Icf Final Report - Epa 2017 Aircraft Co2 Cost Assessment - 2018-09-30 PDF

Aircraft CO2 Cost
and Technology
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September 30, 2018
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ICF
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Aircraft CO2 Cost and Technology Refresh
Table of Contents
I. Preface.............................................................................................................................................. 4
II. Assessment of CO2 Reducing Technologies ............................................................................... 5
1. Introduction ................................................................................................................................... 5
1.1 Growth of Aviation-Produced CO2 and the International Response................................... 5
1.2 Data Sources ...................................................................................................................... 6
1.2.1 Secondary Research ...................................................................................................... 7
1.2.2 Market Interviews ........................................................................................................... 7
1.2.3 Domain Knowledge and ICF Internal Cost and Performance Models ........................... 9
1.2.4 Benchmark databases, industry conferences, and latest industry news &
announcements .......................................................................................................................... 9
III. Executive Summary ...................................................................................................................... 10
IV. Aircraft Metric Values ................................................................................................................... 13
1. Introduction ................................................................................................................................. 13
2. Metric Value Data Sources – PIANO ......................................................................................... 14
V. Metric Value Forecast ................................................................................................................... 15
1. Introduction ................................................................................................................................. 15
2. Methodology ............................................................................................................................... 15
2.1 Short and Mid-Term Metric Value Impact Methodology (Years 2015-2029) ................... 15
2.2 Long-Term Metric Value Impact Methodology (Years 2030-2040) .................................. 16
2.3 Technology Development Cost Methodology................................................................... 17
3. Updates to 2015 Assumptions ................................................................................................... 17
3.1 Technology and Cost Assumptions Updates.................................................................... 17
3.2 Methodology Updates ....................................................................................................... 18
4. Results/Forecast ......................................................................................................................... 18
VI. Stringency Implications ................................................................................................................ 19
1. Introduction ................................................................................................................................. 19
2. Stringency Scenarios .................................................................................................................. 19
3. Stringency Lines ......................................................................................................................... 23
4. Stringency Gaps ......................................................................................................................... 25
VII. Technology Response for Failed Aircraft .............................................................................. 27
1. Modeling Metric Value Reduction............................................................................................... 27
1.1 Implementation of Metric-Value-Improving Technology versus Smoothed Forecast ...... 27
1.2 1% Additional Design Margin for Non-Compliant Aircraft ................................................ 29
2. PIANO Data Based Technology Response ............................................................................... 29
2.1 Regulatory Non-compliance by Scenario ......................................................................... 29
2.2 Technology Response by Aircraft by Scenario ................................................................ 31
2.2.1 A380 (-842 / -861) ........................................................................................................ 31
2.2.2 767-3F........................................................................................................................... 33
2.3 2028 Freighter Delay ........................................................................................................ 34

2.4 Low Volume Exemption .................................................................................................... 36
2.4.1 Introduction to Low Volume Exemption........................................................................ 36
2.4.2 Low Volume Exemption for In-Scope Aircraft based on PIANO Data ......................... 36
2.5 In-Development Freighter Aircraft Analysis ...................................................................... 38
VIII. Appendices ............................................................................................................................. 39
1. 2015 Technology Impact Model Methodology ........................................................................... 39
1.1 Introduction ....................................................................................................................... 39
1.2 Magnitude and Sources of Historical CO2 Reductions ..................................................... 42
1.3 The Nature of Technology Insertion ................................................................................. 42
2. Long-Term Technology Impact Model Methodology .................................................................. 47
2.1 Introduction ....................................................................................................................... 47
2.2 Methodology overview ...................................................................................................... 47
2.3 Derive fuel burn reduction prospect index ........................................................................ 47
2.4 Derive market driver index ................................................................................................ 49
2.5 Derive overall metric value improvement acceleration index ........................................... 49
2.6 Example: Narrowbody Long-Term Metric Value Forecast ............................................... 49
2.7 Long-Term Replacement Aircraft Analysis (Replacement Aircraft circa 2030-2040) ...... 51
2.7.1 Historical Aircraft Emissions Performance ................................................................... 51
2.7.2 Long-term metric value forecast ................................................................................... 53
3. 2015 Development Cost Model Methodology ............................................................................ 55
3.1 Introduction ....................................................................................................................... 55
3.2 Methodology Overview ..................................................................................................... 55
3.3 Categorizing Incremental Technologies ........................................................................... 55
3.4 Elements of Non-Recurring Cost ...................................................................................... 56
3.5 Baseline Non-Recurring Cost Element Proportions ......................................................... 56
3.6 Non-Recurring Cost Scaling Factors ................................................................................ 57
3.7 Considerations for Recurring Costs .................................................................................. 59
3.8 Cost Calculations .............................................................................................................. 59
3.9 Example: Large Incremental Update NRC (Wingtip Devices)......................................... 59
4. Table of Aircraft MV Forecast (PIANO Data) ............................................................................. 62
5. Representative Cumulative Metric Value Improvement and Cumulative Non-Recurring Cost
(NRC) by Aircraft Category......................................................................................................... 66
6. Selected Technology Profiles ..................................................................................................... 67
6.1 Engine Technologies ........................................................................................................ 67
6.2 Variable Camber Trailing Edge......................................................................................... 71
6.3 Advanced Wingtip Devices ............................................................................................... 73
6.4 Adaptive Trailing Edge ...................................................................................................... 75
6.5 Riblet Coatings .................................................................................................................. 77
6.6 Natural Laminar Flow Control - Nacelle............................................................................ 79
6.7 Hybrid Laminar Flow Control – Empennage..................................................................... 81
6.8 Hybrid Laminar Flow Control – Nacelle ............................................................................ 83

6.9 ECS Aerodynamic Cleanup and On-Demand ECS Scheduling ...................................... 85
6.10 Fuel Cell APU Replacement ......................................................................................... 87
6.11 Control Surface – Optimal Control Laws for Horizontal Stabilizer Trim ....................... 89
6.12 Gap Reductions & Aerodynamic Cleanup on Slats/Spoilers/Ailerons/ etc................... 91
6.13 Reducing Profiles of Lights, Antennae, Sensors, etc. .................................................. 93
6.14 Aft Body Redesign for Aerodynamics ........................................................................... 95
6.15 Composites – Current State, Increased Application ..................................................... 97
7. Technology Readiness Level Definitions ................................................................................... 99
8. Introduction to Technology Response Database ..................................................................... 100
I. Preface
In February 2016, the International Civil Aviation Organization’s (ICAO) Committee on Aviation
Environmental Protection (CAEP) agreed on the first-ever international standard to regulate CO2
emissions from aircraft, and in March 2017, ICAO formally adopted this standard. Domestically,
the Environmental Protection Agency (EPA) could propose future aircraft greenhouse gas (GHG)
emission standard that are at least as stringent as ICAO’s CO2 standard. This report has been
composed for the US Environmental Protection Agency (EPA) to study the costs of developing
and implementing fuel burn or carbon dioxide (CO2)-reducing technologies on new in-production
aircraft as measured by ICAO’s CO2 metric. This report provides an overview of the ICAO CO2
aircraft metric and standard. Additionally, this report assesses if there will be any impact on the
US fleet from the ICAO CO2 aircraft standard relevant to new deliveries of in-production aircraft,
and any alternative scenarios, as well as costs for scenarios where aircraft may need a technology
response.
In a prior project for EPA, ICF gathered data on some 70 technologies from a combination of
public sources and confidential interviews, then applied a detailed methodological framework (or
expected value methodology) to develop projected CO2 metric values and costs. ICF leverages
the tool built under this prior project to perform the analysis described in this report, and the
methodologies can be referred to in appendices VIII.1. This report was prepared by Peter Zimm
and Kent Harli of ICF and Dr. Joaquim Martins of the University of Michigan.
II. Assessment of CO2 Reducing Technologies
1. Introduction
1.1 Growth of Aviation-Produced CO2 and the International Response

In 2012, global aircraft CO2 emissions were 2% of total global aggregate CO2 output, 1 (and 13%
of global transportation CO2 emissions in 2011 2 , which is the most recent year that global
transportation CO2 emissions data is available). Aircraft CO2 emissions are receiving increasing
scrutiny because they have steadily increased due to fleet growth and higher aircraft utilization.
Globally, civil aircraft generated an estimated 1.44 trillion pounds 3 of CO2 in 2012. Commercial
air transport aircraft—encompassing the Very Large Aircraft, Large Twin Aisle, Small Twin Aisle,
Single Aisle, and Regional Jet aircraft categories—generated approximately 96% of this total 4.
Furthermore, ICF estimates global commercial air transport CO2 output will increase at 3.5% per
annum over the next 10 years 5, rising to 1.8 trillion pounds in 2021. The air transport aircraft
categories will continue to produce the most CO2 output, and the production of two categories in
particular—Single Aisle and Large Twin Aisle—will outpace overall CO2 emissions growth.
In response to this issue, in February 2016, the tenth meeting of the International Civil Aviation
Organization’s (ICAO) Committee on Aviation Environmental Protection (CAEP) – CAEP10 –
agreed on the first-ever international standard to regulate CO2 emissions from aircraft and, in
March 2017, ICAO formally adopted this standard. This standard applies to subsonic jet aircraft
having a maximum takeoff weight (MTOW) greater than 5,700kg (12,566lb) and to propeller-
driven multi-engine aircraft (e.g., turboprops) having MTOW greater than 8,618kg (19,000lb). 6
The Metric Value (MV) for the ICAO CO2 standard is based on an instantaneous measure of the
fuel burn per distance flown that is then adjusted by accounting for usable aircraft floor area.
Three test points are considered in the calculation of the MV for each aircraft, representing flight
at high, medium, and low gross weights. The fuel burn per unit distance of each aircraft is
1 ICF analysis.
2Climate Data Explorer of the World Resources Institute http://cait.wri.org. Accessed October 31, 2014. International Energy
Agency, Data Services http://data.iea.org. Accessed October 22, 2014
3 ICF analysis.
4 ICF analysis.
5 ICF analysis.
6 ICAO, 2016: Tenth Meeting Committee on Aviation Environmental Protection Report, Doc 10069, CAEP/10, 432 pp, AN/192,
Available at: http://www.icao.int/publications/Pages/catalogue.aspx (last accessed July 11, 2018). The ICAO CAEP/10 report is
found on page 27 of the English Edition 2018 catalog and is copyright protected; Order No. 10069.
evaluated at these three points and then averaged to obtain the MV. 7 A more detailed description
of the MV can be found in section IV.1. For the ICAO standard, the maximum allowed MV
increases with the maximum takeoff mass (MTOM) of the aircraft, according to a stringency
function. Furthermore, the implementation dates for the CO2 standard are 2020 or 2023 for new
type aircraft (depending on the MTOM for the aircraft) and 2028 for in-production aircraft. 8
Domestically, the EPA potentially could propose future aircraft CO2 standard that are at least as
stringent as the ICAO CO2 standard. For the EPA, this study projects the reductions in aircraft
metric value from incremental technology improvements and assesses the compliance position
of the aircraft models subject to the ICAO standard. We then project the technology responses
likely to be applied to those aircraft that are expected to fail the standard at the time of
implementation. In addition to the ICAO standard, ICF assesses aircraft compliance and
technology response under two additional scenarios: one in which the ICAO standard is effective
5 years earlier for in-production aircraft and one in which a more stringent standard is applied 5
years earlier than the ICAO standard. The implications of these scenarios are that in-production
aircraft may need to perform technology insertions or cease production to comply with the ICAO
standard.
1.2 Data Sources

As a specialized consultant in the field of aviation, ICF works across the aviation value chain –
from airlines and aerospace equipment makers to airports and investors. Specifically, in the
aerospace market, ICF provides aerospace thought leadership and comprehensive services. We
work with manufacturers and component original equipment manufacturers (OEMs) on
aftermarket strategies and assist buyers, sellers, and advisors with aerospace-related acquisition
targeting, commercial due diligence, and document preparation. More specifically, the essence
of the work we do spans across the following project types:
• Analyzing market fundamentals
• Developing business strategies
• Assessing interest in new products and services

• Conducting customer satisfaction assessments
• Benchmarking supply chain functions.
7 ICAO, 2016: Tenth Meeting Committee on Aviation Environmental Protection Report, Doc 10069, CAEP/10, 432 pp, AN/192,
Available at: http://www.icao.int/publications/Pages/catalogue.aspx (last accessed July 11, 2018). The ICAO CAEP/10 report is
found on page 27 of the English Edition 2018 catalog and is copyright protected; Order No. 10069. See Appendix C (starting on
page 5C-1) of this report.
8 The ICAO CO standard’s 2028 implementation date for in-production aircraft will be a production cut-off (in-production
2
aircraft that do not comply with the CO2 standard after this date cannot be built). Also, the ICAO CO2 standard has a 2023
implementation date for in-production aircraft with adverse CO2 emission changes or significant in-production type changes.
As we perform these projects for the largest clients in the industry, we continually develop up-to-
date analyses and maintain our in-house databases that translate years of proprietary data in
areas such as aircraft and equipment production forecasts and raw material demand projections
into analysis for expansion, capital allocation, and other strategic decisions. Therefore, we
constantly draw from the following resources:
• Secondary research into industry published articles, white papers, scientific papers
• Primary research with market experts
• Domain knowledge from past work/engagements and ICF Internal Cost and Performance
Models
• Benchmark databases, industry conferences, and latest industry news & announcements.
Therefore, all the analyses that are laid out in this report incorporate the aforementioned
resources, synthesized with our constant internal dialogue within our team of aerospace senior-
level aviation experts and aerospace industry contacts that validate the credible results that we
produce.
1.2.1 Secondary Research
Secondary research provided a wealth of information about individual technologies and ongoing
research programs. This was captured in the industry press, supplier and Original Equipment
Manufacturer (OEM) press releases, conference proceedings, and news articles. University
publications and websites also provided much information.
1.2.2 Market Interviews
ICF conducted a broad and thorough market interview program to gather feedback on technology
performance, modeling approach and methodology, and commercial feasibility. Over 40
interviews were conducted with a wide cross-section of key individuals from throughout the
industry – airframe, engine, and systems manufacturers, aircraft operators, and university and
research organizations provided input and feedback on methodology, technology performance,
and costs.
Current and former employees were interviewed from the following organizations:
Organizations Interviewed
• Aerion • Bombardier • PATS Aircraft Systems

• Aerodynamic Solutions • GE • Pratt & Whitney
• Airbus • Honeywell • Rolls-Royce

• Aloft AeroArchitects • Mitsubishi • Volvo
• ATR • MTU • United Airlines
• Boeing • NASA • United Technologies
Furthermore, the titles of the interviewees for this study spanned across multiple area of
expertise:
Titles of Interviewees
• Advanced Structures – • Head of Research and • SVP Operations & Supply

Core Engineering Technology Chain
• Chief Technology Officer • Head of Engines and • SVP Strategy
Systems Technology
• Director, Project • Airframe Programs
Engineering • [OEM] Technical Fellow Technical Assistant
• Director, Strategic • Principal Design Engineer • Vice President (VP)
Technology Engineering
• Senior Engineer
• Executive Vice President • VP Strategic Marketing
• Senior Vice President
(EVP), Commercial
(SVP) Engineering • VP Technology &
Programs
Environment
• Federal Aviation
Administration (FAA)
Designated Engineering
Representative
• Head of Product Strategy
1.2.3 Domain Knowledge and ICF Internal Cost and Performance Models
The ICF team was able to leverage knowledge gained through past consulting engagements, as
well as cost and performance models that had been developed to support market knowledge and
ongoing project work. In some cases, knowledge was available from in-depth cost and
performance models used for particular technologies.
1.2.4 Benchmark databases, industry conferences, and latest industry news &
announcements
The ICF team also drew our information from various benchmark databases that were published
by other market experts. Additionally, ICF team members regularly attend industry conferences
in which industry experts attend and discuss the latest trends in the market. Finally, the ICF team
is always up to date on the latest industry news & OEM announcements.
Through a combination of these sources, ICF was able to create comprehensive profiles of both
the fuel burn impact and cost of a wide variety of technologies.
III. Executive Summary

The purpose of this report is to evaluate the cost to implement CO2 -reducing technologies on in-
production aircraft to reduce aircraft CO2 metric values (MVs).
ICAO metric values originated from CAEP10 agreements for developing the CO2 standard.
Despite ICAO metric value data being the official dataset that underpinned the development of
the CAEP10 CO2 standard, the dataset is not available in the public domain due to ICAO’s data-
sharing restrictions. Therefore, this report uses PIANO (Project Interactive Analysis and
Optimization) data so that our analysis results may be shared publicly. Metric values developed
utilizing PIANO data are similar to ICAO metric values.
This study leverages a model ICF built for the EPA in 2012-2015. That study examined the impact
of the CO2 standard to new in-production aircraft. In particular, it assessed the technological
improvements to new in-production aircraft that are feasible, and the potential CO2 emission
reductions that could result. We updated the assumptions in the 2012-2015 model, re-ran the
CO2 emission reduction projections, and compared the forecasted aircraft emissions with the
respective stringency levels and the implementation dates, which will be elaborated in detail in
section VI.2. Finally, we projected the non-recurring engineering costs of realizing the projected
CO2 emission reductions that the OEMs have to undertake to improve the metric value.
Furthermore, we evaluated compliance to three scenarios:
• Scenario 1 is the ICAO CO2 standard and its production cut-off date is 2028. 9
• Scenario 2 pulls ahead the Scenario 1 production cut-off date to 2023. In addition, Scenario
2 delays the production cut-off date to 2028 for dedicated freighters.
• Scenario 3 implements a tighter stringency level, pulls ahead the production cut-off date to
2023, and delays the production cut-off date to 2028 for dedicated freighters.
Using PIANO MV baselines and ICFs MV forecast model, ICF forecasted metric values of over
120 aircraft models for upcoming years. First, we computed the gap between each aircraft MV
and its respective stringency level in each of the three different scenarios. To compute the gap,
we started with the projected MV to the stringency enforcement year, and subtracted the
stringency line value for the corresponding MTOM for all three scenarios. We then filtered out the
aircraft models that are projected to end their production before the standard goes into effect
(again, by scenario). Aircraft models meeting the standard were filtered out next, leaving those
models which fail the standard for at least one of the scenarios.
The result of the analysis is two aircraft failed at least one stringency scenario:
9 The ICAO CO standard’s 2028 implementation date for in-production aircraft will be a production cut-off (in-production
2
• The A380 does not comply with scenario 3 with a MV gap of 3.24%
• The 767F does not comply with scenarios 2 or 3 with MV gaps of 7.91% and 15.67%,
respectively.
• There are no aircraft that fail scenario 1.

For those aircraft that do not comply with a scenario, an additional 1% design margin above the
shortfall to the stringency level of the scenario needs to be achieved. This design margin is
expected in order to ensure the technology addresses the shortfall to the standard (actual CO2
reduction for a given technology is variable).
The A380 does not comply with scenario 3 10 with a MV gap of 3.24% -- so it requires a technology
response. Adding the 1% design margin, the technology response must total to 4.24% in
expected MV improvement. Furthermore, we assume the original equipment manufacturer
(OEM) would have implemented Advanced Wingtip Devices and Engine Technologies in the
course of achieving the metric value reductions projected by the smoothed forecast. Doing so
would in fact mean that 1.71% of excess reductions would already have been achieved, leaving
1.53% of reductions to be achieved through technology response. Adding the 1% design margin,
the net target becomes 2.53%. The most economical solution is for A380 to implement Adaptive
Trailing Edge if design margin is not required but, Adaptive Trailing Edge and ECS Aero if design
margin is required. The non-recurring cost to implement these improvements are $493M and
$580M, respectively.
The 767-3F will fail stringency scenario 2 at its stringency level and production cut-off date (2023)
with a smoothed forecasted metric value gap of 7.91%. Considering the large metric value gap
that 767-3F has, and that 2023 is the final year of production for the aircraft model, it is likely that
767-3F will pull forward its final year of production by a year (to 2022) to avoid mandatory
technological insertion. This response would be much less costly than the investment required
to implement technology response sufficient to address such a large MV gap.
The 767-3F will fail stringency scenario 3 at its stringency level and production cut-off date (2023)
with a smoothed forecasted metric value gap of 15.67%. Considering the large metric value gap
that 767-3F has, and that 2023 is the final year of production for the aircraft model, it is likely that
767-3F will pull forward its final year of production by a year (to 2022) to avoid mandatory
technological insertion. This response would be much less costly than the investment required
to implement technology response sufficient to address such a large MV gap.
ICF then analyzed further potential freighter stringency year delays that may be applied to non-
compliant freighter aircraft models and low-production-volume exemptions that may be applied to
the non-compliant aircraft models. The analysis showed that the delay of the production cut-off
date to 2028 for dedicated freighters in scenarios 2 and 3 will enable the 767F to avoid a
10 As described later in section VI, Scenario 3’s stringency levels (SLs) for in-production aircraft > 60 tons MTOM range from
SL 8 to SL9. The A380 complies with SL8, but not SL9. The A380 has a MV gap of 3.24% to SL9.
mandatory accelerated technological insertion due to the aircraft being out of production by the
later implementation date. For low-production-volume exemptions, ICAO will publish a set of
criteria after CAEP11 meeting, and therefore the methodology will not be outlined in this report.
However, A380 and 767F both will qualify for this low-volume-exemption.
Finally, ICF analyzed in-development freighter aircraft and forecasted their potential CO2
compliance. Based on ICF’s forecast, both upcoming in-development freighter aircraft (A330neoF
and 777XF) will both pass the three scenarios without any issues.
IV. Aircraft Metric Values
1. Introduction
The ultimate purpose of this report is to evaluate the cost of reducing aircraft CO2 emissions,
which are proportional to fuel burn. ICF began its analysis by evaluating the impact of
technologies on relative fuel burn reductions.
However, the CAEP certification procedure does not use fuel burn directly, but instead, defines a
metric system or Metric Value (MV) that is related to fuel burn. The metric system or MV is
developed to equitably reward advances in aircraft technologies that contribute to reductions in
aircraft CO2 emissions. 11
The MV is defined based on an instantaneous measure of fuel burn per distance flown and
represents an attempt to develop a metric that correlates with fuel burn, while being independent
of aircraft type, weight and utilization. The MV is based on the specific air range (SAR), which is
an instantaneous measure of the distance flown per unit weight of fuel. The MV is obtained by
inverting SAR (which yields the fuel weight required to travel a unit distance), and then dividing it
by a non-dimensionalized floor area raised to an exponent, resulting in the following equation: 12
1
𝑀𝑀𝑀𝑀 =
𝑆𝑆𝑆𝑆𝑆𝑆 × (𝐴𝐴𝐹𝐹 ⁄𝐴𝐴𝑅𝑅 )0.24
where 𝐴𝐴𝐹𝐹 is the floor area, and 𝐴𝐴𝑅𝑅 is a reference area related to the fuselage platform.
Since SAR depends on the instantaneous weight, which varies during flight (i.e., weight reduces
as fuel is burned) and has a wide range depending on the mission. SAR can vary by as much as
a factor of 2 for a given aircraft. Given this wide range of variation, the MV is highly dependent
on the weight used in its calculation. To address this issue, CAEP defined three weight values
over which the MV should be averaged to obtain a final value that is representative. 13
When converting fuel burn reductions to reductions in the MV, ICF assumed that the MV is based
on SARs at a representative set of weights. Therefore, a 1% fuel burn reduction corresponds to
1% MV reduction.
11 ICAO, 2016: Tenth Meeting Committee on Aviation Environmental Protection Report, Doc 10069, CAEP/10, 432 pp,
AN/192, Available at: http://www.icao.int/publications/Pages/catalogue.aspx (last accessed July 11, 2018). The ICAO CAEP/10
report is found on page 27 of the English Edition 2018 catalog and is copyright protected; Order No. 10069. See Appendix C
(starting on page 5C-1) of this report.
12 Ibid.
13 Ibid.
One important characteristic regarding the MV is that reductions in aircraft empty weight 14 would
not impact the MV. The rationale for this was that any reduction in empty weight would be
canceled out by a corresponding increase in payload, fuel, or both. Thus, even though weight
saving technologies and improvements increase the aircraft efficiency, this is not reflected in the
MV. 15 Therefore, ICF post-processed all the fuel burn reductions to remove the reductions due to
weight by individually analyzing each technology and assessed the magnitude of fuel burn
reduction that is caused by aerodynamic improvements and weight savings respectively. Across
technologies, about 2/3 of the fuel burn impact is reflected in the MV, although this varies
depending on the technology and the aircraft category.
2. Metric Value Data Sources – PIANO

ICAO metric values originated from CAEP10 agreements for developing the CO2 standard.
Despite ICAO metric value data being the official dataset that underpinned the development of
the CAEP CO2 standard, the dataset is not available in the public domain due to ICAO’s data-
sharing restrictions. Therefore, this report uses PIANO (Project Interactive Analysis and
Optimization) data so that our analysis results may be shared publicly. Metric values developed
utilizing PIANO data are similar to ICAO metric values.
The PIANO metric value database is a professional tool for various design/performance analysis
on commercial aircraft, including environmental emissions assessment. 16 PIANO uses an
identical formulation as ICAO to derive metric value, except that it draws on various industrial and
academic sources instead of the confidential disclosures of the manufacturers. The PIANO
assumptions are derived partly from first principles (e.g. performance calculations), and partly
from classical, semi-empirical, semi-theoretical calculations. PIANO was developed by Lissys
LTD, a UK-based limited company that began the PIANO metric value database in 1990. PIANO
is currently utilized by more than 20 major aerospace organizations as a publicly available source
of data about airplane performance. The PIANO version utilized in this analysis was PIANO
version 5.4.
14Refers to Operating Empty Weight is the basic weight of an aircraft including the crew, all fluids necessary for operation such
as engine oil, engine coolant, water, unusable fuel and all operator items and equipment required for flight but excluding usable
fuel and the payload.
15 The metric value does not directly reward weight reduction technologies because such technologies are also used to allow for
increases in payload, equipage and fuel load. Thus, reductions in empty weight can be canceled out or diminished by increases in
payload, fuel, or both; and, this varies by operation.
16 PIANO is a software by Dr. Dimitri Simos, Lissys Limited, UK. It is available at www.piano.aero. This is a commercially
available aircraft design and performance software suite used across the industry and academia.
V. Metric Value Forecast
1. Introduction
This study leverages a model ICF built for the EPA in 2012-2015. That study examined the impact
of the CO2 standard to new in-production aircraft. In particular, it assessed the technological
improvements to new in-production aircraft that are feasible, and the potential CO2 emission
reductions they could produce. We updated the assumptions in the 2012-2015 model, re-ran the
CO2 emission reduction projections, and compared the forecasted aircraft emissions with the
respective stringency levels and the implementation dates. Finally, we projected the costs of
realizing the projected CO2 emission reductions.
2. Methodology
2.1 Short and Mid-Term Metric Value Impact Methodology (Years 2015-
2029)
For the 2012-2015 work, ICF developed a detailed methodological framework to analyze the
potential impact of new technology introduction on aircraft fuel efficiency and CO2 emissions as
shown in Exhibit 5.1.
Exhibit 5.1: ICF Technology Impact Methodology
This framework involved five basic steps that we utilized to forecast annual metric value
improvement for the upcoming short and mid-term where we are able to foresee the technologies
that are being implemented to in-production aircraft:
1.First, we identified the technologies that could reduce CO2 emissions from new in-production
aircraft
2.Second, we then assessed each technology for the magnitude of potential CO2 reduction
and the mechanisms by which reduction is achieved. Both were analyzed by aircraft size
category
3.Third, the technologies were passed through technical success probability
4.Fourth, the technologies were passed through commercial probability success screens
5.Last, individual aircraft differences were considered within aircraft category to develop a
CO2 emissions reduction forecast by technology by aircraft model
Detailed descriptions of the short and mid-term metric value reduction forecast can be found in
Appendix 1 (or section 1 of Appendices).
2.2 Long-Term Metric Value Impact Methodology (Years 2030-2040)

The methodology that is elaborated in the previous section is only applicable for the timeframe
in which we are able to recognize the technologies that are going to be implemented on in-
production aircraft (i.e. years 2015-2029). Therefore, to forecast long-term metric value
improvements beyond 2029, we need to derive an alternative methodology.
Because it is still highly uncertain as to what specific technologies will be feasible and ready for
implementation beyond 2029, we will need to utilize a parametric approach in deriving the long-
term forecast. This framework involved three steps that we utilized to forecast long-term annual
forecast metric value improvement:
1. First, for each aircraft type, we identified ten technical factors on three scoring
dimensions that drive fuel burn and metric value reduction impact and feasibility in the
long-term, and we then scored each aircraft type on a scale of 1 to 5 for each technical
factor and on each scoring dimension to arrive at an overall fuel burn reduction prospect
index.
2. Second, we analyzed the potential market factors for each aircraft type and derived
indices on a scale of 1 to 5 as an estimate for how much R&D will be put into each
aircraft type based on overall potential of each aircraft type’s future market.
3. Third, we coupled each aircraft type’s the market factor with their respective overall fuel
burn reduction index and derived an overall index score for their metric value
improvements. A low overall index score means that the aircraft type will experience
reduced annual metric value reduction, while a high overall index score means that the
aircraft type will experience accelerated annual metric value reduction.
Afterwards, we expanded our short/mid-term metric value improvement impact figures to the
end of the long-term forecast horizon (i.e. 2040) and applied the overall metric value
improvement index scoring derived by each aircraft type.
Detailed descriptions of the long-term metric value reduction forecast can be found in Appendix
2 (or section 2 of Appendices).
2.3 Technology Development Cost Methodology
ICF developed an independent, bottom-up non-recurring cost (NRC) cost model for implementing
minor (0-10% metric value) improvements on existing aircraft platforms. First, we categorized the
incremental technologies into impactful-ness groupings – either as Minor PIPs (performance
improvement packages) or as Large Incremental Updates. Next, we identified the elements of
non-recurring cost. Third, we developed baseline non-recurring cost element proportions by
incremental technology category for single-aisle aircraft. Then, we scaled the baseline NRC
elements to the other aircraft size categories. Next, we determined the NRC costs for single aisle
aircraft and applied the scaled costs to the other aircraft size categories. Lastly, we compiled
technology supply curves by aircraft model.
Detailed descriptions of the technology development cost methodologies can be found in
3. Updates to 2015 Assumptions
3.1 Technology and Cost Assumptions Updates

ICF reviewed the 2015 model assumptions and conducted research to validate them. A number
of technologies had been inserted on aircraft that had entered service since the 2015 report so
they now had actual service histories (natural and hybrid laminar flow in particular). We also
reviewed the outcomes of major design changes (i.e., re-engine, re-wing). Lastly, even though
they were studied in the 2012-2015 effort, weight reducing technology assumptions were not
updated in this analysis. Despite reducing overall emissions driven by less aircraft fuel burn, the
weight-reducing technologies do not affect the CAEP metric value (CAEP metric value is
independent of aircraft type, weight, and utilization).
ICF updated the following assumptions in the metric value forecast analysis based on the results
of our research:
1. Engine technologies: Increased fuel burn reducing impact and increased commercial
feasibility. We did this because we found that engine OEMs were constantly pushing the
frontier to incorporate these technologies. Put another way, it appears adopting these
engine technology improvements is a high priority.
2. Riblet coatings: Increased technical feasibility. For example, Airbus and Lufthansa are
already experimenting with shark skin coatings and British Airways is experimenting with
coatings on transatlantic A318s.
3. Hybrid laminar flow control – empennage: Decreased commercial feasibility and
increased recurring cost. Boeing is reviewing the drag benefits of Hybrid laminar flow
control on the 787. As a result of the current wing shape and several other factors, the
technology isn’t producing the sweet spot balance of cost/performance as initially
expected.
3.2 Methodology Updates

Either based on validation research or to address new requests from EPA, ICF made the following
modifications to metric value forecast methodology:
1. Analysis extended to aircraft variant level (i.e. beyond aircraft family level): The
analysis in the 2015 report was done at the aircraft family level (e.g., 737 family).
Therefore, to determine the compliance of each in-scope aircraft model (e.g., 737-700,
737-800, etc.), ICF applied the forecasted aircraft family metric value reductions to the
base year metric value of each aircraft model.
2. Continuous technology benefit applicability assessment to more precisely model
technology applicability for new project aircraft 17: Typically, new project aircraft will
have lower baseline metric values compared to legacy aircraft, due to having more
advanced technologies implemented within the initial launch of the aircraft. As a result,
there will be fewer incremental improvements available from future technologies for new
project aircraft. Due to the addition of a number of new project aircraft into the analysis,
ICF modified the technology applicability matrix from analyzing each technology in a
binary manner (i.e. technology can only be fully applicable or fully un-applicable), to a
continuous manner so that partial impacts of technologies could be applied to new aircraft
models (i.e. percentage magnitude of a fuel burn impact will each technology provide).
4. Results/Forecast
As elaborated in the methodology section, the metric value forecast is derived through
approximating incremental annual metric value improvement, and applying those annual
improvements to a baseline metric value. To derive each year’s cumulative metric value reduction,
ICF took the following approach:
17 “Project Aircraft” are aircraft that were in development by manufacturers at the time this report was completed.
Metric value reduction = Technology applicability percentage * commercial feasibility factor *

probability of technical success * Average MV benefit of technology by aircraft type
Using this approach and using PIANO data, ICF projected metric values for 125 in-scope aircraft
models for the 2015-2029 time period using the short/mid-term methodology (as elaborated in
section V.2.1), and for the 2030-2040 time period using the long-term methodology (as elaborated
in section V.2.2). Results for years 2015, 2018, 2020, 2023, 2028, 2030, and 2040 are shown in
VI. Stringency Implications
1. Introduction
In this section, we compute the gaps between the forecasted MV for the various aircraft and the
corresponding stringency standard for each aircraft model at the time the standard goes into
effect. We then identify in-production and project aircraft that are expected to fail to meet the
stringency requirements. For those aircraft that are expected to fail the standard, we analyze the
potential technology responses that would bring them into compliance. Lastly, in addition to
evaluating the ICAO CO2 standard stringency scenario, we considered two alternative scenarios:
one scenario in which the ICAO standard are implemented 5 years earlier for in-production aircraft
and one scenario in which a more stringent standard is applied 5 years earlier.
2. Stringency Scenarios
CAEP considered and analyzed 10 different stringency levels (SLs) for both in-production and
new type standard, comparing aircraft with a similar level of technology on the same stringency
level. These levels were generically referred to numerically from ‘‘1’’ (the least stringent) to ‘‘10’’
(the most stringent). 18 For the CO2 standard that were ultimately adopted by ICAO, the new-type
and in-production stringency levels for smaller and larger aircraft were adopted at different levels
to reflect the range of technology being used and the availability of new fuel burn reduction
technologies that vary across aircraft of differing size and weight. Exhibit 6.1 provides a brief
overview of the implementation dates and stringency levels of the ICAO CO2 standard.
18 ICAO, 2016: Tenth Meeting Committee on Aviation Environmental Protection Report, Doc 10069, CAEP/10, 432 pp,
AN/192, Available at: http://www.icao.int/publications/Pages/catalogue.aspx (last accessed July 11, 2018). The ICAO CAEP/10
report is found on page 27 of the English Edition 2018 catalog and is copyright protected; Order No. 10069. See Appendix C
(starting on page 5C-1) of this report.
Exhibit 6.1: Stringency Levels and Implementation Dates for International Aircraft CO2 Emission
Standard
Aircraft Weight New-Type Aircraft

In-Production
(MTOM) Thresholds Maximum Permitted
Aircraft Maximum
(KG) CO2 Level
Permitted CO2
Level
Stringency Level >5,700 to <60,000 SL5 19 SL3 20
60,000 to ~ 70,000 SL5-SL8.5 2122 SL3-SL7 2324
> ~70,000 SL8.5 25 SL7 26
Implementation Date Application for a new- 2020 2023

type certificate or a
change to an existing- (2023 for planes with
type certificate less than 19 seats)
Production Cut-Off n/a 2028
𝟐𝟐
−𝟐𝟐.𝟕𝟕𝟕𝟕𝟕𝟕𝟕𝟕𝟕𝟕+ �𝟎𝟎.𝟔𝟔𝟖𝟖𝟖𝟖𝟖𝟖𝟖𝟖𝟖𝟖 ∗ 𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)�+ �−𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 ∗ �𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)� �
19 The stringency equation for SL5 is the following: 𝑴𝑴𝑴𝑴 = 𝟏𝟏𝟏𝟏
𝟐𝟐
−𝟐𝟐.𝟓𝟓𝟓𝟓𝟓𝟓𝟓𝟓𝟓𝟓 + �𝟎𝟎.𝟔𝟔𝟔𝟔𝟔𝟔𝟔𝟔𝟔𝟔𝟔𝟔 ∗ 𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)�+ �−𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 ∗ �𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)� �
21The stringency level for the standard starting at 60,000 kilograms maintains the level of SL5 and continues to increase until it
intersects the SL8.5 at 70,000 kilograms (MTOM).
22 The stringency equation for new type transition in between 60,000kg to 70,395kg is the following: 𝑴𝑴𝑴𝑴 = 𝟎𝟎. 𝟕𝟕𝟕𝟕𝟕𝟕
23The stringency level for the standard starting at 60,000 kilograms maintains the level of SL3 and continues to increase until it
intersects SL7 at 70,000 kilograms (MTOM).
24 The stringency equation for new type transition in between 60,000kg to 70,107kg is the following: 𝑴𝑴𝑴𝑴 = 𝟎𝟎. 𝟕𝟕𝟕𝟕𝟕𝟕
𝟐𝟐
−𝟐𝟐.𝟕𝟕𝟕𝟕𝟕𝟕𝟕𝟕𝟕𝟕+ �𝟎𝟎.𝟔𝟔𝟔𝟔𝟔𝟔𝟔𝟔𝟔𝟔𝟔𝟔 ∗ 𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)�+ �−𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 ∗ �𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)� �
25 The stringency equation for SL8.5 is the following: 𝑴𝑴𝑴𝑴 = 𝟏𝟏𝟏𝟏
𝟐𝟐
−𝟏𝟏.𝟑𝟑𝟑𝟑𝟑𝟑𝟑𝟑𝟑𝟑 + �−𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 ∗ 𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)�+ �𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 ∗ �𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)� �
26 The stringency equation for SL7 is the following 𝑴𝑴𝑴𝑴 = 𝟏𝟏𝟎𝟎
CO2 adverse or
significant in-
production type n/a 2023
changes 27
We summarize the ICAO scenario and the two alternative scenarios in Exhibit 6.2.
Scenario 1 is the ICAO CO2 standard. The stringency lines for this scenario are shown in Exhibits
6.3 and 6.4 for in-production aircraft. The production cut-off date for this standard is 2028.
Scenario 2 pulls ahead the Scenario 1 production cut-off date to 2023. In addition, Scenario 2
delays the production cut-off date to 2028 for dedicated freighters.
Scenario 3 implements a tighter stringency level, pulls ahead the production cut-off date to 2023,
and delays the production cut-off date to 2028 for dedicated freighters.
We analyze the results of these three scenarios in the next section.
27 The ICAO CO2 standard’s 2028 implementation date for in-production aircraft will be a production cut-off (in-production
Exhibit 6.2: Stringency Scenarios
Scenario Option Description
• New Type SL8.5 (SL5 for aircraft < 60 tons) 2020
o (SL5 for aircraft < 60 tons and < 19 seats 2023)

ICAO (as agreed at
1 • In Production SL7 (SL3 for aircraft < 60 tons) 2028
CAEP/10)
• 2023 for CO2 adverse or significant in-production type
changes
Pull Ahead Some • Move in-production standard or production cut-off date to 2023
2 In-Production (2025 for aircraft < 60 tons)
Dates • Delay production cut-off date to 2028 for dedicated freighters
Pull Ahead Some

New Type and In- • New Type SL9 (SL6 28 for aircraft < 60 tons) 2020
Production
• In Production SL8 29 or SL9 30 2023 31 (SL5 for aircraft <60 tons,
3
Dates and More 2025 32)
Stringent
• Delay production cut-off date to 2028 for dedicated freighters
Levels
𝟐𝟐
−𝟐𝟐.𝟖𝟖𝟖𝟖𝟖𝟖𝟖𝟖+ �𝟎𝟎.𝟕𝟕𝟕𝟕𝟕𝟕𝟕𝟕𝟕𝟕𝟕𝟕∗ 𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)�+ �−𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 ∗ �𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)� �
28 The stringency equation for SL6 (<60 tons) is the following: 𝑴𝑴𝑴𝑴 = 𝟏𝟏𝟏𝟏
𝟐𝟐
−𝟏𝟏.𝟒𝟒𝟒𝟒𝟒𝟒𝟒𝟒𝟒𝟒+ �−𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎∗ 𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)�+ �𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 ∗ �𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)� �
30The stringency equation for SL9 is the following: 〖𝑴𝑴𝑽𝑽 = 𝟏𝟏𝟏𝟏〗^(−𝟏𝟏. 𝟒𝟒𝟒𝟒𝟒𝟒𝟒𝟒𝟒𝟒 + (−𝟎𝟎. 𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 ∗ 𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴)) +
(𝟎𝟎. 𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 ∗ (𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍𝒍(𝑴𝑴𝑴𝑴𝑴𝑴𝑴𝑴))^𝟐𝟐 ) )
31 Move production cut-off date to 2023 for aircraft > 60 tons MTOM.
32 Move production cut-off date to 2025 for aircraft < 60 tons MTOM
3. Stringency Lines
MV varies with aircraft maximum take-off mass (MTOM) and mission range. Thus, we cannot
apply a single MV stringency value for all aircraft. ICAO adopted a stringency function that is
dependent on MTOM. Ideally, a fair MV stringency would also account for the range that an
aircraft is capable of within their MTOM category. However, aircraft range is strongly correlated
with the MTOM. The result was the following stringency option function:
2�
𝑀𝑀𝑀𝑀𝑆𝑆𝑆𝑆 = 10�𝐶𝐶0 +𝐶𝐶1 log10 (𝑀𝑀𝑀𝑀𝑀𝑀𝑀𝑀)+𝐶𝐶2 log10 (𝑀𝑀𝑀𝑀𝑀𝑀𝑀𝑀)
This is a second order log curve whose coefficients were tuned to match the trends of MVs for
actual aircraft.
For in-production aircraft, ICAO adopted SL3 for MTOMs under 60,000 kg and to SL7 for MTOMs
over 70,107 kg, with a constant MV value of 0.797 for MTOMs between 60,000 kg and 70,107 kg.
This results in the curve shown in Exhibits 6.3 and 6.4, which shows that most aircraft models are
already passing the stringencies. Aircraft models that have stringency gaps will be elaborated
upon further in section VI.4.
Exhibit 6.3: Stringency lines for the three scenarios 33,34
33 (Scenario 1 in red, Scenario 2 in blue, and Scenario 3 in green). Note that the lines for scenarios 1 and 2 are identical, since
they only differ in the enforcement year. Scenario 3 is shown as a range between SL8 and SL9. Three MV values are plotted for
each aircraft, corresponding to the values for each scenario’s enforcement year. Note that the values for Scenarios 2 and 3 are
the same since they have identical enforcement years.
34 In Exhibits 6.3 and 6.4, Scenarios 1 and 2 have a constant metric value or stringency level for MTOMs between 60,000 kg and
70,107 kg. Consistent with the 10 stringency levels that ICAO/CAEP considered, Scenario 3 has a varying stringency level in
this same MTOM range or a kink point at 60 tons MTOM. The results of aircraft affected by Scenario 3 do not change with
either having a constant stringency level between 60 tons and 70.107 tons or instead having a kink point at 60 tons MTOM.
Exhibit 6.4: Detail of Stringency lines for aircraft below 100 metric tons of MTOM
4. Stringency Gaps
Using PIANO MV baselines and ICFs MV forecast model, ICF forecasted metric values of over
120 aircraft models for upcoming years as shown in Appendix 4 (or section 4 of Appendices).
First, we computed the gap between each aircraft MV and its respective stringency level in each
of the three different scenarios. To compute the gap, we started with the projected MV to the
stringency enforcement year, and subtracted the stringency line value for the corresponding
MTOM for all three scenarios. We then filtered out the aircraft models that are projected to end
their production before the standard goes into effect (by scenario). Aircraft models meeting the
standard were filtered out next, leaving those models, which fail the standard for at least one of
the scenarios.
The aircraft models failing the standard in at least one of the scenarios are listed in Exhibit 6.5.
This figure depicts the computed percentage gap relative to the corresponding stringency line
(yellow line), for scenarios 1 (red), 2 (blue) and 3 (green). A zero value for scenario 1 in Exhibit
6.5 means that the aircraft is projected to end its production before the stringency standard goes
into effect. A negative value in Exhibit 6.5 means that the aircraft meets the stringency standard
of a given scenario, and a positive value indicates that it does not meet the stringency level. Dots
to the right of yellow line show that an aircraft is not meeting a stringency level of a scenario.
(Note, scenario 3 includes both SL8 and SL9 for in-production aircraft greater than 60 tons, hence
there are two columns for this scenario. The first column under scenario 3 represents SL8, and
the second column is for SL9.)
Exhibit 6.5: Gap to stringency scenario for aircraft models that fail the stringency when using
PIANO database MVs.
VII. Technology Response for Failed Aircraft
1. Modeling Metric Value Reduction
1.1 Implementation of Metric-Value-Improving Technology versus

Smoothed Forecast
There is an important distinction to bear in mind for the technical response discussion below. The
metric value reduction forecast is an expected value calculation; it is a projection of the annual
fuel burn improvement from all the technologies that will be implemented on each aircraft. As a
result, it is expressed in terms of a constant annual improvement in metric value. We know that
original equipment manufacturers (OEMs) work to develop and implement incremental
technology improvements, but we don’t know the timing of the investment or implementation of
the improvements aircraft model to aircraft model. Rather than attempt to discretely project
improvements by aircraft, we consider the potential improvement by aircraft family implemented
over a given time frame, and project reductions in terms of a smoothed forecast.
In contrast, for those aircraft requiring a technical response (i.e., failing to meet the standard and
expected to remain in production), ICF constructed supply curves that plot the expected benefit
(CO2 emission reduction) of a given technology against its expected development cost. The result
is an ordinal ranking of the incremental technologies by aircraft family, from most cost effective to
least cost effective, expressed as a supply curve. For the purpose of determining technical
response, ICF assumes the manufacturer will invest in and implement the most cost effective
technologies first and proceed to the next most cost effective technology next to achieve their
incremental metric value improvements projected by the metric value reduction forecast.
However, in contrast to the smoothed forecast described above, once the new technology is
implemented, there is a step change in the metric value reduction; in other words, metric value
reductions are realized all at once (instead of gradually) when the technology is implemented.
So, from the base year to the year the standard goes into effect (e.g., from 2010 to 2025), the
metric value reduction forecast projects a given reduction (e.g., 6.25% in Exhibit 7.1 below).
However, for this example, in order to achieve that level of reduction, the manufacturer will have
implemented Advanced Wingtip Devices and Engine Technologies, for a total of 7.7% in metric
value reductions. Thus, while the smoothed forecasted reduction is 6.25%, the implemented
reductions are actually higher because the actual technology benefit is fully realized at once when
technology is implemented. A representative metric value improvement and its associated non-
recurring cost data points by aircraft category is shown in Appendix 5 (or section 5 of Appendices),
while each individual technology’s non-recurring costs and fuel burn benefit are shown in the
technology profiles in Appendix 6 (or section 6 of Appendices).
Exhibit 7.1: Incremental Improvement Technology Insertion Analysis Methodology
We applied the following methodology in order to derive the implemented metric value
improvement that relates to the smoothed forecast:
1. For a given future year, a manufacturer’s technology insertion is assumed to have
progressed up the supply curve (i.e. technologies with largest improvement and most
economical cost are implemented first). Therefore, these economical technologies
would have already been implemented by the stringency year, and will not be available
for future investment.
2. We overlay the smoothed forecasted incremental metric value improvement by the

stringency year on the aircraft model’s discrete supply-curve. From this overlay, ICF
identifies the most economical technologies that would already have been implemented
by the stringency year.
3. The remaining technologies not yet implemented are available for accelerated
investment should a technology response be needed. For each in-scope aircraft model,
ICF analyzed technology responses using PIANO data.
1.2 1% Additional Design Margin for Non-Compliant Aircraft

For those aircraft that do not comply with the stringency standard, an additional 1% design margin
above the shortfall to the stringency needs to be achieved. This design margin is expected in
order to ensure the technology addresses the shortfall to the standard (actual CO2 reduction for
a given technology is variable).
2. PIANO Data Based Technology Response

Using PIANO metric values and ICF’s metric value reduction forecast, ICF compared the
forecasted Metric Values of each aircraft model to the stringency standard in the year the standard
goes into effect to derive the gap between the expected performance of the aircraft model to the
standard. This section identifies those aircraft models which are expected to fail the standard in
the three scenarios, identifies the technology responses available to the manufacturer to bring
the aircraft into compliance, and explores any exemptions that may apply to the non-compliant
aircraft.
2.1 Regulatory Non-compliance by Scenario

Based on PIANO data, the following aircraft models are non-compliant to the standard at their
respective stringency years in at least one of the scenario options:
Exhibit 7.2: Aircraft Non-Compliance by Scenario
Scenario 1 Scenario 2 Scenario 3
Metric Metric Metric

Aircraft
Compliance Value Compliance Value Compliance Value
Model
Gap Gap Gap
A380 Out of
Production -1.79% to
(-842 / N/A Pass -3.69% Fail
3.24%
-861) (by 2028)
Out of
Production 10% to
767-3F N/A Fail 7.91% Fail
15.67%
(by 2028)
In-scope aircraft not listed on this table pass all stringency scenario requirements.
2.2 Technology Response by Aircraft by Scenario
2.2.1 A380 (-842 / -861)
Exhibit 7.3: A380 Incremental Improvement Technology Supply Curve
Scenario 1
The A380 will be out of production by scenario 1’s stringency year (2028), therefore no technology
response is required. As the A380 fleet is retired, ICF expects its routes will be taken over by the
A350XWB and the 777.
Scenario 2
The A380 passes scenario 2’s metric value stringency requirement by -3.7%, therefore no
technology response is required.
Scenario 3
The A380 passes scenario 3 SL 8, but fails SL 9 by 3.24% -- so it requires a technology response.
Adding the 1% design margin, the technology response must total to 4.24% in expected MV
improvement. Furthermore, we assume the OEM would have implemented Advanced Wingtip
Devices and Engine Technologies in the course of achieving the metric value reductions projected
by the smoothed forecast. Doing so would in fact mean that 1.71% of excess reductions would
already have been achieved, leaving 1.53% of reductions to be achieved through technology
response. Adding the 1% design margin, the net target becomes 2.53%. The most economical
solution is for A380 to implement Adaptive Trailing Edge if design margin is not required but,
Adaptive Trailing Edge and ECS Aero if design margin is required. The non-recurring cost to
implement these improvements are $493M and $580M, respectively (see Exhibit 7.4 below).
1% Design Margin Implementation on A380
Exhibit 7.4: A380 Scenario 3 – 1% Design Margin Implementation Compared To No Design Margin
No Design Margin 1% Design Margin
% Gap to MV Standard 3.24% 4.24%
Residual Implemented MV Improvement (1.71%) (1.71%)
Technology Response Improvement Target 1.53% 2.53%
2.00% of A380 2.00% of A380

Technology Response: Adaptive Trailing Edge
baseline MV baseline MV
0.63% of A380
Technology Response: ECS Aero N/A
baseline MV
Non-Recurring Cost to Implement Technology

$493M $580M
Response
Recurring Costs of Technology Response

For the aircraft operators, ICF anticipates there would be very low and possibly no recurring
costs associated with incorporating these technologies (e.g., additional maintenance, material,
labor, and tooling costs) due to these technologies having relatively similar recurring cost
requirements and characteristics to existing equivalent technologies. This is driven by the fact
that technologies need to be economically feasible for the operators to implement and/or utilize.
Technologies that are not able to be economical will not be adopted by the operators.
Furthermore, given that the aircraft has already had trailing edges and ECS implemented with
their respective recurring cost, the new technologies implemented must not have additional
significant recurring cost, due to an existing cost benchmark. In other words, if the new
implemented technologies were to add significant recurring cost, operators would likely object to
them being added.
2.2.2 767-3F
Exhibit 7.5: 767 Incremental Improvement Technology Supply Curve
Scenario 1
The 767-3F is out of production by scenario 1’s stringency year (2028), therefore no technology
response is required. As the 767 freighter fleet retires, ICF expects its routes will be taken up by
A330 and 777 freighters.
Scenario 2
According to the incremental improvement metric value forecast, 767-3F will fail stringency
scenario 2 at its stringency year (2023) with a smoothed forecasted metric value gap of 7.91%.
Considering the large metric value gap that 767-3F has, and that 2023 is the final year of
production for the aircraft model, it is likely that 767-3F will pull forward its final year of production
by a year (to 2022) to avoid mandatory technological insertion. This response would be much
less costly than the investment required to implement technology response sufficient to address
such a large MV gap.
Scenario 3
According to the incremental improvement metric value forecast, 767-3F will fail stringency
scenario 3 at its stringency year (2023) with a smoothed forecasted metric value gap of 15.67%.
Considering the large metric value gap that 767-3F has, and that 2023 is the final year of
production for the aircraft model, it is likely that 767-3F will pull forward its final year of production
by a year (to 2022) to avoid mandatory technological insertion. This response would be much
less costly than the investment required to implement technology response sufficient to address
such a large MV gap.
1% Design Margin Implementation on 767-3F
Exhibit 7.6: 767 Scenarios 2 & 3 – 1% Design Margin Implementation Compared To No Design
Margin
Scenario 2 Scenario 2 Scenario 3 Scenario 3

No Design 1% Design No Design No Design
Margin Margin Margin Margin
% Gap to MV Standard 7.91% 8.91% 15.67% 16.67%
Residual Implemented MV
(2.29%) (2.29%) (2.46%) (2.46%)
Improvement
Technology Response
5.61% 6.61% 13.22% 14.22%
Improvement Target
Technology Response N/A N/A N/A N/A
Non-Recurring Cost to
Implement Technology N/A N/A N/A N/A
Response
For Scenarios 2 and 3, technology response to address such a large MV gap on 767-3F is
prohibitively expensive; adding a 1% design margin potentially adds even more expense.
2.3 2028 Freighter Delay

Under stringency scenarios 2 and 3, selected freighter aircraft may be allowed to have their
stringency years delayed to 2028. Therefore, ICF conducted an additional analysis to estimate
the effects of this potential delay on the compliance of the in-scope freighter aircraft.
Exhibit 7.7: Freighter Aircraft Stringency Delay to 2028 Analysis for Scenarios 2&3 (stringency
year 2023)
As shown in Exhibit 7.7, all but one (767-3ERF) of the in-scope freighters will be out of
production by 2023. Therefore, delaying the stringency year for freighter aircraft will have
minimal benefit to the manufacturers. Aircraft that go out-of-production will leave behind active
in-service fleets. We expect that the aircraft listed in Exhibit 7.7 above could be replaced with
the newer freighter aircraft shown in Exhibit 7.8:
Exhibit 7.8: Potential Future Freighter Aircraft Replacement
Freighter Aircraft Model Replacement Freighter Aircraft
A330-2F A330neo freighter
747-8F 777X freighter
767-3ERF A330neo freighter / 777X freighter
777-2LRF 777X freighter
Exhibit 7.8 shows that current freighter variants retiring in the future will be replaced with
A330neo or 777X freighters. Section VII.2.5 analyzes these in-development freighter aircraft for
their compliance to the stringency standard.
2.4 Low Volume Exemption
2.4.1 Introduction to Low Volume Exemption
For the CO2 standard, ICAO agreed to provide flexibility for certain aircraft with low volume
production. Thus, if by the implementation date a non-compliant aircraft is still in production, it
may be exempt from having to meet the ICAO standard (and thus, having to make mandatory an
accelerated technological insertion). This exemption will be dependent upon two main factors:
1.Total aircraft left to be produced (per type certificate)
2.Magnitude of the aircraft model’s metric value margin to the regulatory standard
The specific exemption criteria were agreed to at the CAEP Steering Group in December 2016,
which was after the CAEP10 meeting in February 2016, and it is not yet available to the public in
the form of a published ICAO document. (These specific criteria are expected to be available to
the public after the CAEP11 meeting in February 2019.) Thus, this report will only generally
describe the exemption criteria.
2.4.2 Low Volume Exemption for In-Scope Aircraft based on PIANO Data
Exhibit 7.9: Aircraft Production Forecast Beyond Stringency Years
Total
Aircraft End of Production
Type Production 2023 2024 2025 2026 2027 2028 2029 2030 Beyond
Certificate Year Stringency
Year
A380 2025 12 35 12 12 0 0 0 0 0 36
767 2023 10 0 0 0 0 0 0 0 10
As shown in Exhibit 7.9, ICF first developed an aircraft production forecast for aircraft models that
have metric value gaps against stringency requirements to determine the possibility of qualifying
for a low volume exemption. The far right column sums the number of aircraft left to be produced
during and after the stringency year. This sum is then compared to the low volume exemption
aircraft production threshold.
35 Dark grey cells refer to stringency years
Exhibit 7.10: Aircraft Low Volume Exemption by Scenario
Total Scenario 1 Scenario 2 Scenario 3

A/C
Production End of
Type
Beyond Prod. PIANO Low Low Low
Certifi Exempt. PIANO Exempt. PIANO Exempt.
Stringency Year MV Volume Volume Volume
cate Quantity MV Gap Quantity MV Gap Quantity
Year Gap Exempt. Exempt. Exempt.
A380 36 2025 N/A N/A N/A N/A N/A N/A 3.24% 61 Qualify
767 10 2023 N/A N/A N/A 7.91% 42 Qualify 15.67% 15 Qualify
Exhibit 7.10 depicts the production beyond stringency year against low volume exemption
thresholds for those cases when there is a gap to the stringency standard. Both aircraft are out
of production before Scenario 1 goes into effect. 767F qualifies for the low volume exemption in
Scenario 2 and both A380 (both models) and 767F will qualify for the low volume exemption under
Scenario 3 because the total aircraft production beyond their stringency years are below the
exemption quantities.
2.5 In-Development Freighter Aircraft Analysis

To analyze the compliance of in-development freighter aircraft, namely A330neo and 777X
freighter variants, ICF mainly utilized a historical benchmarking analysis approach:
1. ICF compared the baseline metric values for previous generation passenger variants
against their freighter variants
2. ICF determined the baseline metric values for in-development freighter aircraft based on
the analyzed previous generation and current metric value of passenger versions of in-
development freighter aircraft (i.e. A330neo and 777X passenger versions)
3. ICF assumed comparable year-over-year metric value improvements for in-development
freighter variants to its passenger variant
4. ICF derived annual metric values based on derived baseline metric value and year-over-
year metric value improvements
Exhibit 7.11 A330neoF and 777XF stringency compliance
Exhibit 7.11 shows the results of the analysis using the above methodology. ICF expects that
both A330neo and 777X freighter variants will be compliant with all the stringency scenarios.
VIII. Appendices
1. 2015 Technology Impact Model Methodology
1.1 Introduction
ICF developed a detailed methodological framework to analyze the potential impact of new
technology introduction on aircraft fuel efficiency and CO2 emissions. This framework involved
five basic steps. First, we identified the technologies that could reduce CO2 emissions of new in-
production aircraft. Second, we then assessed each technology for the magnitude of potential
CO2 reduction and the mechanisms by which reduction is achieved. Both of these were analyzed
by aircraft category. Third and fourth, the technologies were passed through technical success
probability and commercial probability success screens, respectively. Last, individual aircraft
differences were considered within aircraft category to develop a CO2 emissions reduction
forecast by technology by aircraft model. This entire methodological framework detailed above
will be referred to henceforth as the expected value methodology.
Exhibit 8.1. ICF Technology Impact Methodology
ICF additionally identified and evaluated some 70 engine and airframe technologies for their ability
to reduce CO2 emissions 36 on new, in-production aircraft. Select critical technologies are further
profiled in Appendix 6.
36 Or fuel burn. The terms are used interchangeably throughout this report.
37
Exhibit 8.2. ICF Airframe & Systems Technologies List37
Airframe Technologies
Aerodynamic Structural Systems
• Adaptive Trailing Edge • Advanced Metals • Lightweight Lightening

• Advanced Wingtip • Increased Composite Strike Protection
Devices Application • More Electric Systems
• Variable Camber Trailing • Advanced Composites • On demand
Edge (non-retrofittable) Environmental Control
• Re-Wing (non- • Re-Wing (non- Systems (ECS)
retrofittable) retrofittable) • Fuel cell Auxiliary Power
• Riblet Coatings • Advanced Configurations Unit (APU)
• Laminar Flow Control (non-retrofittable) • Light interior
− Natural and Hybrid • Titanium Landing Gear • Fly By Wire
− Nacelle, Empennage, • Lightweight Paint / • Carbon brakes

and Wing Surface Treatment • Zonal Drying
• Advanced Configurations • Control Surface
(non-retrofittable)
• Environmental Control
System (ECS) Inlet 38
• Gap Reductions
• Aft Body Redesign
• Light Profile
37 Please refer to Appendix 6 for more information on these technologies

38 ECS Inlet and On Demand ECS are analyzed in aggregate
Exhibit 8.3. ICF Engine Technologies List

Engine Technologies
Materials Architecture Systems
• Titanium Aluminide (TiAl) • Ultra High By • Bleedless engines

turbine airfoils Pass(UHBP) engine • Electric engine start
• TiAl compressor airfoils (above 10 Bypass Ratio
• High Pressure
(BPR))
• Ceramic-matrix Compressor (HPC) mod.
composites (CMC) • UHBP (above 20 BPR) Clearance control
turbine shrouds/ Outer Air • Open rotor • Turbine mod. Clearance
Seal (OAS) • Variable cycle control
• CMC High Pressure • Intercooled compressors • Clearance control w/
Turbine (HPT) blades/ feedback
• Integrated propulsion
vanes
system • High Pressure (HP)/LP
• CMC Low Pressure (LP) power extraction sharing
• Lightweight component
blades/ vanes
fab techniques • High eff. Oil/air cooler
• Organic Matrix
• Reduced hub-tip ratio fan • Recuperative exhaust
Composite (OMC) fan
• Fan drive gear
blades
• Next gen load sharing
• OMC case
architecture
• CMC exhaust nozzle
• Ceramic bearings
• Turbine coatings
• OMC stator
• OMC comp. cases
Aerodynamics Sealing Coating / Cooling
• Next gen engine airfoil • Compressor blisks • Compressor airfoil

designs • Turbine blisks coating
• Optimized fan root fairing • Turbine air cooling air
• Scalloped fan exhaust cooling
• Low Pressure Ratio (PR) • Next gen. turbine airfoil
fan cooling design
• Low drag inlet/nacelle
1.2 Magnitude and Sources of Historical CO2 Reductions

Since the advent of gas turbine engine powered air transport in 1958, aircraft fuel efficiency has
improved about 1.5% per annum through a combination of major redesigns and incremental
improvements 39. Major redesigns refer not only to completely redesigned aircraft, but also to
significant partial redesigns – redesigned wings (re-winging) and re-engine-d aircraft. Incremental
improvements are less extensive changes to the production standard of the aircraft, such as
winglets or performance improvement packages (PIPs) that are introduced into airframes or
engines mid-life. ICF research indicates that major redesigns account for as much as two-thirds
of historical fuel burn reduction. By implication, incremental improvements account for about one-
third of reductions, or about 0.5% per year. Furthermore, it appears more of the incremental
reductions in recent times are due to improvements in aerodynamics than in engines. In contrast,
engine technology has been the primary driver of major redesign aircraft efficiency improvements.
Secondary research and interview input point to a 0.8 to 1.0% annual improvement in engine
efficiency from major redesign technology while incremental improvements yield about 0.2%
better fuel burn per annum.
1.3 The Nature of Technology Insertion

Major redesigns yield large fuel burn reductions – 10% to 20% over the prior generation they
replace. As one might expect, the significant fuel burn reductions of major redesigns do not
happen frequently. One of the best examples of this is the Boeing 737 program. Debuting in
1968 with two variants and powered by low bypass JT8D engines, the airplane has undergone
major redesigns three times – they entered service in 1984, 1998, and will enter in 2017,
respectively, or about every 16 years.
39 ICF analysis
Exhibit 8.4. Major Redesign History of the Boeing 737
Insofar as we are going through a wave of major redesign and service entry now, prospects for
further step-function improvements will be low in the coming 10-15 years. The outlook for major
redesigns is described below in the Exhibit 8.5:
Exhibit 8.5. Outlook for Major Redesigns by Aircraft Category
Photo Example Aircraft Entry Into

Major Redesign Major Redesign Outlook
Category Service
This category is experiencing

Very 747-100 (1969) 747-400 (1989) sluggish sales.
Large A380 (2007) 747-8 (2011) No other major redesign until
after 2025.
777-200LR 777-9X (2020)

Large
777-200/300 (2004) 777-8X (2020)
Twin
(1995) A350-900 No other major redesign until
Aisle
(2015) after 2030
Small 767 (1982) A330neo (2017)

767-400ER
Twin A330 (1994) No other major redesign until
(2000)
Aisle 787-8 (2011) after 2030
CS100 (2015), CS300 (2016)

A320neo (2015)
737MAX (2017)
C919 (2018)
737-100 (1968) 737 Classic
Single MS-21 (2018)
A320 (1988) (1984)
Aisle The decision by Boeing and
737NG (1998)
Airbus to re-engine the 737 and
A320 will delay introduction of a
major redesign western single-
aisle until well beyond 2025
The regional jet category was
ripe for new major redesigns
CRJ-100 ARJ21 (2015)
Regional (1992) CRJ-700 (2001) MRJ (2017)
Jet E 170 (2004) Embraer E2 (2018)
Major redesigns can be
expected in the 2025-2030
timeframe
Contrary to all other aircraft size

segments, business jets
Large Gulfstream
G550 (2004) undergo frequent minor
BGA40 V(1995)
changes and somewhat
frequent major redesigns
Contrary to all other aircraft size

segments, business jets
Small Learjet 40/45 Learjet 70/75
undergo frequent minor
BGA (1998) (2013)
changes and somewhat
frequent major redesigns
Saab 2000
Saab 340 (1994) Major redesign expected by
Turbo-
(1983) ATR 72 (1989) early 2020s, ATR 90 41 turboprop
prop
Q400 (1997) ATR 42 (1985) derivative possible before then
Q400 Next Gen
Furthermore, increasingly, technologies developed for major redesigns eventually make their way
onto mature aircraft – first technologies are researched to technology readiness level (TRL) 6, 42
then they are incorporated into development programs where they are thoroughly tested and
developed for applications on the aircraft. Lastly, they can be chosen to be incorporated into a
PIP 43 on an existing aircraft. Finally, new development cycles are very lengthy. It is not unusual
for new aircraft and engine designs to take 8-10 years to develop, from preliminary design to entry
into service.
40 BGA = Business and General Aviation

41 ATR 90 refers to the ATR 90-seater turboprop.
42 Technology readiness level 6 represents when the system/subsystem model or true dimensional test equipment is validated in a
relevant environment. See the technology readiness section of the appendices for more information. A full list of TRL definitions
can be referenced in appendix VIII.7
43 Occasionally, PIP’s are referred to at technology insertion packages or TI’s.
If past trends continue into the future, we can expect:
• Overall fuel efficiency to improve by 1.5% per annum
• Major redesign activities will contribute about two-thirds of this improvement; incremental
technology introductions will reduce emissions by 0.5% per annum
• Engine technologies will drive major redesign aircraft improvements but aerodynamics will
be a larger contributor of incremental improvements
• Major redesign activity will be infrequent and will not be seen for 10-15 years for most
aircraft categories after the current redesign wave has passed
• Technologies researched and developed during the current wave of major redesign
aircraft will be ripe for incorporation onto existing mature platforms (i.e., new in-production
aircraft)
• The coming drought of major redesigns means incremental improvements to new in-
production aircraft will be the primary lever for CO2 reductions for the next 10-15 years.
2. Long-Term Technology Impact Model Methodology
2.1 Introduction
ICF developed a parametric approach to forecast annual improvement in outbound years of the
metric value forecast based on primary fuel burn reducing factors and differentiated by aircraft
type. This long-term forecast methodology is appropriate for the outbound forecast years
because the short/mid-term forecast methodology is based on predicting metric value
improvements contributed by specific existing technologies that are implemented, and we
predict that around the 2030 timeframe a new round of technology implementation will begin
that will require us to reassess the forecasting method. The methodology will consist of deriving
1-5 scoring indices that will correspond to high scores being favorable outcome, while low
scores being unfavorable outcome. The results of this parametric approach will be in forms of
multiplier indices, which are used to determine if the rates of short/mid-term annual metric value
improvements are accelerated or decelerated based on each aircraft type for the outbound
years of the forecast. A high overall scoring index will correspond to an accelerated metric value
improvement rate and a low index will correspond to a decelerated metric value improvement
rate (relative to an extrapolated short/mid-term annual metric value improvement).
2.2 Methodology overview

ICF developed the following methodology to estimate the accelerated/decelerated rate of annual
metric value improvement in outbound forecast years (i.e. 2030-2040) relative to short/mid-term
annual metric value improvement:
1. Identify the elements of fuel burn technology factors, and determine fuel burn reduction
prospect scoring index for each technology factor, with a 1-5 scoring for each aircraft
type
2. Determine the long-term market prospect scoring index, with a 1-5 scoring based on the
amount of potential R&D that will be conducted on various technologies for each aircraft
type
3. Based on combining fuel burn reduction prospect scoring index and long-term market
prospect scoring index, determine overall metric value improvement acceleration index
that will indicate the amount of acceleration/deceleration of annual metric value
improvement rate
2.3 Derive fuel burn reduction prospect index

We firstly identified the technology factors that primarily contribute to fuel burn. The following
factors drive the fuel burn in each technology that is typically implemented in each aircraft:
• Weight: The lighter the aircraft, the less fuel it will typically burn if everything else stays
the same. However, for reasons elaborated in sections IV.1 and V.3.1 of this report, we
are excluding weight-reducing factors in this analysis.
• Sealing: Imperfect air sealing in the engine leads to leaking that decreases the engine
efficiency (especially in the engine compressor) that ultimately increases the fuel burn.
• Propulsive efficiency: This is the portion of the kinetic energy added to the air that
contributes to thrust. (Not to be confused with the overall propulsive efficiency, which is
the product of the propulsive efficiency and the thermal efficiency). Increasing bypass
ratio is the main way to increase propulsive efficiency and thus reduce fuel burn.
• Thermal efficiency: This is the efficiency with which the chemical energy of the fuel is
converted into mechanical power. The main way to increase the thermal efficiency is by
increasing the turbine entry temperature.
• Reduced cooling: To cool the hotter parts of the engine, bleed air is taken from the
engine compressor stage. This leads to a loss that on its own increases the fuel burn,
but contributes to increasing the thermal efficiency by making it possible to increase the
turbine entry temperature (see above).
• Reduced power extraction: Bleed air is also commonly used for other aircraft systems
(anti-icing, cabin pressurization, pneumatic actuators, etc.). In addition to power
extraction through bleeding air, shaft power may be extracted through electric
generators to power aircraft systems. The lower the power extraction, the lower the fuel
burn.
• Induced drag reduction: This type of drag is induced by the generation of lift. For a
given lift, this can be reduced by optimizing the distribution of pressures on the wing
through aerodynamic shaping, increasing wing span, and adding wing tip devices. The
lower the induced drag, the lower the fuel burn.
• Friction drag reduction: This type of drag is due to mechanical friction of the air with
the aircraft surface. This can be reduced by reducing the exposed area, improving
surface finishing, and through aerodynamic shaping. The lower the friction drag, the
lower the fuel burn.
• Profile drag reduction: This type of drag is due to flow separation that causes a
turbulent wake where energy is dissipated. Profile drag can be reduced by aerodynamic
shaping.
Afterwards, we took the technology factors and scored each of them on three scoring
dimensions that we believe will drive the overall fuel burn reduction effectiveness in the
outbound forecast years. The three scoring dimensions include:
• Effectiveness of technology in reducing fuel burn
• Likelihood of technology implementation
• Level of research effort required
Out of these three scoring dimensions, we believe that effectiveness of technology in reducing
fuel burn and level of research effort required will be the predominant drivers in the technical
factors. These two factors are most important because the effectiveness of technology in
reducing fuel burn would most incentivize the OEMs to pursue the research, while level of
research effort will dictate how economically feasible the technology is. Therefore, we assigned
heavier weightings onto those two factors (40% weight each) than likelihood of implementation
(20% weight) in our assessment. We then averaged the scoring of each technical factors on the
three dimensions to derive an overall fuel burn reduction prospect index.
2.4 Derive market driver index

We then derived market driver indices for each aircraft type. This assessment is based on
where we believe the market will shift towards in the outbound years, and therefore the amount
of research & development that OEMs will conduct will also be weighted towards where the
market is headed. We believe that the market will be more focused on improvements of single
aisle and small twin aisle aircraft types, and less focused on large quad aircraft. We believe that
especially engine OEMs will be able to produce more efficient engines in upcoming years that
will enable more point-to-point travel that will reduce the need for large quad aircraft, and will
drive more market demand for single aisle and small twin-aisle aircraft. Furthermore, we believe
that with current year developments being heavy on re-engine improvements, there will be
much potential for an airframe redesign in the next round of technological improvement that we
believe will be due in early 2030s. Business jets, turboprops, and regional jet aircraft types will
grow somewhat slower than average. We expect these categories of aircraft to be relatively
stagnant in the outbound years and will grow somewhat slower compared to in the recent past.
We expect highest growth on single aisle and small twin aisle aircraft size categories.
2.5 Derive overall metric value improvement acceleration index

Lastly, we will combine the fuel burn reduction prospect index with the market driver index for
each aircraft type to determine the overall metric value improvement acceleration index. A
scoring of 1 translates to a 60% improvement rate relative to extrapolated short/mid-term annual
metric value improvement, a scoring of 3 translates to a continued extrapolated short/mid-term
annual metric value improvement, and a scoring of 5 translates to a 140% improvement rate
relative to extrapolated short/mid-term annual metric value improvement. We are putting slightly
more weight onto the technological factors with 65% scoring weight, compared to market factors
with 35% scoring weight. This weighting is appropriate because despite fuel burn prospects
being the biggest consideration for OEMs, how the overall market is evolving (i.e. more single
aisle aircraft) will affect how the OEMs allocate their research efforts.
We then expanded our short/mid-term metric value improvement impact figures to the end of
the long-term forecast horizon (i.e. 2040) and applied the overall metric value improvement
acceleration index scoring derived by each aircraft type.
2.6 Example: Narrowbody Long-Term Metric Value Forecast

To derive the overall metric value improvement acceleration index, we firstly derived initial
scorings for each technical factors for the single aisle aircraft type as shown in exhibit 8.6.
Exhibit 8.6. Single Aisle Fuel Burn Reduction Prospect Index Scoring
Likelihood of
Effectiveness Level of
implementation Fuel Burn
Single Aisle Technical in reducing Research Effort
in new Reduction
Factors: fuel burn (1-5) Required (1-5) 44
technology (1-5) Prospect Index
[40%] [40%]
[20%]
Weight N/A N/A N/A N/A
Sealing 1 2 4 2.4
Propulsive efficiency 3 3 2 2.6
Thermal efficiency 3 3 2 2.6
Reduced cooling 3 3 3 3
Reduced power extraction 3 3 3 3
Reduced thermal management 3 3 3 3
Induced drag reduction 5 4 1 3.2
Friction drag reduction 5 4 1 3.2
Profile drag reduction 1 2 3 2
Overall Fuel
Burn Reduction 2.78
Prospect Index:
We believe that for single aisle, it is likely that there will be a new clean sheet design that will
enable considerable aerodynamics improvement that will reduce drag, as well as latest engine
technologies to supplement the new aircraft design that will have the latest engine technologies.
Therefore, there are a lot of potential from fuel burn effectiveness and likelihood of
implementation standpoints. However, because of the efforts required, there will be risks
associated with achieving the improvement. This rationale drove to an overall fuel burn
reduction prospect index that is slightly decelerated solely from a technical standpoint.
On the other hand, we also identified that the single aisle market will be flourishing in the long-
term as there will be more point-to-point travel with the availabilities of fuel-efficient
technologies. Therefore, we believe that the market driver index for single aisle is very favorable
with a scoring of 5, because we believe that OEMs will focus its research efforts onto this
flourishing market.
44 For level of research effort required, 5 indicates the least amount of effort required (favorable), and 1 indicates the most
amount of effort required (unfavorable)
Combining the fuel burn reduction prospect index and the market driver index, we arrive at a
metric value improvement acceleration index of 3.56 as shown below:
Fuel Burn Metric Value
Reduction Improvement
Market Driver Index [35%]
Prospect Index Acceleration
[65%] Index
5 2.78 3.56
This score of 3.56 indicates that single aisle metric value improvement will be accelerated faster
than an extrapolated short/mid-term metric value improvement rate. Following the linear
regression of a scoring of 1 indicating 60% annual metric value decelerated improvement rate
and a scoring of 5 indicating a 140% annual metric value accelerated improvement rate, a
scoring of 3.56 indicates that annually, single aisle will annually accelerate at a rate of 111%.
This annual metric value accelerated improvement rate figure is then incorporated into the
extrapolated short/mid-term MV forecast for the appropriate aircraft models.
2.7 Long-Term Replacement Aircraft Analysis (Replacement Aircraft

circa 2030-2040)
2.7.1 Historical Aircraft Emissions Performance

To understand how aircraft emissions will improve in the long-term, we firstly performed a
historical benchmarking analysis. In this analysis, we found that every 15 to 25 years after entry
into service, aircraft models typically go through major redesigns that are driven by
aerodynamics or engine efficiency improvements that drive down fuel burn. These major re-
designs typically yield large fuel burn and MV reductions – 10% to 20% over the prior
generation they replace, depending on the type of redesign. There are three types of major
aircraft redesigns: redesigned engines (re-engine), redesigned wings (re-wing), or clean sheet
development.
Exhibit 8.7. Historical Example of OEM-Realized Step Change Improvement in Fuel Burn 45
Last
Replace- Model to
Aircraft First Replace-
Aircraft Redesign ment Design Replace-
Size Aircraft Model ment
OEM Type Aircraft Duration ment Fuel
Category EIS Aircraft
EIS Burn
Reduction
Clean
Widebody Boeing 767-300 1986 787-900 2014 28 20%
Sheet
Narrowbody
Clean
/Regional Airbus A319 1996 CSeries 2016 20 22%
Sheet
Jet
Large Quad Boeing 747-400 1989 747-8 Re-Wing 2011 22 16%
737
737 Classic
Original
Narrowbody Boeing 1968 (-300/400/ Re-Wing 1984 16 20%
(-
500)
100/200)
737
737 Next
Classic
Generation
Narrowbody Boeing (- 1984 Re-Wing 1998 14 15%
(-600/700/
300/400/
800/900)
500)
Regional
Embraer E175 2004 E175-E2 Re-Wing 2021 17 16%
Jet
Regional
Embraer E190 2005 E190-E2 Re-Wing 2018 13 16%
Jet
Narrowbody Airbus A320 1988 A320neo Re-Engine 2015 27 15%
737 Next
Generati
737MAX
Narrowbody Boeing on (- 1998 Re-Engine 2017 19 13%
(-7/8/9/10)
600/700/
800/900)
Exhibit 8.7 demonstrates historical examples major re-design improvements that have been
realized and published by each of the aircraft OEMs. As shown above, clean sheet re-designs
have historically produced approximately 20+%, re-wing have historically produced
approximately 15-20%, while re-engine have historically produced approximately 10-15%.
Additionally, our research indicates that major redesigns account for as much as two-thirds of
historical fuel burn reduction, and a lot of these step change improvements are due to engine
technologies. Despite the OEMs not publishing strictly MV improvement values, the majority of
fuel burn improvements consist of aerodynamic improvements as opposed to weight reductions,
and therefore we expect the MV improvement values to be similar.
45 OEM publications
2.7.2 Long-term metric value forecast

Based on this historical analysis, ICF then analyzed potential long-term replacement aircraft
based on extrapolating the design transitions, metric value improvement step-down per aircraft
generation, and timing of aircraft design transition. Analyzing these factors, we derived potential
long-term aircraft replacements that current/new generation aircraft will transition into in the
outbound years of the forecast. We have identified the potential aircraft replacements as shown
in exhibit 8.8
Exhibit 8.8. Long-Term Potential Replacement Aircraft

MV Uncertainty
Market Aircraft Estimated Improvement Band (+/-)
Category Type 2030-2040 Replacement EIS Estimate
Air Transport Large Quad No direct replacement. N/A N/A N/A
Large Twin beyond
Air Transport Aisle 777X 2040 N/A N/A
Small Twin Re-wing or re-engine small twin
Air Transport Aisle aisle late 2030 ~15% 3%
Air Transport Single Aisle Clean sheet aircraft early 2030 ~20% 4%
Air Transport Regional Jet Re-wing regional jet early 2030 ~10% 2%
Re-wing or re-engine turboprop
Air Transport Turboprop aircraft early 2030 ~10% 2%
Air Transport Freighter A330neo or 777X freighter late 2020 N/A N/A
Re-wing or re-engine large
BGA Large BGA business jet early 2030 ~10% 2%
Re-wing or re-engine small
BGA Small BGA business jet early 2030 ~10% 2%
We also utilized the historical analysis as a basis to determine the long-term aircraft
replacement, in which we analyzed two main factors: historical re-design type and aircraft size.
We analyzed the historical re-design type to figure out what re-designs were employed in the
aircraft’s recent iteration and utilized that conclusion to predict the future re-design type. We
also analyzed the size class to determine the seat class and aircraft type that will replace the
existing aircraft.
Detailed rationale, results, and commentary on the long-term replacement and reference aircraft
analysis can be found in EPA’s Technology Response Database. In that document, we
analyzed the long-term replacement aircraft for all in-scope models, as well as forecasted an
estimate MV for these long-term replacement aircraft based on available MV of reference
aircraft, grouped by aircraft type and OEM. Further details on the background and detailed
elaboration of the technology response database’s purpose is shown in appendix VIII.8
Furthermore, due to the uncertain nature of the long-term forecast, we have also included
uncertainty bands in determining the metric value improvement estimates. These uncertainty
bands vary by the magnitude of design improvement that we expect by aircraft type. The more
rigorous the design improvement, the larger the uncertainty band. For example, designing a
clean sheet aircraft will yield a higher potential metric value improvement, but there are more
risks associated with achieving the design improvement; hence a larger uncertainty band. A re-
engine design improvement has less risk associated with the improvement; hence a smaller
uncertainty band.
3. 2015 Development Cost Model Methodology
3.1 Introduction
ICF developed an independent bottom-up cost curve especially focused on categorizing the non-
recurring cost of implementing minor (0-10% metric value) improvement on existing aircraft
platforms. This area is of particular importance for determining the costs of compliance with a
number of proposed stringency options, and was also an area neglected by previous non-
recurring cost (NRC) methodologies. The results of the ICF curve were a supply-curve of available
technology options and associated non-recurring costs for each aircraft platform. For most
aircraft, this methodology was limited to predicting improvements in the 0-10% range. Also, ICF’s
research indicated that, given the lack of verifiable publically available cost data for small metric
value improvements, it would be most effective to create bottom-up technology applicability and
cost analyses by aircraft model, and then validate these through case studies, secondary
research, and targeted interviews.
3.2 Methodology Overview
ICF developed the following methodology to estimate the non-recurring costs (NRC) by aircraft:
1. Categorize incremental technologies into groupings by impactful-ness – either Minor PIP or
Large Incremental Update
2. Identify the elements of non-recurring cost
3. Develop baseline NRC element proportions by incremental technology category for single-
aisle aircraft
4. Scale the baseline NRC elements to the other aircraft categories
5. Determined the NRC costs for single aisle aircraft and applied the scaled costs to the other
aircraft categories
6. Compiled technology supply curves by aircraft model
3.3 Categorizing Incremental Technologies
Incremental technologies fall into two categories: minor PIPs and large incremental updates.
Minor PIPs are aerodynamic cleanups (e.g., redesigned fairings, APU inlets, ECS exhausts, etc.)
and other improvements that often can be certified by analysis without dedicated flight test aircraft,
and with only minor ground, wind tunnel, and flight tests. Minor PIP costs scale only incrementally
with aircraft size. Most of the technologies ICF researched were minor PIPs, providing in the
range of 0-2% fuel burn improvement.
Large incremental updates are significant aerodynamic or structural improvements (e.g., winglets)
that require flight test programs – usually with production aircraft. These types of improvements,
singly or grouped into a large package, can provide from 2-10% fuel burn reduction. Tooling and
facilities costs are not driving factors for these improvements. Large incremental upgrades scale
highly with aircraft size.
3.4 Elements of Non-Recurring Cost
Non-recurring cost is fundamentally driven by three elements: engineering and integration,

testing (flight and ground) and tooling, capital equipment, and infrastructure. Engineering and
Integration (Engrg) includes the engineering and Research & Development (R&D) required to
progress a given technology from its current TRL so it can be integrated onto a production
airframe. It also includes all airframe and technology integration costs.
Flight and Ground Testing (Testing) includes fixed costs for test instrumentation, infrastructure,
and program management and variable costs 46 related to the degree of flight and ground testing
required.
Tooling, Capital Equipment, and Infrastructure (Capital) includes tooling required to modify the
production line to support the PIP, incorporates any capitalized changes to plant, property, and
equipment, and includes other miscellaneous costs such as Information Technology (IT) system,
supply chain system, and other costs associated with a particular design change.
3.5 Baseline Non-Recurring Cost Element Proportions
For incremental technologies applicable to single aisle aircraft, the proportion of engineering and
integration, flight and ground testing, and tooling, capital equipment, and infrastructure varies
depending on whether it is an airframe or an engine technology and, for airframe technologies,
whether the technology is a minor PIP or a large incremental update. Exhibit 8.9 illustrates the
cost element proportions for single aisle aircraft. In general, engine PIP development costs are
heavily driven by both flight and ground testing. This includes the cost of test hardware, recurring
flight and ground test costs, test engineering and analysis, and the like. Small airframe PIPs, on
the other hand, are dominated by engineering costs. This is because small airframe PIPs
generally do not require a dedicated flight testing program. Therefore, costs are concentrated on
the engineering design and analysis required to analytically verify the safety and performance of
the PIP. Large airframe PIPs do require a flight test program, and therefore have a large portion
of their total costs allocated to the testing effort.
46 Variable costs refer to the costs of flight and ground testing that scale with the amount of time spent testing. For instance, fuel
costs and crew/test engineer salaries directly scale with the amount of time spent in flight and ground test.
Exhibit 8.9. Single Aisle NRC Cost Element Proportions
3.6 Non-Recurring Cost Scaling Factors
Non-recurring costs exhibit different scaling behavior with aircraft size. Engineering and
integration cost for a given technology and metric value improvement is not strongly correlated
with aircraft size; rather, it scales with a 5% differential of aircraft complexity. ICF used aircraft
realized sale price to scale this element. Flight and ground testing scales with aircraft operating
costs. ICF used direct block hour average operating costs to scale this element. Lastly, for Minor
PIPs, tooling, capital equipment, and infrastructure costs are not strongly correlated with aircraft
size. As with engineering, average realized aircraft sale price was used to scale this element.
ICF used independently verifiable data to calculate the NRC scaling factors, shown in Exhibit
8.10. Average realized sale price is the scaling parameter used for Engineering, as well as for
Capital NRC. Average operating cost was used as the scaling parameter for Testing NRC.
Testing scales with 100% of the operating cost differential, using single aisle as the baseline.
Engineering and Capital scale by 15% of the differential in average realized sale price, using
single aisle as the baseline.
Exhibit 8.10. Aircraft Cost Element Scaling Factor Sources
Source: Block hour operating cost and averaged realized price data from The Airline Monitor
The end result was factors that were used to scale the cost elements in reference to the baseline
single aisle aircraft to every aircraft category, illustrated in Exhibit 8.11.
Exhibit 8.11. Non-Recurring Cost Element Scaling Factors
3.7 Considerations for Recurring Costs

In implementing new technologies, there is an implication that the new technology may entail
further costs, that may include additional maintenance, material, labor, and tooling. OEMs have
to keep this in mind when developing the technologies to ensure that there are low to none
recurring costs, or that the recurring cost requirements are similar to current technologies that
are being implemented. This report assumes that the technologies being implemented will be
able to meet these criteria and operators will be incentivized to implement the technologies.
3.8 Cost Calculations
Applying the scaling factors, NRC was calculated for every technology across every aircraft
category. An example is provided below.
3.9 Example: Large Incremental Update NRC (Wingtip Devices)

Wingtip devices are a “Large Incremental Update” –level technology. For the baseline single aisle
aircraft, total cost is composed of 3% baseline fixed costs, 52% engineering & integration, 40%
testing, and 5% capital equipment. The calculation assumes a minimum $5M fixed cost. (We
used this amount for all of the incremental upgrades. It does not vary by technology or aircraft
category.) This fixed cost is an allowance for basic program management overhead that
accompanies any level of design change at an aircraft OEM. An example of this approach in
practice is shown below in Exhibit 8.12, which in this case represents winglets. For this
technology, interview input and secondary research indicated a total non-recurring cost for winglet
implementation of $173M for single aisle aircraft. Given this known data point, ICF used the cost
element breakdown shown in Exhibit 8.10 above to split the total NRC into the constituent
elements. Note in Exhibit 8.11 below that Engineering and Capital NRCs exhibit only minor
scaling factors.
Exhibit 8.11. Large Incremental Update Cost Scaling by Aircraft Category
4. Table of Aircraft MV Forecast (PIANO Data)

The following table shows the aircraft metric value forecast by aircraft model utilizing PIANO baseline data. As the forecast year progresses,
we could observe that the metric values incrementally improve as new technologies are being introduced and retrofitted to the aircraft.
Market 2015 2018 2020 2023 2028 2030 2040
Aircraft Model Manufacturer Category Aircraft Type MV MV MV MV MV MV MV
A380-842 AIRBUS Air Transport Large Quad 2.9007 2.8582 2.8220 2.7665 2.6838 2.6495 2.5156
A380-861 AIRBUS Air Transport Large Quad 2.9007 2.8582 2.8220 2.7665 2.6838 2.6495 2.5156
B747-8 BOEING Air Transport Large Quad 2.5462 2.5096 2.4783 2.4303 2.3608 2.3317 2.2177
B747-8F BOEING Air Transport Large Quad 2.6503 2.6122 2.5796 2.5296 2.4573 2.4270 2.3084
A330-203 AIRBUS Air Transport Large Twin Aisle 1.6506 1.6264 1.6058 1.5742 1.5272 1.5068 1.4132
A330-2F AIRBUS Air Transport Large Twin Aisle 1.6258 1.6020 1.5817 1.5506 1.5042 1.4841 1.3920
A330-2F AIRBUS Air Transport Large Twin Aisle 1.6258 1.6020 1.5817 1.5506 1.5042 1.4841 1.3920
B777-200ER BOEING Air Transport Large Twin Aisle 1.9493 1.9257 1.9046 1.8723 1.8265 1.8060 1.7105
B777-200LR BOEING Air Transport Large Twin Aisle 2.1836 2.1572 2.1336 2.0974 2.0460 2.0231 1.9161
B777-300ER BOEING Air Transport Large Twin Aisle 2.1439 2.1179 2.0948 2.0592 2.0088 1.9863 1.8812
B777-2LRF BOEING Air Transport Large Twin Aisle 2.1846 2.1582 2.1346 2.0983 2.0470 2.0241 1.9170
A330-800-NEO AIRBUS Air Transport Large Twin Aisle 1.4700 1.4700 1.4585 1.4406 1.4156 1.4061 1.3632
A330-900-NEO AIRBUS Air Transport Large Twin Aisle 1.4410 1.4410 1.4297 1.4121 1.3877 1.3783 1.3363
B777-9x BOEING Air Transport Large Twin Aisle 1.7830 1.7830 1.7741 1.7483 1.7125 1.6987 1.6340
B777-8x BOEING Air Transport Large Twin Aisle 1.8210 1.8210 1.8119 1.7855 1.7490 1.7349 1.6688
B767-3ER BOEING Air Transport Small Twin Aisle 1.5695 1.5484 1.5309 1.5039 1.4639 1.4456 1.3588
B767-3ER BOEING Air Transport Small Twin Aisle 1.5695 1.5484 1.5309 1.5039 1.4639 1.4456 1.3588
B767-3ERF BOEING Air Transport Small Twin Aisle 1.5854 1.5641 1.5463 1.5191 1.4787 1.4602 1.3725
B787-8 BOEING Air Transport Small Twin Aisle 1.4102 1.3933 1.3795 1.3581 1.3269 1.3123 1.2408
A318-122 AIRBUS Air Transport Single Aisle 0.8412 0.8307 0.8224 0.8098 0.7899 0.7804 0.7369
A318-112/CJ AIRBUS Air Transport Single Aisle 0.8412 0.8307 0.8224 0.8098 0.7899 0.7804 0.7369
B737-700 BOEING Air Transport Single Aisle 0.8762 0.8656 0.8573 0.8446 0.8245 0.8148 0.7701
B737-700W BOEING Air Transport Single Aisle 0.8365 0.8264 0.8185 0.8063 0.7872 0.7779 0.7353
B737-700IGW Air Transport
(BBJ) BOEING Single Aisle 0.9110 0.9000 0.8913 0.8781 0.8572 0.8471 0.8007
B737-800W BOEING Air Transport Single Aisle 0.8911 0.8804 0.8719 0.8589 0.8385 0.8287 0.7832
B737-900ER BOEING Air Transport Single Aisle 0.9586 0.9470 0.9379 0.9240 0.9020 0.8914 0.8425
B737-900ERW BOEING Air Transport Single Aisle 0.9586 0.9470 0.9379 0.9240 0.9020 0.8914 0.8425
A319-NEO AIRBUS Air Transport Single Aisle 0.7262 0.7169 0.7096 0.6983 0.6808 0.6724 0.6339
B737-8 (BBJ) BOEING Air Transport Single Aisle 0.7817 0.7792 0.7730 0.7635 0.7492 0.7432 0.7171
CS100 BOMBARDIER Air Transport Single Aisle 0.6550 0.6501 0.6439 0.6346 0.6201 0.6132 0.5816
CS300 BOMBARDIER Air Transport Single Aisle 0.7120 0.7066 0.7000 0.6898 0.6741 0.6665 0.6322
MS-21-300 IRKUT Air Transport Single Aisle 0.7380 0.7380 0.7380 0.7271 0.7103 0.7028 0.6688
C919ER COMAC Air Transport Single Aisle 0.7120 0.7120 0.7082 0.6969 0.6795 0.6711 0.6331
CRJ700 BOMBARDIER Air Transport Regional Jet 0.6144 0.6055 0.5991 0.5894 0.5735 0.5664 0.5339
ERJ135-LR EMBRAER Air Transport Regional Jet 0.4182 0.4121 0.4078 0.4012 0.3903 0.3855 0.3634
ERJ145 EMBRAER Air Transport Regional Jet 0.4201 0.4141 0.4097 0.4031 0.3922 0.3873 0.3651
RRJ-95 SUKHOI Air Transport Regional Jet 0.6699 0.6602 0.6532 0.6427 0.6254 0.6177 0.5823
RRJ-95LR SUKHOI Air Transport Regional Jet 0.7154 0.7051 0.6977 0.6864 0.6679 0.6597 0.6219
MRJ-70 MITSUBISHI Air Transport Regional Jet 0.5340 0.5340 0.5340 0.5257 0.5121 0.5060 0.4782
MRJ-90 MITSUBISHI Air Transport Regional Jet 0.5540 0.5540 0.5540 0.5454 0.5313 0.5250 0.4961
ERJ-175 E2 EMBRAER Air Transport Regional Jet 0.5920 0.5892 0.5831 0.5739 0.5588 0.5521 0.5213
ATR42-5 ATR Air Transport Turboprop 0.3353 0.3311 0.3280 0.3234 0.3157 0.3125 0.3009
ATR72-2 ATR Air Transport Turboprop 0.3779 0.3732 0.3697 0.3645 0.3559 0.3522 0.3392
Q400 BOMBARDIER Air Transport Turboprop 0.4960 0.4898 0.4852 0.4783 0.4670 0.4623 0.4451
CL-605 BOMBARDIER BGA Large BGA 0.4990 0.4928 0.4878 0.4804 0.4685 0.4633 0.4411
CL-850 BOMBARDIER BGA Large BGA 0.4911 0.4849 0.4801 0.4727 0.4610 0.4559 0.4341
G-5000 BOMBARDIER BGA Large BGA 0.6428 0.6348 0.6285 0.6188 0.6035 0.5969 0.5683
G-6000 BOMBARDIER BGA Large BGA 0.6924 0.6838 0.6770 0.6666 0.6501 0.6429 0.6121
DASSAULT- BGA
FAL900LX AVIATION Large BGA 0.4712 0.4653 0.4607 0.4536 0.4424 0.4375 0.4166
DASSAULT- BGA
FAL7X AVIATION Large BGA 0.4911 0.4849 0.4801 0.4727 0.4610 0.4559 0.4341
ERJLEG EMBRAER BGA Large BGA 0.4990 0.4928 0.4878 0.4804 0.4685 0.4633 0.4411
GVI GULFSTREAM BGA Large BGA 0.5734 0.5663 0.5607 0.5521 0.5385 0.5326 0.5072
GULF5 GULFSTREAM BGA Large BGA 0.5853 0.5780 0.5722 0.5635 0.5495 0.5434 0.5174
GULF4 GULFSTREAM BGA Large BGA 0.6419 0.6339 0.6275 0.6179 0.6026 0.5959 0.5674
Global 7000 BOMBARDIER BGA Large BGA 0.5880 0.5880 0.5823 0.5736 0.5597 0.5538 0.5280
Global 8000 BOMBARDIER BGA Large BGA 0.5960 0.5960 0.5930 0.5842 0.5702 0.5641 0.5380
Learjet 40XR BOMBARDIER BGA Small BGA 0.3344 0.3305 0.3276 0.3234 0.3165 0.3136 0.3037
CL-300 BOMBARDIER BGA Small BGA 0.3831 0.3785 0.3753 0.3704 0.3626 0.3592 0.3478
CNA525B CESSNA BGA Small BGA 0.2421 0.2393 0.2372 0.2341 0.2292 0.2271 0.2199
CNA525C CESSNA BGA Small BGA 0.2421 0.2393 0.2372 0.2341 0.2292 0.2271 0.2199
CNA560-XLS CESSNA BGA Small BGA 0.3265 0.3226 0.3199 0.3157 0.3090 0.3062 0.2965
CNA680 CESSNA BGA Small BGA 0.3865 0.3820 0.3788 0.3739 0.3660 0.3627 0.3513
CNA750 CESSNA BGA Small BGA 0.4084 0.4036 0.4002 0.3951 0.3868 0.3833 0.3713
DASSAULT- BGA
FAL2000LX AVIATION Small BGA 0.3870 0.3824 0.3792 0.3742 0.3663 0.3630 0.3514
EMB505 EMBRAER BGA Small BGA 0.2749 0.2716 0.2693 0.2658 0.2602 0.2578 0.2496
G280 GULFSTREAM BGA Small BGA 0.4426 0.4374 0.4337 0.4280 0.4190 0.4152 0.4021
GULF150 GULFSTREAM BGA Small BGA 0.3850 0.3805 0.3772 0.3723 0.3644 0.3611 0.3496
Learjet 70 BOMBARDIER BGA Small BGA 0.3457 0.3416 0.3387 0.3344 0.3274 0.3244 0.3142
Learjet 75 BOMBARDIER BGA Small BGA 0.3457 0.3416 0.3387 0.3344 0.3274 0.3244 0.3142
CNA680-S CESSNA BGA Small BGA 0.3865 0.3820 0.3788 0.3739 0.3660 0.3627 0.3513
CNA750-X CESSNA BGA Small BGA 0.3716 0.3672 0.3641 0.3594 0.3519 0.3487 0.3378
PC-24 PILATUS BGA Small BGA 0.2930 0.2918 0.2894 0.2857 0.2798 0.2773 0.2687
5. Representative Cumulative Metric Value Improvement and Cumulative Non-Recurring Cost

(NRC) by Aircraft Category
The following table shows examples of representative non-recurring costs for each aircraft size category. We could observe that the more
technologies inserted, there is a diminishing MV% benefit to the amount of NRC spent.
Single Aisle Small Twin Small Twin Large Twin Large Twin
Single Aisle
Small BGA Large BGA Turboprop Regional Jet - new gen Aisle - Aisle - new Aisle - Aisle - new Large Quad
MV% NRC ($B) NRC ($B) NRC ($B) NRC ($B)
- legacy NRC
legacy NRC gen - NRC legacy NRC generation NRC ($B)
($B) NRC ($B) ($B) ($B) ($B) NRC ($B)
3.50% $0.1 $0.1 $0.1 $0.1 $0.2 $0.2 $0.2 $0.2 $0.3 $0.5 $0.3
7.10% $0.2 $0.3 $0.2 $0.3 $0.4 $0.4 $0.7 $0.7 $1.0 $1.2 $1.0
7.20% $0.2 $0.3 $0.3 $0.3 $0.4 $0.5 $0.7 $0.7 $1.0 $1.2 $1.0
7.25% $0.2 $0.3 $0.3 $0.3 $0.4 $0.5 $0.7 $0.7 $1.0 $1.6 $1.0
7.70% $0.3 $0.4 $0.3 $0.4 $0.5 $0.5 $0.7 $0.7 $1.0 $1.6 $1.0
7.73% $0.3 $0.4 $0.3 $0.4 $0.5 $0.5 $0.7 >$1.1 $1.0 $1.6 $1.1
7.85% $0.3 $0.4 $0.3 $0.4 $0.5 $0.8 $0.7 >$1.1 $1.0 $1.6 $1.1
7.88% $0.3 $0.4 $0.3 $0.4 $0.5 $0.8 $0.8 >$1.1 >$1.4 $1.6 $1.2
8.38% $0.3 >$0.6 $0.5 $0.4 $0.8 $0.8 $0.8 >$1.1 >$1.4 $1.6 $1.2
8.48% $0.5 >$0.6 $0.5 $0.4 $0.8 $0.8 $0.8 >$1.1 >$1.4 $1.6 $1.2
8.75% $0.5 >$0.6 $0.5 $0.4 $0.8 $0.8 >$1.2 >$1.1 >$1.4 $1.6 >$1.8
9.13% $0.5 >$0.6 $0.5 $0.5 $0.8 $0.8 >$1.2 >$1.1 >$1.4 $1.6 >$1.8
9.20% $0.5 >$0.6 $0.6 $0.5 $0.8 $0.8 >$1.2 >$1.1 >$1.4 $1.6 >$1.8
9.38% $0.5 >$0.6 $0.6 $0.5 $0.8 $0.8 >$1.2 >$1.1 >$1.4 >$2.0 >$1.8
9.48% $0.6 >$0.6 $0.6 >$0.6 $0.8 $0.8 >$1.2 >$1.1 >$1.4 >$2.0 >$1.8
9.63% $0.6 >$0.6 $0.6 >$0.6 $0.8 >$1.0 >$1.2 >$1.1 >$1.4 >$2.0 >$1.8
9.88% $0.6 >$0.6 >$0.7 >$0.6 >$1.0 >$1.0 >$1.2 >$1.1 >$1.4 >$2.0 >$1.8
>10% >$0.8 >$0.6 >$0.7 >$0.6 >$1.0 >$1.0 >$1.2 >$1.1 >$1.4 >$2.0 >$1.8
6. Selected Technology Profiles

The following sections are selected technology profiles that provide details of each of the most important fuel burn reducing technologies
that were analyzed. Each of the profiles explain the background of each technology, alongside with its source of fuel burn improvements,
technology applications, metric value improvement, commercial & technical feasibility, and non-recurring engineering cost estimate by
aircraft size category. This report elaborates only selected technology profiles that are most pertinent to metric value improvement, as it is
the focus of the analysis in this report. A more complete technology profile list can be found in the March 2015 report.
6.1 Engine Technologies

Major engine OEMs are continually adding to their technology portfolio. Big Four OEMs are spending between $800M and $1.2B on R&D,
so these types of upgrades are part of the ongoing business model to keep competitive in the aero-engine market. Engine technology
insertion is targeted to address TSFC (Thrust Specific Fuel Consumption), Propulsion System Weight Reduction, Maintenance Cost
reduction, Performance Improvement, or System Reliability. Engine technologies embody a range of innovations, including materials (e.g.,
ceramic matrix composite parts), architecture (e.g., optimizing thermal efficiency versus propulsive efficiency), airfoil aerodynamics, sealing
(e.g., blade tip clearances), cooling (i.e., blade cooling to enable higher operating temperatures), and systems technologies (e.g., electric
engine start). In practice, however, it is airfoil aerodynamics and sealing technologies that are applied to new in-production aircraft. The
engine is a highly integrated set of systems that leaves little room for modifications post-entry into service (EIS).
Exhibit 8.12. Representative Engine "Tech Insertion" Packages
Furthermore, engine technologies rarely buy their way on individually; rather, engine OEM’s create technology insertion (TI) “packages” that
improve fuel burn, reduce maintenance cost, and/or improve performance (representative TI packages are illustrated in Exhibit 4-1). If fuel
burn is the competitive requirement, a minimum of 0.5 to 1.0% fuel burn improvement is necessary to justify the development and
certification costs in order to be marketable to airline customers. Integration of a suite of TRL-6 technologies into a propulsion system can
cost the OEM in the ballpark of $100M per 1% fuel burn reduced, excluding any potential additional certification costs. Lower TRL
technologies can add another $100 to $150M, and require additional years in development. These TI packages normally become the new
production standard, and are sold for incorporation during normal engine maintenance activities. As stated by a major engine OEM
executive “….there is 2 to 4 year financial return requirement (for technology insertion packages)…..anything that gets repaired or replaced
(during normal maintenance) buys its way in….”. Another consideration, especially for lessors, is residual value. Technology insertion is not
only a short term cost/benefit analysis, but a consideration in future residual value of the aircraft and/or engine at future sale.
Traditionally, technology development generally revealed itself in mid-life upgrades to engine programs. With the plethora of new engine
development going on, technologies developed for new engines (such as LEAP-X and Trent XWB) are being migrated back to prior versions
of existing engines (e.g., technology developed for the Trent 1000 and 700EP were incorporated into a TI package for the Trent 900 47).
While TI packages will vary from engine to engine, technologies developed and tested in recent new engine programs (e.g., GEnx, Trent
1000/XWB, geared turbofan (GTF), LEAP-X, etc.) will be incorporated into current engines. ICF projects engine upgrade packages will
continue to be developed throughout the forecast period regardless of the source of technology development. While ICF forecasted 0.2%
improvement per annum, some sources indicate that there is substantial upside to this number, with Pratt and Whitney claiming an average
fuel burn improvement of 0.5%-1% for the geared turbofan (Warwick, Pratt and Whitney's Geared Turbofan).
47 “Rolls-Royce Reveals Trent 900 Enhancement Package”, Aviation Week & Space Technology, September 28, 2009, p. 41.
Engine Technologies Improvements (Minor PIP)
Metric Value Benefit & Percentage Improvement by Aircraft Category
Turbo-
nal Jet
Single
Regio
Large
Large
Large
Small
Small
Quad
Aisle
Twin
Twin
BGA
BGA
prop
= 48 = - = = = = =
0.2% /yr 0.2% /yr 0.1% /yr 0.2% /yr 0.2% /yr 0.2% /yr 0.2% /yr 0.2% /yr
Commercial & Technical Feasibility by Forecast Year
2015 2018 2020 2023 2028 2030
Commercial
N/A 49 N/A N/A N/A N/A N/A
Feasibility
Technical
N/A N/A N/A N/A N/A N/A
Feasibility
Estimated Total NRE ($M) by Aircraft Category
$118 $200 $115 $181 $270 $503 $681 $720
48 =: Technology has maximum benefit of average of minimum and maximum for that category
-: Technology has maximum benefit of 100% of minimum for that category
49 Commercial & technical feasibility are not applicable because ICF analyzes engine technologies as improvements that recur on an annual basis as oppose to a one-time improvement
6.2 Variable Camber Trailing Edge

The idea of the variable camber trailing edge is to tailor the aerodynamics of the wing in flight to improve the performance over a range of
flight conditions. Ideally aircraft would fly mostly at the nominal cruise flight condition for which the wing was designed for, but in practice,
aircraft end up flying at a range of conditions dictated by operations. The air traffic control restriction that requires flight at a constant altitude
in 2,000 ft. increments is particularly limiting. The drag penalty due to this restriction over the complete cruise segment can be as high as
7%. If these restrictions were to be reduced or eliminated in the future, as planned under Federal Aviation Administration (FAA)’s NextGen
program, the penalties could reduce dramatically, and this technology might no longer be worthwhile.
Variable camber trailing edge technology is currently implemented in the Boeing 787 and the Airbus A350. In these implementations, both
ailerons and flap positions are optimized for each flight condition to minimize the drag ( (Norris, Boeing Unveils Plans for Trailing Edge
Variable Camber on 787 to Reduce Drag, Save Weight)). The aileron mechanisms are similar to conventional ones, but the flap
mechanisms had to be adapted to enable the required adjustments. This includes the ability of the spoilers to deflect downwards to close
gaps opened when the flaps are slightly drooped. There is also the possibility of morphing the trailing edge without resorting to hinged
surfaces, which we cover in the “Adaptive Morphing Trailing Edge” section.
Variable Camber Trailing Edge Improvements (Large Incremental Update)
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0.0% 3.0% 0.5% 0.5% 1.8% 3.0% 3.0% 3.0%
2015 2018 2020 2023 2028 2030
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0% 0% 2% 3% 5% 6%
Feasibility
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0% 100% 100% 100% 100% 100%
Feasibility
$184 $233 $209 $228 $282 $419 $496 $611
50 X: Technology doesn’t apply to category for technical or economic reasons

+: Technology has maximum benefit of maximum for that category
6.3 Advanced Wingtip Devices

Wingtips devices are an effective way of increasing the lift-to-drag ratio of an aircraft. These can be winglets (single or split), or span
extensions. Increasing the span or the vertical extent of the wing reduces the lift-induced drag by spreading the vorticity, weakening the
adverse effect that this vorticity has on the rest of the wing. At the global level, this is expressed as a reduction in the kinetic energy
associated with the vortex system. Adding wing tip devices also increases the lift, which improves field and climb performance. The penalty
for adding a wing tip device is added viscous drag and weight. The degree to how much weight is added is highly dependent on how much
margin there is in the structural design of the original wing. For an over-designed wing, it is possible to add wingtip devices with no structural
reinforcement, but usually reinforcements are required in the rest of the wing.
The tradeoffs between extending the wing horizontally versus adding a winglet involve a careful multidisciplinary analysis. Aerodynamically,
a wing horizontal extension is more effective in reducing the induced drag than an equivalent increase in the vertical extent of the wing. The
fact that the equivalent horizontal extension can be made smaller for the same induced drag reduction further decreases the viscous drag
penalty. However, the horizontal extension induces larger bending moments on the wing and thus leads to a heavier wing. This makes it
more challenging to incorporate in a wing that has already been designed.
Given the trend to retrofit in-production aircraft with winglets, one must question why this was not done in the original design. After all,
winglets are relatively mature technology. The reason has to do with the tradeoff between fuel burn and aircraft cost. Fuel burn depends on
both weight and drag, but it is more sensitive to drag, while aircraft cost depends primarily on the weight and has no dependence on drag.
Hence, as fuel prices increase, there is more incentive to decrease the fuel burn at the cost of a more expensive aircraft. This is a major
factor when determining the optimal span and wingtip devices of an aircraft.
This trend can be seen in two of the most recent aircraft, the Boeing 787 and the Airbus 350, which exhibit significantly higher spans when
compared to aircraft of the same weight. Further, the 777X is rumored to feature higher span wings, and Embraer just announced that they
would extend the span of the E-175 (Caldas)
Gate code constraints play a major role in the decision of span and wingtip devices. It is no coincidence that the Airbus A350 has winglets
while the Boeing 787 does not: the A350’span is just under the ICAO gate code E constraint, while the Boeing 787 is well under this
constraint. An interesting note on this is that the 777X is rumored to feature folding wingtips in order to increase its span while fitting in code
E gates, further reinforcing the fact that we are now willing to trade higher penalties in weight and cost for lower drag and hence lower fuel
burn.
The design of wing tip extensions is still progressing, as evidenced by the novel shape of the split winglets introduced by Boeing on the 737
MAX. Raked wingtip are also becoming more common and their shape is changing, as can be seen in the evolution of the original 777-
200LR/300ER tips to the shape in the 787. Thus, further gains are expected from the shaping of wingtip devices.
Advanced Wingtip Devices Improvements (Large Incremental Update)
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2015 2018 2020 2023 2028 2030
Commercial
5% 10% 14% 20% 30% 38%
Feasibility
Technical
100% 100% 100% 100% 100% 100%
Feasibility
$98 $124 $111 $121 $150 $222 $264 $325
6.4 Adaptive Trailing Edge

The motivation for this technology is exactly the same as the one for the variable camber trailing edge described previously: to tailor the
wing so as to minimize the drag at the various flight conditions. Instead of relying on hinged surfaces to alter the shape of the wing,
morphing changes the shape of the structure continuously by using piezoelectric materials or by internal mechanisms. The result is a
smooth variation in the shape with no need for gaps that would otherwise contribute to the overall drag. On the other hand, gaps are a
desirable feature in the high-lift system (slats and flaps), since they enable higher maximum lift. This technology has been tested in the
Boeing 737 ecoDemonstrator (Wilsey and Stoker).
The main tradeoff to be considered when employing morphing is whether the performance improvement is worth the added weight, cost,
complexity and actuation energy. Morphing technology has been progressing in all these fronts and it is expected that this trade will become
favorable at some point in the next 10 years. There are two possibilities to deploy the morphing trailing edge: one could have local morphing
on the trailing edge or conventional moving surfaces to augment or replace the conventional adaptive trailing edge technology, or one could
replace all control surfaces with morphing. The latter would have the advantage of eliminating the drag due to gaps, and it also allows for a
finer control of the spanwise distribution of the trailing edge camber, which is very limited when using a conventional adaptive trailing edge.
Adaptive Trailing Edge Improvements (Large Incremental Update)
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X + - - = + + +
0.0% 51 2.0% 0.5% 0.5% 1.3% 2.0% 2.0% 2.0%
2015 2018 2020 2023 2028 2030
Commercial
0% 0% 4% 10% 15% 17%
Feasibility
Technical
0% 0% 50% 100% 100% 100%
Feasibility
51 Due to the small size of a small business and general aviation aircraft, the MV improvement provided by adaptive trailing edge is negligible
$148 $188 $168 $184 $228 $338 $401 $493
6.5 Riblet Coatings

Riblets are a pattern of tiny ridges that are aligned in the direction of the flow. They have been shown to reduce the skin friction due to a
turbulent boundary layer by about 6.5% for the flight regime that is typical of commercial transport aircraft. Riblets work by reducing the
turbulence at the surface in the direction perpendicular to the flow, reducing the skin friction drag. Although this is a well understood way of
reducing skin friction drag, the issue with the use of this technology hinges on the cost of manufacturing, the curability in service and
maintenance issues. Lufthansa Technik is currently researching riblet paint coatings (Gubisch). Given the increasing value of decreasing
drag, there is a chance that this technology is deployed within the next 10 years.
Riblet Coatings Improvements (Large Incremental Update)
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0.5% 0.5% 0.5% 0.5% 1.0% 1.5% 1.5% 1.5%
2015 2018 2020 2023 2028 2030
Commercial
0% 5% 13% 25% 35% 51%
Feasibility
Technical
0% 50% 80% 100% 100% 100%
Feasibility
$148 $188 $168 $184 $228 $338 $401 $493
6.6 Natural Laminar Flow Control - Nacelle

Skin-friction drag is one of the primary sources of drag on an aircraft, usually accounting for just over 50% of the total drag at cruise. As
mentioned previously, this drag is due to the friction caused by the boundary layer. Boundary layers can be either laminar or turbulent, and
the former generate less friction, and thus lower drag. Laminar boundary layers are also thinner, contributing to a decrease in pressure drag
as well. Due to the combination of high speed and scale of the aircraft, the boundary layers on transport aircraft are almost completely
turbulent. It is particularly difficult to achieve a laminar boundary layer in this flow regime through passive means, especially in lifting
surfaces that are swept. Although they start as laminar at the leading edges, they will quickly transition to turbulent unless the right
technology is used.
Natural laminar flow (NLF) relies solely on the careful design of the aerodynamic shape so as to delay the transition of the boundary layer
from laminar to turbulent as much as possible. This technology has been used in high-performance sailplanes for several decades, but the
higher the speed and the longer the dimensions, the more difficult it is to achieve. Furthermore, wing sweep has an adverse effect. As a
result, NLF is currently not feasible on wings of commercial transports flying at high subsonic speeds.
However, recent progress has made it possible to achieve NLF for a significant portion of engine nacelles, as is the case in the Boeing 787.
NLF requires especially tight manufacturing tolerances as well as attention to the paint material and thickness. The 777X will also feature
nacelles with NLF. (CITE Boeing PAS Widebody presentation).
Natural Laminar Flow Control - Nacelle Improvements (Large Incremental Update)
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- - + + = = = =
0.1% 0.1% 1.0% 1.0% 0.6% 0.6% 0.6% 0.6%
2015 2018 2020 2023 2028 2030
Commercial
0% 0% 1% 3% 5% 6%
Feasibility
Technical
100% 100% 100% 100% 100% 100%
Feasibility
$254 $324 $289 $316 $391 $580 $688 $847
6.7 Hybrid Laminar Flow Control – Empennage

As mentioned above, it is possible to achieve a significant amount of NLF on nacelles. However, the boundary layer will eventually transition
when the streamwise distance is long enough. To increase the extent of laminar flow beyond what is possible with the passive means of
NLF, or to ensure laminar flow with an adverse shape or flight condition, it is possible to use hybrid laminar flow control (HLFC).
HLFC uses suction to delay the transition from laminar to turbulent and thus create areas with a laminar boundary layer. This technology has
been tested for the 787-9 vertical tail and will represent the first commercial application of HLFC. Usually, the suction is created by
mechanical means and requires a source of power. The patent filed by Boeing seems to show a system that does not require mechanical
power: it sucks the boundary layer in through tiny holes in the skin to a plenum, or hollow chamber, inside the leading edge vertical tail that
is then connected to an area of lower pressure elsewhere. This reduces the complexity of the system and eliminates the power requirement,
making it commercially more viable.
Hybrid Laminar Flow Control - Empennage Improvements (Large Incremental Update)
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0.3% 0.3% 0.3% 0.3% 1.4% 2.5% 2.5% 2.5%
2015 2018 2020 2023 2028 2030
Commercial
0% 3% 6% 10% 15% 17%
Feasibility
Technical
0% 80% 100% 100% 100% 100%
Feasibility
$254 $324 $289 $316 $391 $580 $688 $847
6.8 Hybrid Laminar Flow Control – Nacelle

As mentioned above, it is possible to achieve a significant extent of NLF on nacelles. However, there might be desirable to increase the
extent of laminar flow even further than it is possible with passive means. Given the possible application of HLFC to the empennage of the
787-9, and as this technology matures, it is likely that this will be applied to other components of the aircraft, including nacelles. The
application to wings, however, remains a very challenging proposition for the reasons that were already mentioned.
Hybrid Laminar Flow Control - Nacelle Improvements (Large Incremental Update)
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- - - - = + + +
0.1% 0.1% 0.1% 0.1% 0.7% 1.3% 1.3% 1.3%
2015 2018 2020 2023 2028 2030
Commercial
0% 3% 6% 10% 15% 17%
Feasibility
Technical
0% 80% 100% 100% 100% 100%
Feasibility
$219 $278 $249 $272 $337 $499 $592 $729
6.9 ECS Aerodynamic Cleanup and On-Demand ECS Scheduling

The environmental control system (ECS) of an aircraft provides air supply, thermal control and cabin pressurization for the crew and
passengers. Avionics cooling, smoke detection and fire suppression are also commonly considered part of an aircraft’s environmental
control system. The Boeing 787 and Airbus A350 have made both aerodynamic and power-saving improvements to the ECS system
(Sinnett). The inlet and outlet ducts to the system’s compressor have been optimized to reduce the pressure drag. In addition, on-demand
ECS scheduling now allows engines to power the system only when needed as opposed to an entire flight (Boeing Co.).
ECS Aerodynamic Cleanup and On-Demand ECS Scheduling Improvements (Minor

PIP)
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= = = = = = = =
0.6% 0.6% 0.6% 0.6% 0.6% 0.6% 0.6% 0.6%
2015 2018 2020 2023 2028 2030
Commercial
8% 20% 28% 40% 60% 68%
Feasibility
Technical
100% 100% 100% 100% 100% 100%
Feasibility
$40 $46 $43 $45 $50 $68 $77 $87
6.10 Fuel Cell APU Replacement

Aircraft auxiliary power units (APUs) are small gas turbine engines used to provide electrical power, air conditioning, hydraulic power, and
pneumatic power both on the ground as a backup in flight. Several companies are conducting research to enable APUs to be replaced with
fuel cells. Fuel cells take advantage of a chemical reaction of some hydrogen-based compounds with air to produce electricity. While this
would likely not produce a direct weight reduction benefit, fuel cell APUs are an important element to enable further development of the
“more electric aircraft” architecture discussed earlier in the report, as well as reducing fuel consumption and emissions for ground
operations. Fuel cell APUs would have many ancillary benefits, including production of nitrogen as a byproduct, which could be used for the
fuel tank inerting system. Fuel cells also produce water as a byproduct of the chemical reaction, which would allow airlines to begin a flight
with less stored water for lavatories, further reducing weight (Breit).
Fuel Cell APU Replacement Improvements (Large Incremental Update)
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2015 2018 2020 2023 2028 2030
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0% 0% 0% 60% 30% 36%
Feasibility
Technical
0% 0% 0% 25% 100% 100%
Feasibility
$148 $188 $168 $184 $228 $338 $401 $493
6.11 Control Surface – Optimal Control Laws for Horizontal Stabilizer Trim
Maintaining trimmed flight efficiently requires clean, accurate, and dynamic control laws. There is room for improvement with contemporary
control systems with regards to overshoot, rise time, and steady-state error. This technology complements the adaptive trailing edge
technology, since if the trailing edge geometry changes, the trim settings should change at the same time.
Control Surface - Optimal Control Laws for Horizontal Stabilizer Trim Improvements
(Large Incremental Update)
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X = = = = = = =
0.0% 0.4% 0.4% 0.4% 0.4% 0.4% 0.4% 0.4%
2015 2018 2020 2023 2028 2030
Commercial
5% 10% 14% 20% 50% 60%
Feasibility
Technical
80% 100% 100% 100% 100% 100%
Feasibility
$98 $124 $111 $121 $150 $222 $264 $325
6.12 Gap Reductions & Aerodynamic Cleanup on Slats/Spoilers/Ailerons/ etc.
Hinged control surfaces such as ailerons, elevators and rudders, leave gaps on the aerodynamic surface that need to be sealed as much as
possible to reduce drag. While some effort has been made to minimize this type of drag, this is an area of continuous improvement.
Spoilers and slats also incur some drag if their trailing edges are not perfectly flush with the shape of the wing. By making these trailing
edges thinner, this source of drag can be reduced, as demonstrated in a recent next-generation 737 performance improvement package
(Tesch, Next-Generation 737 Fuel Performace Improvement).
Gap Reductions & Aerodynamic Cleanup on Slats/Spoilers/Ailerons Improvements

(Minor PIP)
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- - = = = = = =
0.1% 0.1% 0.2% 0.2% 0.2% 0.2% 0.2% 0.2%
2015 2018 2020 2023 2028 2030
Commercial
10% 25% 35% 50% 75% 83%
Feasibility
Technical
100% 100% 100% 100% 100% 100%
Feasibility
$40 $46 $43 $45 $50 $68 $77 $87
6.13 Reducing Profiles of Lights, Antennae, Sensors, etc.

Although the additional lights, antennae and sensors protruding from the aircraft have relatively small dimensions, they can collectively add
up to a significant amount of drag. It is well known that circular cross sections (such as those used in some anti-collision lights) exhibit a
drag that is ten times higher of that of a streamlines shape with the same width. Therefore, several in-production aircraft have modified these
details for in-production aircraft (Tesch, Next-Generation 737 Fuel Performace Improvement), (Caldas). Although the drag reductions are
modest, they are generally low cost modifications.
Reducing Profiles of Lights, Antennae, Sensors, etc. Improvements (Minor PIP)
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2015 2018 2020 2023 2028 2030
Commercial
10% 25% 35% 50% 75% 83%
Feasibility
Technical
100% 100% 100% 100% 100% 100%
Feasibility
$8 $9 $9 $9 $10 $14 $15 $17
6.14 Aft Body Redesign for Aerodynamics

There is room for aerodynamic improvements on the aft body of many contemporary aircraft. Understandably, the majority of aerodynamic
analysis and design effort targets the wings. However, with recent skyrocketing fuel prices, opportunities for drag reduction on non-lifting
parts such as the fuselage have also become a focus of aircraft OEMs. This has been seen on the 737 MAX (Boeing Co.)
For in-production aircraft, it is not feasible to perform a major redesign of the aft body, but it is possible to make modifications on the existing
shape. The area where the horizontal and vertical tails join the fuselage is particularly critical when it comes to interference drag, and is a
good target for redesign.
Aft Body Redesign for Aerodynamics Improvements (Large Incremental Update)
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1.0% 1.3% 1.3% 1.3% 1.3% 1.3% 1.3% 1.3%
2015 2018 2020 2023 2028 2030
Commercial
9% 20% 28% 40% 60% 68%
Feasibility
Technical
90% 100% 100% 100% 100% 100%
Feasibility
$184 $233 $209 $228 $282 $419 $496 $611
6.15 Composites – Current State, Increased Application

Decreasing aircraft weight without compromising drag is a sure way of reducing aircraft fuel burn. Composite materials have been known for
decades and have been used in military airplanes for a long time, and exhibit strength to weight ratios higher than those of metals. However,
composites have only recently been used in the primary structures of commercial transport aircraft (in the Boeing 787 and the Airbus A350).
In spite of the knowledge gained over the years in the military applications, the current generation of composite structures in these new
commercial aircraft has much room for improvement. For both airplanes, the predicted weight advantages of composites have not been fully
realized and there have been growing pains in the development of these structures. This is due in part to complications in the fastening of
the various parts (especially when interfacing composite parts with metal ones) and also due to the use of conservative design procedures
to mitigate the risks in using a new material. Design and manufacturing techniques that enable a more detailed tailoring of the composite ply
angles have the potential to reduce the weight further. There is room for improvement when it comes to reducing the cost of manufacturing
composites. In addition to the weight reduction, composites a much less susceptible to corrosion and should reduce the maintenance cost in
the long run. Finally, composites enable more freedom in the manufacture shape, which could improve the aerodynamics of wings.
There are typically three main techniques to fabricate composite parts that are utilized to produce various part types:
Automated layup:
Automated layup could include Automated Tape Laying (ATL), in which CNC robotic compaction delivery head to deposit composite prepreg
reinforcements from a loading station onto a mold surface, or Automated Fiber Placement (AFP), in which the machine applies “tow preg”
material in strips instead of a single sheet.
Hand layup:
Hand layup fabrication involves manual placement of composite reinforcements in or on a tool, which usually involves placing prepregs into
a mold, subsequently placing a vacuum bag on the tool, and placing the material and tool into a high-temperature oven or autoclave to
cure.Out of autoclave:
Out of autoclave composite fabrication could include Resin Transfer Molding, in which liquid matrix resin is infused into a dry-fiber “preform”
and the resulting part is molded to near-net shaped with very good surface quality, or Resin Film Infusion, in which stacks of composite
fabrics mixed with B-staged resin are stacked onto a tool and readied for vacuum bagging and curing.
Composites - Current State, Increased Application Improvements (Large

Incremental Update)
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2015 2018 2020 2023 2028 2030
Commercial
2% 5% 7% 10% 15% 17%
Feasibility
Technical
100% 100% 100% 100% 100% 100%
Feasibility
$219 $278 $249 $272 $337 $499 $592 $729
7. Technology Readiness Level Definitions
This appendix elaborates the definitions of the technology readiness level (TRL) of technologies
that were mentioned in prior sections of the report. The technology readiness level goes from a
scale of 1-9, in which basic principles and theories are defined as low TRL level, while flight
proven technologies and systems are defined as high TRL level
Technology Readiness Level Definition
1 Basic principles observed and reported
2 Technology concept and/or application

formulated
3 Analytical and experimental critical function

and/or characteristic proof-of-concept
4 Component and/or breadboard validation in

laboratory environment
5 Component and/or breadboard validation in

relevant environment
6 System/subsystem model or prototype

demonstration in a relevant environment
(ground or space)
7 System prototype demonstration in a space

environment
8 Actual system completed and “flight qualified”

through test and demonstration (ground or
space)
9 Actual system “flight proven” through

successful mission operations
8. Introduction to Technology Response Database

The Technology Response Database (or Technology Response Microsoft Excel Spreadsheets)
provides the basis for the future aircraft fleet (for aircraft that the international CO2 standards
apply to). Specifically, the entry into service (EIS) years, end of production (EOP) years, metric
value (MV) continuous improvement forecast, and the long-term MV improvement estimates out
to 2040 are used in the fleet evolution modeling that the EPA developed separate from this
report.
In the EPA analysis, the aircraft in the Technology Response Database are first organized into
growth and replacement market segments. The same market segments are mapped to aircraft
in the baseline CO2 emissions inventory for the year 2015 that the EPA uses for its analysis. 52
Growth and retirement rates mapped to the operations from the 2015 baseline inventory
determine the market demand for each growth and replacement market segment. The aircraft
available to assume the market demand for a specific year are determined by the EIS and EOP
years. The EIS years for new aircraft that are part of a specific transition pair (e.g., A319-1 and
A319-NEO) are adjusted to enter the fleet after the EOP year of the older aircraft in the same
pair (e.g. A319-NEO EIS changes from 2017 to 2020). If aircraft going out of production are not
part of a specified transition pair, the other aircraft in the same market segment will assume the
market demand for that year (or years).
The MV continuous improvement forecast is implemented as an adjustment factor to the fuel
burn (calculated using PIANO). Because we start with a 2015 base year and the ICF MV
forecast starts at 2010, we must scale the MV continuous improvement values to the base year
we use in our analysis, and thus, the adjustment factor, 𝜂𝜂, for a given year is
𝑀𝑀𝑀𝑀(𝑌𝑌)
𝜂𝜂(𝑌𝑌) = , 𝑌𝑌 > 2015
𝑀𝑀𝑀𝑀(2015)
where 𝑀𝑀𝑀𝑀(𝑌𝑌) is the metric value from the ICF continuous improvement metric value forecast for
year 𝑌𝑌 and 𝑀𝑀𝑀𝑀(2015) is the metric value in the base year.
If all the aircraft go out of production within a specific market segment for a year after 2015, then
the long-term percent improvement provided by ICF is added to this adjustment factor for the
aircraft remaining in the market segment. Long-term replacement aircraft beyond the project
aircraft defined for transition pairs are considered generic. At least one long-term replacement
aircraft is selected in each market segment to represent the general fleet level efficiency within
that market segment in our fleet evolution model. Long-term replacements for aircraft that end
production before the final forecast year (2040) are modeled with a MV percent improvement
estimate in the Technology Response Database. These long-term improvements are added to
the MV continuous improvement forecast of the aircraft that is going out of production. For
example, A319-NEO has an EOP year of 2030. The long-term replacement for A319-NEO is a
clean sheet aircraft which is estimated to have a MV improvement of about 20 percent. This 20
percent improvement is added to the MV improvement forecast for A319-NEO as a step-change
52 To develop the baseline operations, the EPA used the FAA's 2015 inventory database as the basis from which to project future
year growth and retirement rates and annual fleet operations for all future years up to 2040. For the FAA 2015 inventory
database, commercial aircraft jet fuel burn and CO2 emissions estimates were included in the U.S. inventory using radar-
informed data from the FAA Enhanced Traffic Management System (ETMS) -- for 2000 through 2016 -- as modeled with the
Aviation Environmental Design Tool (AEDT).
to all subsequent years after the aircraft’s EOP year (2030). The adjustment factor then
becomes
𝑀𝑀𝑀𝑀(𝑌𝑌) 100 − 𝑥𝑥
𝜂𝜂(𝑌𝑌) = ∗
𝑀𝑀𝑀𝑀(2015) 100
where 𝑥𝑥 is the long-term percent improvement provided by ICF.
For the analysis of stringency scenarios, the adjustment factor is updated further to include the
technology response. The only aircraft impacted by a stringency scenario is the A380-8 for
scenario 3. This scenario 3 has an effective date for in-production aircraft of 2023, and the EOP
year for A380-8 is 2025. Thus, for the years 2023 to 2025, the adjustment factor for A380-8 is
𝑀𝑀𝑀𝑀(𝑌𝑌) 100 − 𝑥𝑥 𝑡𝑡𝑡𝑡
𝜂𝜂(𝑌𝑌) = � ∗ �−
𝑀𝑀𝑀𝑀(2015) 100 100
where 𝑥𝑥 is the long-term percent improvement as before and 𝑡𝑡𝑡𝑡 is the percent MV improvement
after the accelerated technology insertions. For the A380-8, the MV improvement from the
technology response is 2.63 percent.

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Aircraft CO2 Cost

September 30, 2018

2.3 2028 Freighter Delay ........................................................................................................ 34

6.8 Hybrid Laminar Flow Control – Nacelle ............................................................................ 83

II. Assessment of CO2 Reducing Technologies

1.1 Growth of Aviation-Produced CO2 and the International Response

1.2 Data Sources

• Assessing interest in new products and services

1.2.1 Secondary Research

1.2.2 Market Interviews

• Aerion • Bombardier • PATS Aircraft Systems

• Airbus • Honeywell • Rolls-Royce

• Boeing • NASA • United Technologies

• Advanced Structures – • Head of Research and • SVP Operations & Supply

III. Executive Summary

• There are no aircraft that fail scenario 1.

IV. Aircraft Metric Values

2. Metric Value Data Sources – PIANO

V. Metric Value Forecast

Exhibit 5.1: ICF Technology Impact Methodology

2.2 Long-Term Metric Value Impact Methodology (Years 2030-2040)

2.3 Technology Development Cost Methodology

3. Updates to 2015 Assumptions

3.1 Technology and Cost Assumptions Updates

3.2 Methodology Updates

Metric value reduction = Technology applicability percentage * commercial feasibility factor *

VI. Stringency Implications

Aircraft Weight New-Type Aircraft

Stringency Level >5,700 to <60,000 SL5 19 SL3 20

60,000 to ~ 70,000 SL5-SL8.5 2122 SL3-SL7 2324

> ~70,000 SL8.5 25 SL7 26

Implementation Date Application for a new- 2020 2023

Production Cut-Off n/a 2028

We analyze the results of these three scenarios in the next section.

Exhibit 6.2: Stringency Scenarios

Scenario Option Description

• New Type SL8.5 (SL5 for aircraft < 60 tons) 2020

o (SL5 for aircraft < 60 tons and < 19 seats 2023)

Pull Ahead Some

Exhibit 6.3: Stringency lines for the three scenarios 33,34

VII. Technology Response for Failed Aircraft

1. Modeling Metric Value Reduction

1.1 Implementation of Metric-Value-Improving Technology versus

Exhibit 7.1: Incremental Improvement Technology Insertion Analysis Methodology

2. We overlay the smoothed forecasted incremental metric value improvement by the

1.2 1% Additional Design Margin for Non-Compliant Aircraft

2. PIANO Data Based Technology Response

2.1 Regulatory Non-compliance by Scenario

Exhibit 7.2: Aircraft Non-Compliance by Scenario

Scenario 1 Scenario 2 Scenario 3

Metric Metric Metric

2.2 Technology Response by Aircraft by Scenario

2.2.1 A380 (-842 / -861)

Exhibit 7.3: A380 Incremental Improvement Technology Supply Curve

No Design Margin 1% Design Margin

% Gap to MV Standard 3.24% 4.24%

Residual Implemented MV Improvement (1.71%) (1.71%)

Technology Response Improvement Target 1.53% 2.53%

2.00% of A380 2.00% of A380

Non-Recurring Cost to Implement Technology

Recurring Costs of Technology Response

Exhibit 7.5: 767 Incremental Improvement Technology Supply Curve

1% Design Margin Implementation on 767-3F