CAEP6WP34 NOx Production Cutoff Considerations

1
CAEP/6-WP/34NOx Production Cut-off Considerations

• Presented by ICCAIA

2
Is There a Need for a CAEP/4 NOx Production
Cut-off?

• Historically, the purpose of a production cut-off
  has been to prevent industry from continuing to
  manufacture products not in compliance with
  recent standards
• Industry, however, as demonstrated during the
  adoption of the CAEP/4 NOx standard, has
  responded to reasonable standards and market
  forces by incorporating the best available
  technology into their products, even without an
  accompanying production cut-off
• Today, all but one in production engine has met
  the CAEP/4 NOx standard long before it took
  effect after 31 December 2003
• Technology has been identified to make this
  engine compliant
• The overwhelming compliance rate suggests that a
  production cut-off is not required

Reasonable standards and market forces are the
primary drivers to new technology development
and incorporation, not production cut-offs!
3
Industry is Proactive in Meeting Reasonable
Standards Long Before Implementation Dates
Status of Engines Not Meeting CAEP/4 NOx Standard
in 1998
4
Recommendations

• ICCAIA recommends no CAEP/4 NOx Production
  Cut-off at CAEP/6
• By taking this action, CAEP can confirm the
  strength of market forces reasonable standards
  as a driver for industry to continue to achieve
  regulatory compliance
• A reasonable CAEP/6 NOx standard will reinforce
  market pressure on manufacturers to incorporate
  best available technology into their products
  that meet and exceed CAEP/6, not CAEP/4
• Expands the scope of ICAO policies to achieve
  environmental objectives
• Minimal environmental risk (Paris SG FESG Interim
  Analysis Report CAEP/6-WP18 and IP13),
  potentially high benefits