SUPPORTING STATEMENT

AIRCRAFT ENGINES — SUPPLEMENTAL INFORMATION RELATED 

TO EXHAUST EMISSIONS 

PROPOSED RULE

OMB Control No. 2060-NEW

EPA ICR No. 2427.01

January 2011
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SUPPORTING STATEMENT

FOR MANDATOR REPORTING OF GREENHOUSE GASES, PROPOSED RULE

EPA ICR No. 2427.01

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

TITLE: “Aircraft Emission Standards – Proposed Rule.”

OMB Control Number: 2060-NEW

1(b) Short Characterization/Abstract

The U.S. Environmental Protection Agency (EPA) is proposing a new set of emission 

standards for new aircraft engines. The proposed rule would require manufacturers to report 

production volumes, technical parameters, and emission information in addition to what is 

already required under the Greenhouse Gas Reporting Rule. 

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

Clean Air Act section 231 (42 U.S.C. 7571) authorizes EPA to adopt emission standards 

for aircraft engines. The Clean Air Act additionally provides broad authority for EPA to collect 

information related to the regulations we adopt for aircraft and other emission sources (42 U.S.C. 

7414(a)(1)). EPA is accordingly adopting a new set of emission standards for aircraft gas turbine 

engines and adding a requirement for manufacturers to submit information related to these 

standards.

2(b) Practical Utility/Users of the Data

EPA will use the data to verify compliance with emission standards and to better 

understand the characteristics of aircraft engines that are subject to emission standards. This 

information will be very helpful in future rulemakings as we continue to explore appropriate and 

achievable emission standards for aircraft engines. This will be especially useful in evaluating 

alternative approaches to specifying the transition to new standards. For example, we may want 

to specify a certain number of allowable exemptions for a transition period, or allow 

manufacturers to “earn” an allowance to produce higher-emitting engines for a time with 

emission credits, offsetting the higher emissions with other engines that have emission levels 

below what would otherwise be required.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA
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3(a) Nonduplication

The International Civil Aviation Organization maintains and “emissions databank” with 

much of the information that is the subject of the proposed reporting requirement. The ICAO 

databank is a useful tool for providing a general overview of the aircraft fleet, but it is not 

updated on a consistent basis, it contains a varying amount of voluntarily reported data from each 

manufacturer, and it does not specifically include information for every engine sub-model. It 

also does not contain information on smaller thrust category turbofans or turboprops, and 

contains no information on engine production volumes. We need this data to conduct accurate 

emission inventories and develop appropriate policy; therefore, the emissions databank is not 

necessarily the proper tool for us to use to inform our policy decisions, including future standardsetting actions. Furthermore, while the situation is unique here, in the context of the roles of 

EPA and FAA with regard to aircraft engine emission standards, it is consistent with EPA policy

and practice to ask for timely and reasonable reporting of emission certification testing and other 

information that is relevant to our emission standards. 

3(b) Public Notice Required Prior to Information Collection Request (ICR)

Submissions to OMB

As part of the Federal Register notice on the proposed regulation, EPA is also soliciting 

comments on this information collection and the estimates in this ICR. EPA will solicit 

comments on specific aspects of the proposed information collection.

In compliance with the Paperwork Reduction Act (44 USC 3501 et seq.), EPA submitted

this ICR for the proposed rule to the Office of Management and Budget (OMB) for review and 

approval. 

3(c) Consultations

In developing the proposed rule, EPA met with many of the manufacturers that would 

need to submit information under the new requirements. Discussions included the extent, form, 

and timing of the information submissions.

3(d) Effects of Less Frequent Collection

We are proposing to require annual reporting. This is consistent with the common 

practice of submitting the information to the ICAO Databank, and also with the requirement to 

submit greenhouse gas data. Much of the information will not change from year to year; we 

would expect that the new information would often be limited to the production volumes for the 

preceding year. Having the information updated every year will be most helpful for confirming, 

in a timely way, that manufacturers are properly complying with regulatory requirements. It will 

also help us to stay abreast of any developments in the characteristics of the aircraft engine 

industry. 
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3(e) General Guidelines

This collection of information is consistent with all OMB guidelines under 

5 CFR 1320.6. EPA’s proposal to allow a variety of electronic and hard copy formats for 

records allows flexibility for facilities to use a system that meets their needs and is consistent 

with other facility records maintenance practices, thereby minimizing the recordkeeping burden.

3(f) Confidentiality

In general, emission data collected under CAA sections 114 and 208 cannot be declared 

confidential business information (CBI). We would, however, generally consider manufacturers’ 

production volumes to be CBI and would accordingly protect this information in accordance 

with 40 CFR part 2. Although CBI determinations are usually made on a case-by-case basis, 

EPA has issued guidance on what constitutes emission data that cannot be considered CBI 

(56 FR 7042, February 21, 1991).

3(g) Sensitive Questions

This information collection does not ask any questions concerning sexual behavior or

attitudes, religious beliefs, or other matters usually considered private.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

The respondents in this proposed information collection include manufacturers of aircraft 

gas turbine engines.

4(a) Respondents/North American Industrial Classification Systems (NAICS) Codes

All of the expected respondents are manufacturers of new aircraft engines, which are 

represented by NAICS Code 336412.

4(b) Information Requested

Reporting Requirements

We are proposing to require the information listed below as applicable for each affected 

gas turbine engine sub-model in order to establish our own independent engine exhaust 

emissions database. We are seeking comment on the proposed data reporting elements.

• Company corporate name as listed on the engine type certificate;

• Calendar year for which reporting;

• Complete sub-model name (This will generally include the model name and the submodel identifier, but may also include an engine type certificate family identifier.)

• The type certificate number, as issued by the FAA (Specify if the sub-model also has a 

type certificate issued by a certificating authority other than the FAA);
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• Date of issue of type certificate and / or exemption, i.e. month and year;

• Emission standards to which the engine is certified, i.e. Annex 16, Volume II, edition 

number and publication date;

• If this is a derivative engine, identify the original certified engine model;

• Engine sub-model that received the original type certificate for the engine type 

certificate family;

• Production volume of the sub-model for the previous calendar year, or if zero, state that 

the engine model is not in production and list the date of manufacture (month and year) 

of the last engine produced;

• Regarding the above production volume report, specify (if known) the number of 

engines that are intended for use on new aircraft and the number intended for use as 

certified (non-exempt) spare engines on in-use aircraft;

• Reference pressure ratio;

• Combustor description (type of combustor where more than one type available on an 

engine);

• Engine maximum rated thrust output, in kilonewtons (kN) ) or watts (W) (depending 

on engine type);

• Unburned hydrocarbon (HC) mass (g) total (weighted) and over each segment of the 

Landing and Take-off Cycle (LTO), i.e. Take-off, Climb, Approach, Taxi / Ground Idle;1

• Unburned hydrocarbon characteristic level (i.e. mass of hydrocarbons over LTO cycle / 

Rated Thrust (Dp/Foo); 2

• Carbon monoxide (CO) mass (g) total (weighted) and over each segment of the entire 

Landing and Take-off Cycle (LTO) (i.e. Take-off, Climb, Approach, Taxi / Ground Idle);

• Carbon monoxide (CO) characteristic level (i.e. mass of CO over LTO cycle / Rated 

Thrust (Dp/Foo)) ;

• Nitrogen oxides (NOx) mass (g) total (weighted) and over each segment of the entire 

Landing and Take-off Cycle (LTO) (i.e. Take-off, Climb, Approach, Taxi / Ground Idle);

• Nitrogen oxides (NOx) characteristic level (i.e. mass of NOx over LTO cycle / Rated 

Thrust (Dp/Foo)). 

• Smoke number total and over each segment of the entire Landing and Take-off Cycle 

(LTO) (i.e. Take-off, Climb, Approach, Taxi / Ground Idle);

• Smoke number characteristic level; 

• Carbon dioxide (CO2) mass (g) total (weighted) and over each segment of the entire 

Landing and Take-off Cycle (LTO), i.e. Take-off, Climb, Approach, Taxi / Ground Idle;

• Number of tests run per sub-model;

• Number of engines tested per sub-model;

• Fuel flow (grams / second) total (weighted) and over each segment of the Landing and 

Take-off Cycle (LTO) (i.e. Take-off, Climb, Approach, Taxi / Ground Idle); and 

• Any additional remarks to the EPA.

The proposed annual report would be submitted for each calendar year in which a 

manufacturer produces any affected gas turbine engine. These reports would be due to EPA by

 

1 See Regulation Part 87-Control of Air Pollution from Aircraft and Aircraft 

Engines, Subpart E, §87.42 Certification report to EPA for definitions.

2 Dp/Foo : total gross emission of each gaseous pollutant (mass) / rated 

thrust (g/kN).
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February 28 of each year, starting with the 2014 calendar year. Where information provided for 

any previous year remains valid and complete, manufacturers may report your production figures 

and state that there are no changes instead of resubmitting the original information. To facilitate 

and standardize reporting, we expect to specify a particular format for this reporting in the form 

of a spreadsheet or database template that we provide to each manufacturer. Note that this 

annual report does not affect the existing regulatory requirements in § 87.64 to report CO2 and 

NOx emission data for purposes of greenhouse gas reporting. We are, however, clarifying those 

provisions to specify that CO2 reporting should be for individual modal values rather than a 

weighted composite value. Additionally, both the greenhouse gas reporting and this reporting 

will be incorporated into one submission in order to minimize the reporting burden to the 

manufacturer.

Recordkeeping Requirements

Manufacturers would not need to keep records other than copies of the information 

submitted to EPA. They would need to keep these records for at least three years.

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODS, AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA activities associated with the rule include creating a reporting template and 

answering manufacturers’ questions about how to complete the form. Once the reporting 

program is in place, EPA activities would include monitoring and verification of emission 

reports, further communication and outreach, and program evaluation.

5(b) Collection Methodology and Management

Manufacturers would submit data electronically. We will maintain records of these files 

and plan to post non-CBI data on our website. 

5(c) Small Entity Flexibility

One manufacturer, Williams International, is a small business under the criteria 

established by the Small Business Administration. The proposed information collection involves 

a minimal amount of additional effort, so we are not proposing any provisions to reduce the 

burden of sending or keeping this information.

5(d) Collection Schedule

We are proposing to require annual reporting. This is consistent with the common 

practice of submitting the information to the ICAO Databank, and also with the requirement to 

submit greenhouse gas data. Much of the information will not change from year to year; we 

would expect that the new information would often be limited to the production volumes for the 

preceding year. Having the information updated every year will be most helpful for confirming, 
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in a timely way, that manufacturers are properly complying with regulatory requirements. It will 

also help us to stay abreast of any developments in the characteristics of the aircraft engine 

industry.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section presents EPA’s estimates of the burden and costs to respondents associated 

with the activities described in Section 4 as well as the Federal burden hours and costs associated 

with the activities described in Section 5(a). EPA estimates that, over the three years covered by

this request, the total respondent burden associated with this reporting would average 60 hours 

per year and the cost to all respondents of the information collection would average $3646 per 

year.

Section 6(a) of this ICR provides estimates of burden hours for all respondent types.

Section 6(b) contains estimates of respondent costs for the information collection. Section 6(c) 

summarizes Federal burden and costs. Section 6(d) describes the respondent universe and the 

total burden and cost of this collection to respondents. Section 6(e) presents the bottom line 

burden and cost. The burden statement for this information collection is in Section 6(f). 

6(a) Estimating Respondent Burden

EPA estimates that the total annual burden to all affected entities would be 6 hours per

year over the three years covered by this information collection. EPA estimates that 10 

respondents will submit a report each year. 

6(b) Estimating Respondent Costs

Costs to respondents associated with this information collection include labor costs (i.e., 

the cost of labor by manufacturers to meet the information collection requirements of the 

proposed rule). Because the proposed requirements merely supplement existing activities, we 

believe manufacturers will incur no non-labor costs (e.g., the cost of purchasing and installing 

equipment or contractor costs associated with providing the required information).

To calculate labor costs, EPA estimated technical, managerial, clerical, and legal loaded 

labor rates for each industry sector using labor rates from the Bureau of Labor Statistics3and 

applying a 60% loading factor.4The labor rates are: $71.03 for managers; $55.20 for 

Engineers/technicians; $29.65 for clerical staff, and $101.00 for legal staff. 

EPA estimates that the annual cost to each engine manufacturer would average 6 hours 

and $365 over the three years covered by this information collection. This is based on an 

estimated effort involving 1 hour for managers, 1.5 hours for engineers, 2 hours for clerical staff, 

 

3 These rates reflect adjustments of the manufacturing sector's average productivity increase of 3.7% per year for 6 

quarters between 2006 Q2 and 2007 Q4, based on the estimate released by the Bureau of Labor Statistics in March 

2008.

4 The ICR Handbook (November 2005) recommends using a multiplier of 1.6 to account for benefits and overhead 

related to government wages; this is considered a conservative estimate (potentially high) for the private sector.
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and 1.5 hours or attorneys. Manufacturers are already required to submit similar information 

annually, so we expect that submitting and keeping the additional records will involve no capital 

costs and no O&M costs.

6(c) Estimating Agency Burden and Cost

This section describes the burden and cost to the Federal government associated with this 

information collection. Federal activities under this information collection include EPA 

oversight of the reporting program.

EPA burden and cost 

EPA activities associated with the proposed rule include oversight and implementation of 

the reporting program, e.g., monitoring and verification of emission reports, communication and 

outreach, and program evaluation. EPA estimates that this would involve up to 10 staff hours 

per year for these activities.

To develop EPA labor costs, EPA estimates the average hourly labor rate for salary and 

overhead and benefits for Agency staff to be $50.14. To derive this figure, EPA multiplied the 

hourly compensation at GS-12, Step 5 on the 2010 General Schedule pay scale ($32.73) by the 

standard government benefits multiplication factor of 1.6 to account for overhead and benefits.

6(d) Estimating the Respondent Universe and Total Burden and Costs

We expect to receive annual reports from 10 manufacturers. 

6(e) Bottom Line Burden Hours and Costs

The estimated bottom line burden hours and costs are 60 hours per year and $3,646 per 

year.

6(f) Burden Statement

The respondent reporting burden for this collection of information is estimated to be an 

average of 60 hours and $3,646 per year. The average annual burden to EPA for this period is 

estimated to be 10 hours. The annual public reporting and recordkeeping burden for this 

collection of information is estimated to average 6 hours per response. Burden means the total 

time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose 

or provide information to or for a Federal agency. This includes the time needed to review 

instructions; develop, acquire, install, and utilize technology and systems for the purposes of 

collecting, validating, and verifying information, processing and maintaining information, and

disclosing and providing information; adjust the existing ways to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information.
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An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB control number. The OMB 

control numbers for EPA’s regulations are listed in 40 CFR part 9.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OAR-2010-0687, which is available for online viewing at 

http://www.regulations.gov, or in person viewing at the Air and Radiation docket in the EPA 

Docket Center (EPA/DC), EPA West Building, Room 3334, 1301 Constitution Avenue, NW, 

Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 

p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading 

Room is (202) 566-1744, and the telephone number for the Air and Radiation docket is (202) 

566-1742. An electronic version of the public docket is available at http://www.regulations.gov. 

This site can be used to submit or view public comments, access the index listing of the contents 

of the public docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the Docket ID Number identified 

above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office 

of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk 

Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2010-0687 and 

OMB Control Number 2060-NEW on any correspondence.