(8 pages) CAEPSG.20082.WP.006.3.en.doc 

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

STEERING GROUP MEETING

Seattle, 22 to 26 September 2008

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

PRODUCTION CUT-OFF FOR ENGINE NOX STANDARDS

(Presented by FESG Rapporteurs)

SUMMARY At the first Steering Group meeting of the CAEP/8 cycle 1 , the United States representative presented a working paper 2 stating that a NO X production cutoff was required because market forces did not appear to be working. According to the paper, “ in-production engines that are ‘non-compliant’ with the CAEP/6 NO X standard will likely not meet these standards in the future ”. This paper presents additional informa tion showing that market forces are working and that non-compliant engines currently in production have been or very soon will be made compliant with the CAEP/6 NO X standard, or have very low volume of sales and will soon be out of production, and hence that there is no environmental impact. As 99+% of in-production engines sold will meet the CAEP/6 NO X requirements by 2009, there is no need for a production cut-off, and the environmental benef it from such a production cut-off would be negligible.

Action by the CAEP-SG is in paragraph 4.

1. INTRODUCTION

1.1 The purpose of ICAO NO X stringency requirements is to en sure that all newly developed airframes and engines incorporate th e latest commercially available proven technologies across the entire product line, mindful that no single technology can be applied across the entire fleet 3 . Unlike the CAEP/2 standard set to ensure new NO X reduction technologies were incorporat ed into new engine designs as well as in-production engines by a certain date, the CAEP/4 and CAEP/6 NO X standards did not mandate a

1 Held in Zurich (Switzerland), from November 26 to 30, 2007.

2 Ref

. [CAEP-SG/20071-WP/26] . “Production Cut-Off For Engine NO X Standards”.
3 Ref

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

Montreal (Canada), from February 5 to 16, 2007. International Civil Aviation Organization



### WORKING PAPER CAEP-SG/20082-WP/6 4/9/08 English onlyCAEP-SG/20082-WP/6 - 2 -

production cut-off for non-compliant engines. The CAEP/4 decision was based on the limited number of engines affected at the date of implementation and th eir expected future market share. The decision made at CAEP/6 was based on evidence that market forces we re sufficient to bring non-compliant engines into compliance across the entire engine family.

1.2 In CAEP-SG/20071-WP/26, the CAEP Steering Group was invited to direct WG3 and FESG to begin work to assess a production cut-off for the CAEP/6 NO X standard at a date 4 and 6 years after the implementation date for newly certificated engines, 31 December 2007, such that it can be considered at the CAEP/8 meeting. This suggestion was predicated on the notion that market forces did not appear to be working and the only way to assu re compliance of non-compliant engines was through the introduction of a production cut-off. In response to CAEP-SG/20071-WP27 4 , the Steering Group agreed to follow a step process to the assessment of a CAEP/6 production cut-off. They agreed that if sufficient evidence was produced to support the assertion that market forces had driven compliance then they would consider not continuing with a second ph ase to a full cost benefit assessment. However, if such evidence was not forthcoming, the Steering Group could decide to task FESG with a full assessment of the effects of a CAEP/6 production cut-off.

1.3 Although both FESG 5 and WG3 6 were tasked to look into the issue, it was agreed that FESG take the lead on providing a qualitative analysis th at would provide sufficient evidence that market forces have driven compliance of in-production engines with the CAEP/6 NO X standard. This paper addresses in detail the list of engines that were labe lled as “in-production” as of 2004 that did not meet the CAEP/6 standard. FESG pulled together informa tion on upgrade programs for current in-production engines with assistance from ICCAIA and WG3. The following sections address the current status of implementation of technologies into engines to meet th ese standards. It also provides reasons that an engine remains non-compliant, such as low sales data or it is no longer in-production.

2. INDUSTRY RESPONSE TO THE CAEP/6 NO X STANDARD

2.1 FESG reviewed the current status of the engines listed in CAEP/7-IP/2 Table 2.3 reproduced in this paper as Table 1 . This list of engines in Table 1 represents the in-production engines, as of 2004, identified as not meeting the CAEP/6 NO X standard.

2.2 FESG noted in the CAEP/7-IP/2 that a sufficient period of time had not elapsed since the CAEP/6 NO X standard was adopted for complete industry r esponses to be observed. Since the time of the writing of the CAEP/7-IP/2 paper, (November / D ecember 2006), approximately only 2.5 years have elapsed since the CAEP/6 meeting wher e the recommendation for the CAEP/6 NO X standard was made and only 2 years since it was formally adopted by th e ICAO Assembly in October 2004. It was also noted that a full evaluation of the industry response to these standards would be reported at future CAEP meetings. FESG is reporting additional pr ogress on industry responses to the CAEP/6 NO X standard in the following paragraphs.

4 Ref

. [CAEP-SG/20071-WP27 ]. “Production Cut-Off For CAEP/6 Engine NO X Standards”. Informa tion paper submitted by the International

Coordinating Council of Aerospace Industrie s Associations (ICCAIA) in response to [CAEP-SG/20071-WP26]

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

CAEP/6 NO X standards and reasons why any in-production engines remain non-compliant. The analysis should provide current and forecast sales as well as assessment of engines s till “in-production” as spares or new engines”.

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

regarding a CAEP/6 Production cut-off provision.”CAEP-SG/20082-WP/6 - 3 -

2.3 At the time of CAEP/6 in 2004, the CFM56 e ngine families did not meet the agreed upon recommendation for the new NO X standard. The CFM56 is an engine family with a high volume of annual sales and since 2004, all CFM56 in-production engines for the Boeing 737, Airbus A320 family, and Airbus A340-200/300 have been upgraded to meet the CAEP/6 NO X standards with margin. It is important to recognize that this engine upgrade prog ram is a visible example that market forces do work. The CFM56-5B and CFM56-7B engines with CFM 56 Tech Insertion have become the new production configurations. The engine upgrade reduces the NO X emissions to meet the CAEP/6 NO X standard with considerable margin plus provides some additiona l performance benefits. For the CFM56-5C family, a performance upgrade package, denoted w ith the “/P” suffix, has allowed the engine models in this family to meet CAEP/6 NO X standard with margin.

2.4 The V2500 is another engine, with a high volume of annual sales, that is installed on the A320 aircraft family and the upgrade being developed for this engine family is another visible example of market forces at work. IAE 7 is currently certificating engine improvements under the V2500 SELECT program, available by third quarter 2008, which will bring the engine family into compliance with the CAEP/6 NO X standards. Additionally, this engine will o ffer improvements in fuel burn and a resulting reduction in CO 2 emissions.

2.5 The B757 is no longer in production and therefore the PW2040 and PW2043 engine models are now out of production.

2.6 The PW4164 and PW4168 engine family has been certificated with a TALON II combustor, which meets the CAEP/6 NO X standard with considerable margin. The PW4164/68 with the original floatwall combustor is still offered for sal e, primarily to fill spare engine requirements for customers requiring commonality with their existing fl eet, however intermix of the engine models with the two different combustors is also allowed. Pra tt & Whitney is currently completing development of an engine upgrade for the PW4168 family called Advantage70 TM , available in early 2009, where the TALON II combustor will become the only combustor option available for new orders. Intermix of PW4164 / 68 engines with or without the TALON II combusto r on the same aircraft will be allowed.

2.7 The PW4077D, PW4080D and PW4090 on the Boeing 777 have low annual sales, and although a technology has been identified to allo w this engine family to meet the CAEP/6 NO X standards it is not cost effective to implement the technolog y. A table of current in-production aircraft-engine configurations with engines that do not meet the CAEP/6 NO X standard and have a low volume of orders was produced from the AvSoft Information Systems ACAS commercial fleet database and is attached as Table 2. The low order figures for aircraft with the PW4077D, PW4084D and PW4090 engines are shown in this attachment. There are outstanding orders for only 12 installed PW4090 engines.

2.8 The PW4056, PW4060, PW4062, PW4156 and PW4158 engine models with a Phase 3 build standard all belong to a common engine fa mily. The TALON II combustor was certified on the PW4158, which powers the Airbus A300, and this co mbustor allows the PW4158 to meet the CAEP/6 NO X standards with considerable margin. The PW4156 powers the A310 that is now out of production. The PW4056/60/62 phase 3 engines on the Boeing 767 and Boeing 747-400 have low sales figures and as a result have not been modified to comply with the CAEP/6 NO X standards. The TALON II combustor technology has been identified as the technology for these engine models to meet the CAEP/6 NO X standard, but will only be implemented if a s ubstantial order for these engines is obtained. Table 2 shows the outstanding orders for the PW4062 that are for 24 in stalled engines to be delivered by the end of 2009.

7 IAE – International Aero Engines. IAE is a multinational aer o engine consortium whose sharehol ders comprise Pratt & Whitney, Rolls-Royce,

the Japanese Aero Engines Cor poration and MTU Aero Engines.CAEP-SG/20082-WP/6 - 4 -

2.9 There is an engine upgrade, (PEC), for th e GE90-94B engine which allows this engine model to meet the CAEP/6 NO X standards with margin.

2.10 There is a new combustor under development for the AS907 engine that will meet the CAEP/6 NO X standards with margin when certificated in 2009.

2.11 The Tay 611-8C engine will be re-certificated for emissions to meet CAEP/6 NO X standards in 2009.

2.12 Summary of in-production engine mode ls that will not meet the CAEP/6 NO X standard by 2009.

Engine Family Engine Model

PW4000 with

94inch fan PW4056 Phase 3 * PW4060 Phase 3 * PW4062 Phase 3 *

PW4090 PW4074D PW4077D
PW4084D PW4090

* TALON II combustor that is certified on PW4158 c ould be installed and certified on PW4056/60/62,

provided a substantial order for these engines was obt ained to rationalize the incremental certification
cost.

3. PRODUCTION CUT-OFF WOULD PROVIDE VERY LITTLE ENVIRONMENTAL BENEFIT

3.1 From the ACAS commercial fleet database, the total installed engines representing firm aircraft orders to be delivered in 2009 for comme rcial passenger and freighter regional jets, narrow body and wide body aircraft is estimated to be more than 2 650 engines. The total number of installed engines to be delivered for 2008, 2009 and 2010 that would not meet the CAEP/6 NO X standards adds up to 32 engines, (see Table 2). The average annual deliveri es of installed engines over this period that do not meet the CAEP/6 NO X standard is estimated to be about 11 engi nes per year. By 2009, the percentage of annual installed engine deliveries that meet the CAEP/6 NO X standard would be 99.6%, ((2 650-11)/2 650).

3.2 After 2012, the ACAS database estimates that there would be only 4 installed engines to be delivered that would not meet the CAEP/6 NO X standard. The estimated firm order deliveries of installed engines for 2012 is estimated to be more than 2 050. These 4 engines represent less than 0.2 percent of calendar year 2012 projected engine deliveries.

3.3 With over 99% of in-production engines to be delivered meeting the CAEP/6 NO X requirements by 2009, the environmental benefit fro m implementing a production cut-off to the CAEP/6 NO X standard would be negligible. Therefore, there is no need for a production cut-off.

3.4 It can be concluded from these elements that market forces do work, provided sufficient time is given for Industry to respond.CAEP-SG/20082-WP/6 - 5 -

4. ACTION BY THE CAEP-SG

4.1 The CAEP-SG is invited to:

a) Recognize the progress that the engine manufacturers have achieved in bringing inproduction engines into compliance with the CAEP/6 NO X standards;

b) Accept the market-driven production cut-off assumption made by FESG (and as described in CAEP/7-IP02) as a reasonable basis for CAEP/8 economic analysis of NO X stringency options; and

c) Approve the recommendation of FESG to not implement a production cut-off for the CAEP/6 NO X standard.

— — — — — — — —CAEP-SG/20082-WP/6 Appendix A

APPENDIX A

Table 1 As summarized in CAEP/7-IP02 Table 2.3 – Engines in production as of 2004 Not Meeting the ICAO CAEP/6 NO X standards.

Large Engine Category CFM56-5B1/P CFM56-5B2/P CFM56-5B3/P CFM56-5C2 CFM56-5C3 CFM56-5C4 CFM56-7B22 CFM56-7B24 CFM56-7B26 CFM56-7B27 / -7B27-B3 V2522-A5 V2524-A5 V2527-A5 V2530-A5 V2533-A5 PW2040 PW2043 PW4164 (1) PW4168 (1) PW4056 Phase 3 PW4156 Phase 3 PW4158 Phase 3 PW4060 Phase 3 PW4062 Phase 3 PW4074D PW4077D (1) PW4084D (1) PW4090 (1) GE90-94B

Small Engine Category AS907 Tay Mk. 611-8C

(1) Indicates that engine did not meet the CAEP/4 NO X standardCAEP-SG/20082-WP/6 Appendix A A-2

Table 2



### Review of Orders for In-Production Engines That Do Not Meet the CAEP/6 NO X 

### standards

– Low Volume of Orders

Engine Aircraft Total Backlog 2008 2009 2010 2011 2012 2013 2014 2015

PW4062A 747-400F / -400ERF 24 12 12

PW4090 777-200 / -200ER 12 6 2 4 Firm Order Backlog as of June 2008 - Number of Installed Engines

(Source: ACAS) 8

— END —

8 ACAS – AirCraft Analytical System: Aviation market information system database.