SUBJ: Airport Deicing Rule – Follow‐up Meetings with Airport and Airline Associations from 11/2011 to

2/2012

FROM: Jan Matuszko

TO: Record

DATE: 2/23/12

As an outgrowth of EPA’s meeting with the Airports Council International‐North America (ACI)

and the Air Transport Association (ATA), on August 31, 2011 in which, among other things, these

associations discussed the extent to which they had incorporated pollution prevention to reduce

discharges, EPA subsequently met with them to discuss this further.  EPA met with these groups on

November 3, 2011, December 12, 2011, and January 19, 2012.   

During the first meeting, EPA and members from these associations explored pollution

prevention in more depth and discussed ways pollution prevention can be used to significantly reduce

discharges associated with aircraft deicing.  During the second meeting, these organizations discussed

the concept of a voluntary pollution reduction program with the goal of reducing discharges associated

with aircraft deicing.  On January 18, 2012, these associations submitted a draft voluntary pollution

reduction plan for our consideration (See attachment 1).  While this program is outside of the ELG

rulemaking and is being undertaken by these associations, they wanted to give EPA an opportunity to

review it before finalizing it.  During the third meeting, we discussed specifics of their voluntary pollution

reduction plan as submitted to us.   

The result was that on January 30, 2012, the ACI, the American Association of Airport Executives

(AAAE), Airlines for America (A4),1 and the Regional Airline Association (RAA ) provided documentation

of a program they worked together to create, on a national basis, to reduce discharges to the

environment associated with aircraft deicing activities.  See attachment 2.  Industry personnel indicate

that this pollution reduction program has the potential to significantly reduce aircraft deicing discharges

in a safe manner.  EPA supports this pollution reduction program.

   

                                                           

1 Formerly called Air Transport Association (ATA)

Conceptual Draft - for Facilitation of 01/19/2012 Discussion Only

Not for Citation or Quotation

1

REDUCTING POLLUTION ASSOCIATED WITH

AIRCRAFT DEICING ACTIVITIES

INTRODUCTION

I. Industry1adopts this Voluntary Pollution Reduction Program (“Voluntary Program”) 

with the goal of achieving, on a nationwide basis, substantial adoption of Pollution 

Reduction Technologies, which will further control Aircraft Deicing Fluid (“ADF”) 

discharges to the environment. Pollution Reduction Technologies may include, but are 

not limited to:

A. Pollution Prevention: examples may include improved ADF (e.g., with improved 

environmental characteristics), improved ADF application techniques, weather 

forecasting technologies, physical snow/ice removal techniques, enhanced 

training, ice-phobic materials on aircraft [etc.]; and

B. ADF-Impacted Stormwater Management: examples may include using systems 

and processes for collecting, storing, treating, recycling and/or otherwise 

managing runoff associated with the use of ADF.

II. The Voluntary Program will be implemented between the baseline year (2005) and a 

target year (2017) (the “Goal Period”) and will consist of the following seven 

components:

A. Conduct outreach and facilitate information exchange regarding this Voluntary 

Program and available Pollution Reduction Technologies;

B. Encourage the development, testing and commercially appropriate deployment of 

Pollution Reduction Technologies;

C. Provide information characterizing the performance benefits of appropriate 

Pollution Reduction Technologies;

 

1

 [Associations] 
Conceptual Draft - for Facilitation of 01/19/2012 Discussion Only

Not for Citation or Quotation

2

D. Develop a quantitative goal for environmental benefits to be achieved through this 

Voluntary Program; 

E. Inventory Pollution Reduction Technologies adopted during the Goal Period; 

F. Develop a comparison of the environmental benefits of Pollution Reduction 

Technologies adopted during the Goal Period with the quantitative goal; and

G. Report the results of the six components above to the U.S. Environmental 

Protection Agency (“EPA”). 

PURPOSE AND STRUCTURE OF VOLUNTARY PROGRAM

III. This Voluntary Program is structured to reflect the unique nature of the air transportation 

industry and aircraft deicing activity. Unique factors not common to other industries 

include:

A. The use of ADF is critical to the safe operation of aircraft under certain operating 

conditions and is mandated by federal law and the Federal Aviation 

Administration (“FAA”);

B. The frequency and intensity of aircraft deicing and associated activities is 

dictated by natural processes beyond human control (specifically weather 

conditions) and is a function of fleet mix, frequency of aircraft operations, the role

and location of an airport facility within the National Airspace System, and many 

other factors;

C. Aircraft deicing only occurs seasonally and, when it does occur, it occurs 

intermittently and for only short time periods;

D. Air transportation is an extremely heavily regulated activity, particularly to ensure 

safety of operations. Such regulations include:

1. Object free zones;

2. Height restrictions;
Conceptual Draft - for Facilitation of 01/19/2012 Discussion Only

Not for Citation or Quotation

3

3. Vehicular movement; 

4. Occupational/environmental;

5. Etc.;

E. There is no “average airport.” Airports are highly variable regarding geology,

hydrology, climate, environmental conditions, etc.; 

F. The existing infrastructure at airports, constraints on adding infrastructure (e.g.,

availability of on-site land) and access to facilities not under Industry control 

(e.g., publicly-owned treatment works (POTWs)), vary; and 

G. Performance of specific Pollution Reduction Technologies will vary based on 

above factors.

IV. Owing to these unique factors and the fact that the Clean Water Act’s existing stormwater 

permitting program addresses effluent associated with aircraft deicing activities, it is 

understood that this Voluntary Program does not and shall not be construed to:

A. Impose or imply any unique, specific or additional obligation on any individual 

airport, airline, fixed-base operator or other entity to deploy any specific Pollution 

Reduction Technology;

B. Impose or imply any constraint or limit of any type on ADF usage; 

C. Impose or imply any constraint or limit of any type (including effluent limit) on 

any specific discharges associated with ADF usage; or

D. Impose or imply any constraint or limit of any type on aircraft operations.
Conceptual Draft - for Facilitation of 01/19/2012 Discussion Only

Not for Citation or Quotation

4

PROGRAM COMPONENTS

V. Outreach to Facilitate Information Exchange: Industry, to the extent practicable and 

subject to legal restraints, will facilitate information exchange regarding Pollution 

Reduction Technologies through the following avenues:

A. ACI-NA/A4A Deicing Conference (conducted at least biennially during the Goal 

Period) (EPA and FAA staff are invited to participate as appropriate);

B. A4A Environment Council; 

C. ACI-NA Environmental Affairs Committee; and

D. AAAE Environmental Services Committee. 

E. This Component is subject to and limited by antitrust prohibitions precluding 

exchange of information or agreements regarding subjects such as: price or 

service-related terms (e.g., service fees, warranty terms, methods of recouping 

costs); boycotts or blacklists (e.g., limiting or refusing to do business with 

suppliers or category of suppliers); requiring suppliers to use certain standards or 

specifications; competitively-sensitive internal information (e.g., product pricing, 

cost-effectiveness); or contract bids or requests for proposals.

F. Reporting on the activities of the Committees is subject to Association bylaws, 

etc.

VI. Encourage Developing, Testing and Deploying Pollution Reduction Technologies: 

Industry, to the extent practicable and subject to legal restraints, will encourage 

development, testing and, as commercially appropriate (as determined by Industry), 

deployment of Pollution Reduction Technologies. Recognizing association activities are 

subject to applicable by-laws, examples of potential activities include:

A. Industry participation in SAE G-12 Committee (Aircraft Deicing Fluids 

Committee, Aircraft Deicing Facilities Committee, New Technologies 

Committee, etc.);
Conceptual Draft - for Facilitation of 01/19/2012 Discussion Only

Not for Citation or Quotation

5

B. Encouraging FAA, DOT, NASA and DOD to provide funding for technology 

development and deployment; and

C. This Component is subject to and limited by antitrust prohibitions precluding 

exchange of information or agreements regarding subjects such as: price or 

service-related terms (e.g., service fees, warranty terms, methods of recouping 

costs); boycotts or blacklists (e.g., limiting or refusing to do business with 

suppliers or category of suppliers); requiring suppliers to use certain standards or 

specifications; competitively-sensitive internal information (e.g., product pricing, 

cost-effectiveness); or contract bids or requests for proposals.

VII. Characterize the Performance Benefits of Pollution Reduction Technologies: Industry 

will gather “existing readily available public information” to characterize the 

performance benefits of specific Pollution Reduction Technologies, including:

A. Manufacturer-Provided Information, for example, regarding environmental 

characteristics of ADF and fluid savings associated with use of ADF trucks;

B. Research/Reports, for example, ACRP Report 14 (Deicing Planning Guidelines 

and Practices for Stormwater Management Systems) (2009);

C. Studies/analyses/assessments regarding the estimated benefits of appropriate 

pollution prevention technologies and stormwater management methods; 

D. For the purposes of this Voluntary Agreement, “existing, readily available public 

information” is meant to identify readily-available manufacturer information, 

reports, and studies/analyses/assessments of various Pollution Reduction 

Technologies that were deployed during the Goal Period, and that are deemed 

appropriate for public disclosure by the entity that undertook or commissioned the 

study. It is not meant to include or require:

1. Feasibility studies or other Pollution Reduction Technology assessments 

that may have been considered but have not been deployed;
Conceptual Draft - for Facilitation of 01/19/2012 Discussion Only

Not for Citation or Quotation

6

2. Initiating or completing any study/analysis/assessment to quantify or 

estimate the benefit of measures implemented during the Goal Period; or

3. Disclosing any study/analysis/assessment that quantifies or estimates the 

benefit of measures implemented during the Goal Period, but is considered 

to be confidential for any reason by its owner.

VIII. Develop a Quantitative Goal for Environmental Benefits to be Achieved Through the 

Voluntary Program: Industry agrees to identify a quantitative goal to be achieved during 

the Goal Period. This “goal” may be stated, for example, in terms of avoided discharges 

of an appropriate ADF-related pollutant compared to the discharges that could have 

occurred without deploying the various Pollution Reduction Technologies adopted during 

the Goal Period, or some other appropriate measure of the environmental benefits of 

Pollution Reduction Technologies adopted during the Goal Period, which is to be 

determined by Industry.

IX. Inventory Pollution Reduction Technologies Adopted During the Goal Period: 

Industry will inventory Pollution Reduction Technologies deployed over the Goal Period 

at the Defined Set of Airports (and at other airports at the Industry’s discretion).

A. “Defined Set of Airports” – means a list of airports that collectively account for 

approximately 80 percent of the ADF applied on a national basis. Additional 

airports may be included at Industry’s discretion at any time during the Goal 

Period. 

B. Industry will identify the Pollution Reduction Technologies deployed during the 

Goal Period through one or more surveys conducted by Industry during and/or at 

the conclusion of the Goal Period. 
Conceptual Draft - for Facilitation of 01/19/2012 Discussion Only

Not for Citation or Quotation

7

X. Compare the Environmental Benefits of Pollution Reduction Technologies Adopted 

During the Goal Period with the Quantitative Goal: Industry will compare the 

environmental benefits of the Pollution Reduction Technologies during the Goal Period

to the goal established under this Voluntary Program.

XI. Reporting: Industry will report to EPA on the Voluntary Program as follows: 

A. Initial Report: No later than November 30, 2012, Industry will provide a report 

consisting of the following:

1. The list of airports included in the “Defined Set of Airports;” and

2. A summary of any outreach that has been conducted or planned to 

facilitate the information exchange in support of the Voluntary Program 

(this summary may be in the form of a table or other useful format).

B. Phase I Report: No later than June 1, 2015, Industry will provide a report 

consisting of the following:

1. A summary of Industry activities undertaken from the time the Initial 

Report was filed through March 31, 2015, to:

a. further facilitate information exchange and outreach; and

b. encourage the development, testing and, as commercially 

appropriate, deployment of Pollution Reduction Technologies; 

2. Information (publicly available as of March 31, 2015) characterizing the 

performance benefits of Pollution Reduction Technologies developed in 

accordance with VII, above; and

3. An articulation of the quantitative goal developed in accordance with VIII, 

above.
Conceptual Draft - for Facilitation of 01/19/2012 Discussion Only

Not for Citation or Quotation

8

C. Phase II Report: No later than September 30, 2018 (6-months after conclusion 

of last deicing season in the goal period (September 2017-April 2018), Industry 

will provide a report consisting of the following:

1. An update of elements 1 and 2 of the Phase I Report through March 31, 

2018; and 

2. A comparison of the environmental benefits of Pollution Reduction 

Technologies adopted during the Goal Period to the goal developed in 

accordance with VIII, above.
Airlines for America'· 

Via Hand Delivery 

Mr. Robert K. Wood 

• MlfOm COUNCil 

ItffUlDlW. 

U.S. Environmental Protection Agency 

Ariel Rios Building 

Mail Code: 450n 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

Dear Mr. Wood: 

Regional Airline Association 

January 30,2012 

The Airports Council International- North America (ACI-NA), the American Association of Airport 

Executives (AAAE), Airlines for America (A4A) , and the Regional Airline Association (RAA) have created 

a program to work together, on a national basis, to reduce discharges to the environment associated with 

aircraft deicing activities, which will further enhance our nation's waters and aquatic ecosystems. While 

purely a voluntary industry program, we believe that the attached framework will help to document the 

benefits associated with the industry's past and future commitment to preventing pollution and 

implementing technologies that help to reduce any environmental risks associated with aircraft deicing 

operations. 

These associations have engaged with the U.S. Environmental Protection Agency for more than 

15 years, providing significant insight, information, and assistance as the Agency analyzed environmental 

risks and technologies for reducing risks associated with applying aircraft deicing fluid (ADF) and 

managing ADF runoff at airports. During that same period, the industry has demonstrated its continued 

commitment to environmental protection. We believe that our five-year voluntary program (attached) will 

help to demonstrate the benefits of this commitment and achieve those benefits faster and more 

efficiently than through an Effluent Limitations Guidelines (ELG) standard, without compromising the 

ultimate purpose for using ADF, the safe travel of the American public. 

The specific details of our program are set forth in the attached document. We encourage you to 

review it with your staff and to consider the many benefits it offers. If you have questions or would like 

additional information, please contact any of the following individuals. 

Respectfully, 

Timothy A. Pohle 

Senior Managing Director, Environmental Affairs 

Airlines for America 

Liam R. Connolly 

Senior Director, Regulatory Affairs 

Regional Airline Association 

eg 

President 

Airports Council International - North America 

1J1gkxJ~ el sa Sabatine 

Vice President, Regulatory Affairs 

American Association of Airport Executives 
REDUCING POLLUTION ASSOCIATED WITH 

AIRCRAFT DEICING ACTIVITIES 

INTRODUCTION 

I. Industry) adopts this Voluntary Pollution Reduction Program ("Voluntary Program") 

with the goal of achieving, on a national basis, substantial adoption of Pollution 

Reduction Technologies that will reduce discharges to the environment associated with 

aircraft deicing activities, enhancing our nation's waters and aquatic ecosystems. 

Pollution Reduction Technologies may include, but are not limited to: 

A. Pollution Prevention: examples may include improved Aircraft Deicing Fluid 

("ADF") (e.g., ADF formulations that exert a lower oxygen demand in waters), 

improved ADF application techniques (e.g., application systems that utilize less 

ADF while maintaining flight safety), weather forecasting technologies that allow 

more efficient use of ADF, physical snow/ice removal techniques, enhanced 

training, ice-phobic materials on aircraft; and 

B. ADF-Impacted Stormwater Management: examples may include systems and 

processes for collecting, storing, treating, recycling and/or otherwise managing 

the runoff that results from applying ADF to aircraft. 

II. The Voluntary Program will be implemented over a 5 year period from September 30, 

2012 to September 30,2017 (the "Program Period") and will consist of the following 

seven components listed below and further described herein: 

A. Conduct outreach and facilitate information exchange regarding this Voluntary 

Program; 

B. Encourage the development, testing and commercially appropriate deployment of 

Pollution Reduction Technologies; 

) A4A, ACI-NA, AAAE and RAA 

1 
C. Provide information characterizing the environmental benefits of appropriate 

Pollution Reduction Technologies; 

D. Develop a quantitative pollution reduction goal to be achieved through the 

adoption of Pollution Reduction Technologies; 

E. Provide an inventory of adopted Pollution Reduction Technologies; 

F. Compare the environmental benefits of adopted Pollution Reduction Technologies 

with the quantitative pollution reduction goal; and 

G. Report the results of the six components above to the U.S. Environmental 

Protection Agency ("EPA"). 

STRUCTURE OF VOLUNTARY PROGRAM 

III. This Voluntary Program is structured to reflect the unique nature of the air transportation 

industry and aircraft deicing activity. Unique factors not common to other industries 

include: 

A. The use of ADF is critical to the safe operation of aircraft under certain operating 

conditions and is mandated by federal law and the Federal Aviation 

Administration ("FAA"); 

B. The frequency and intensity of aircraft deicing and associated activities are 

dictated by natural processes beyond human control (specifically weather 

conditions) and are a function of fleet mix, frequency of aircraft operations, the 

role and location of an airport facility within the National Airspace System, and 

many other factors; 

C. Aircraft deicing only occurs seasonally and, in many areas of the country when it 

does occur, it occurs only intermittently and for short time periods; 

D. Air transportation is an extremely heavily regulated activity, particularly to ensure 

safety of operations. Such regulations include: 

2 
1. Object free areas; 

2. Height restrictions; 

3. Vehicular movement; 

4. Occupational/environmental; 

5. Etc.; 

E. There is no "average airport." Airports are highly variable regarding geology, 

hydrology, climate, weather, geographic location, environmental conditions, etc.; 

F. The existing infrastructure at airports, constraints on adding infrastructure (e.g., 

availability of on-site land) and access to facilities not under Industry control 

(e.g., publicly-owned treatment works (POTWs)), will vary; and 

G. Performance and implementation of specific Pollution Reduction Technologies 

will vary based on above factors. 

IV. Owing to these unique factors and the fact that the Clean Water Act's existing stormwater 

permitting program addresses discharges associated with aircraft deicing activities, it is 

understood that this Voluntary Program does not and shall not be construed to: 

A. Impose or imply any unique, specific or additional obligation on any individual 

airport, airline, fixed-base operator or other entity to deploy any specific Pollution 

Reduction Technology; 

B. Impose or imply any constraint or limit of any type on ADF usage; 

C. Impose or imply any constraint or limit of any type (including effluent limit) on 

any specific discharges associated with ADF usage; or 

D. Impose or imply any constraint or limit of any type on aircraft operations. 

PROGRAM COMPONENTS 

3 
V. Outreach to Facilitate Information Exchange: Industry, to the extent practicable and 

subject to legal restraints, will facilitate information exchange regarding Pollution 

Reduction Technologies through the following avenues: 

A. ACI-NA/A4A Deicing Conference (conducted at least biennially) (EPA, FAA and 

other government agencies staff are invited to participate as appropriate); 

B. AAAE Large Hub Winter Operations and Deicing Conference: 

C. A4A Environment Council; 

D. ACI-NA Environmental Affairs Committee; 

E. AAAE Environmental Services Committee; and 

F. RAA Environmental Committee. 

G. This Component is subject to and limited by antitrust prohibitions precluding 

exchange of information or agreements regarding subjects such as: price or 

service-related terms (e.g., service fees, warranty terms, methods of recouping 

costs); boycotts or blacklists (e.g., limiting or refusing to do business with 

suppliers or category of suppliers); requiring suppliers to use certain standards or 

specifications; competitively-sensitive internal information (e.g., product pricing, 

cost-effectiveness); or contract bids or requests for proposals. 

H. Reporting on the activities of the Industry Associations is subject to each 

Association's bylaws, etc. 

4 
VI. Encourage Developing, Testing and Deploying Pollution Reduction Technologies: 

Industry, to the extent practicable and subject to legal restraints, will encourage 

development, testing and, as commercially appropriate (as determined by Industry), 

deployment of Pollution Reduction Technologies. Recognizing association activities are 

subject to applicable by-laws, examples of potential activities include: 

A. Industry participation in SAE G-12 Committee (Aircraft Deicing Fluids 

Committee, Aircraft Deicing Facilities Committee, New Technologies 

Committee, etc.); 

B. Industry will work with FAA, DOT, NASA and DOD to encourage technology 

development and deployment; and 

C. This Component is subject to and limited by antitrust prohibitions precluding 

exchange of information or agreements regarding subjects such as: price or 

service-related terms (e.g., service fees, warranty terms, methods of recouping 

costs); boycotts or blacklists (e.g., limiting or refusing to do business with 

suppliers or category of suppliers); requiring suppliers to use certain standards or 

specifications; competitively-sensitive internal information (e.g., product pricing, 

cost-effectiveness); or contract bids or requests for proposals. 

VII. Characterize the Environmental Benefits of Pollution Reduction Technologies: 

Industry will gather "existing readily available public information" to characterize the 

environmental benefits of specific Pollution Reduction Technologies, including: 

A. Manufacturer-Provided Information, for example, regarding environmental 

characteristics of ADF and fluid savings associated with use of ADF trucks; 

B. Research/Reports, for example, ACRP Report 14 (Deicing Planning Guidelines 

and Practices for Stormwater Management Systems) (2009); 

C. Studies/analyses/assessments regarding the estimated benefits of appropriate 

pollution prevention technologies and stormwater management methods; 

5 
D. For the purposes ofthis Voluntary Agreement, "existing, readily available public 

information" is meant to identify readily-available manufacturer information, 

reports, and studies/analyses/assessments of various Pollution Reduction 

Technologies assembled by the Industry that are deemed appropriate for public 

disclosure by the entity that undertook or commissioned the study. It is not meant 

to include or require: 

1. Feasibility studies or other Pollution Reduction Technology assessments 

that may have been considered but have not been deployed; 

2. Initiating or completing any study/analysis/assessment to quantify or 

estimate the benefit of measures adopted; or 

3. Disclosing any study/analysis/assessment that quantifies or estimates the 

benefit of measures adopted, but which may be considered to be 

confidential for any reason by its owner. 

VIII. Develop a Quantitative Pollution Reduction Goal: Industry agrees to develop a 

quantitative pollution reduction goal that, on a national basis, will reflect a substantial 

adoption of Pollution Reduction Technologies, enhancing our nation's waters and aquatic 

ecosystems. This pollution reduction goal will be stated in terms of a national estimate of 

the reduction in oxygen demand projected to result from Pollution Reduction 

Technologies adopted during the Defined Period relative to what otherwise would have 

occurred absent industry adoption of such technologies. Industry may also document 

significant reductions in oxygen demand resulting from the adoption of Pollution 

Reduction Technologies prior to the Defined Period. 

IX. Inventory Pollution Reduction Technologies Adopted: Industry will inventory Pollution 

Reduction Technologies adopted during the Defined Period at the Defined Set of Airports 

(and at other airports at the Industry's discretion). 

A. "Defined Set of Airports" - means a list of airports at which, collectively on a 

national basis, approximately 80 percent of the ADF typically is applied. 

6 
Additional airports may be included at Industry's discretion at any time during the 

Program. 

B. Industry will identify the Pollution Reduction Technologies adopted during the 

Defined Period through one or more surveys conducted by Industry during and/or 

at the conclusion of the Program. The Defined Period shall be the period from 

January 1,2005 to September 30, 2017. 

X. Compare the Environmental Benefits of Pollution Reduction Technologies with the 

Quantitative Pollution Reduction Goal: Industry will compare the environmental 

benefits of Pollution Reduction Technologies adopted during the Defined Period to the 

quantitative pollution reduction goal established under this Program. 

XI. Reporting: Industry will report to EPA on the Voluntary Program as follows: 

A. Initial Report: No later than November 30, 2012, Industry will provide a report 

consisting of the following: 

1. The list of airports included in the "Defined Set of Airports;" and 

2. A summary of any outreach that has been conducted or planned to 

facilitate the information exchange in support of the Voluntary Program 

(this summary may be in the form of a table or other useful format). 

B. Phase I Report: No later than September 30,2014, Industry will provide a report 

consisting of the following: 

1. A summary of Industry activities that have been conducted or planned 

from the time the Initial Report was filed to: 

a. further facilitate information exchange and outreach; and 

b. encourage the development, testing and, as commercially 

appropriate, deployment of Pollution Reduction Technologies; 

7 
2. Publicly available information characterizing the environmental benefits 

of Pollution Reduction Technologies developed in accordance with VII, 

above; and 

3. An articulation of the quantitative pollution reduction goal developed in 

accordance with VIII, above. 

c. Phase II Report: No later than 60-days following the Program's September 30, 

2017 closing date, Industry will provide a report consisting of the following: 

1. An update of elements 1 and 2 of the Phase I Report; and 

2. A comparison of the environmental benefits of the Pollution Reduction 

Technologies adopted during the Defined Period to the pollution reduction 

goal developed in accordance with VIII, above. 

XII. Summary of Key Dates 

Establish/Initiate Voluntary Program September 30,2012 

Initial Report November 30,2012 

Phase I Report September 30, 2014 

End Voluntary Program September 30,2017 

Phase II Report November 30, 2017 

8