SUPPORTING STATEMENT

AIRCRAFT ENGINES — SUPPLEMENTAL INFORMATION RELATED TO EXHAUST
EMISSIONS 

PROPOSED RULE

OMB Control No. 2060-NEW

EPA ICR No. 2427.01

January 2011

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

	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 standard-setting 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. 

	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 sub-model 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);

•  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;

•  Unburned hydrocarbon characteristic level (i.e. mass of
hydrocarbons over LTO cycle / Rated Thrust (Dp/Foo); 

•  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 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, 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 Statistics and applying a 60% loading factor. 
The 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,
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.

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.  

 See Regulation Part 87-Control of Air Pollution from Aircraft and
Aircraft Engines, Subpart E, §87.42  Certification report to EPA for
definitions.

 Dp/Foo : total gross emission of each gaseous pollutant (mass) / rated
thrust (g/kN).

 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.

 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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