domingo Sepulveda, Larry Jones, Matthew Stoner, Maher Awkal, and Ro ger Martella. P & W indicated a continuing concern regarding the availability of a limited number of exemptions prior to the proposed production cutoff date of January 1, 201 3

.

1 U.S. EPA, “Summary and Analysis of Comments: Control of Air Pollution from Aircraft and Aircraft Engines,” Office of Transportation and Air Quality, EPA

- 420

- R

- 12

- 011

. A copy of this docum ent is in docket number EPA

HQ

- OAR

- 2010

- 0687.Specifically, P&W ha s two engine models that are both at the end of their production

liv e s , i.e., 4 engines of one model and two engines of another model , that were sold years ago
with contracted delivery dates that would be adversely affected by the production cutoff as proposed.

They noted that the first model with four engines already had been modified to comply
with the Tier 6 standards. However, they also noted that testing and certification by the FAA would take several months, well beyond the January 1, 2013 cutoff date. These engines have

contract deliver y dates beginning in January 2013

. The other model consisting of two engines

w as certificated to the Tier 4 standards and P&W indicated t hat it was not feasible to modify th at model to be Tier 6 compliant. These engines have contract delivery dates in the May 2013
timeframe. P ratt and Whitney claimed that any delay in shipping any of these engines would represent a significant adverse econ omic effect for the company , the aircraft manufacturer

, and
the airline customers

. All of the engines apparently would be delivered to foreign airlines.

We discussed P&W’s idea regarding automatic low

- production exemptions for these six engines. They expressed a desire that at least the four engines ,which were expected to comply
with the Tier 6 standards

, not be labeled as “Exempt New” because that could devalue the engines in the secondary market. We acknowledged that granting exemptions using the

t raditional approach based on a petition for relief from the manufacturer was questionable

. As an
alternative to P&W’s propos ed solution , w e also discussed the possibility and ramifications of delaying the implementation date of the requirement for several months.