Appendices to ACRP Report 11: Guidebook on Preparing Airport GHG Emissions Inventories (2008)

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ACRP Project 02-06 Appendices – Final September 19, 2008 Appendix A: Reasons for Developing GHG Inventories A.1 Introduction When considering the approach to preparing a greenhouse gas inventory, consideration has been, and should continue to be, focused on the purpose of the inventory. For example, what are the goals of the inventory and how is the information to be used? While there are numerous reasons why an airport might prepare an inventory, they can largely be grouped under the following categories: • Climate Change Initiatives (also called Climate Action Plans) • Environmental Management and Sustainability Programs • Disclosure of Project/Action Effects • Future Regulations Figure A-1 shows the relationships between these different reasons in terms of source coverage. As indicated, the Regulatory-Based Project Plan and the Sustainability Project Plan are subsets of the Climate Action Plan which comprehensively covers all sources.   Regulatory-Based Project Plan Sustainability Project Plan Climate Action Plan Figure A-1. Relationship Showing Source Coverage by Different Inventory Purposes These reasons generally agree with the few airport GHG inventories that have been developed to date. The following sections provide a brief overview of these inventory reasons and their needs. A.2 Climate Change Initiatives – GHG Reduction Goals In the U.S., there are no current national regulations specifically controlling greenhouse gases. Concentrations of a few gasses that exert GHG effects (directly or indirectly), such as 2   

ACRP Project 02-06 Appendices – Final September 19, 2008 NOx, O3, and CO, are regulated by the Clean Air Act for visibility and human health implications rather than for climate change effects. Internationally and in the U.S., there are various parties and mechanisms that have been set up to control or at least quantify GHG emissions. The Climate Change Initiative category of emissions inventories are targeted at inventories that are used for purposes of identifying sources of emissions, their contribution to regional, state, local, or national inventories, and then form the basis for examining ways to reduce emissions from these sources. Included in this category are inventories prepared for purposes of climate action registries, such as The Climate Registry (TCR 2008) and the California Climate Action Registry (CCAR 2008). The activities of the primary parties currently addressing greenhouse gases and climate change are generally described by international activities and domestic activities: A.2.1 International • The Kyoto Protocol to the United Nations Framework Convention on Climate Change (UNFCCC) is a supplement to the international treaty on climate change, assigning mandatory targets for the reduction of greenhouse gas emissions to signatory nations. Countries that ratify the Kyoto Protocol commit to reduce their emissions of CO2 and five other greenhouse gases, or engage in emissions trading if they maintain or increase emissions of these gases. Governments are separated into two general categories: developed countries, referred to as Annex 1 countries who have accepted greenhouse gas emission reduction obligations; and developing countries, referred to as Non-Annex 1 countries that have no greenhouse gas emission reduction obligations. As of January 15, 2008, a total of 177 countries and the EEC have ratified the agreement (representing 63.7% of emissions from Annex I countries) (UN 1998). A notable exception is the United States (U.S.). Other developing countries, such as India and China, which have ratified the protocol, are not required to reduce carbon emissions under the present agreement despite their relatively large populations. According to Article 25 of the protocol, it enters into force "on the ninetieth day after the date on which not less than 55 Parties to the Convention, incorporating Parties included in Annex I which accounted in total for at least 55% of the total CO2 emissions for 1990 of the Parties included in Annex I, have deposited their instruments of ratification, acceptance, approval or accession." Of the two conditions, the "55 parties" clause was reached in 2002. The ratification by Russia in late 2004 satisfied the "55%" clause and brought the treaty into force, effective February 2005. Emissions from international aviation were specifically excluded from the targets agreed under the Kyoto Protocol. Instead, countries were encouraged to control international aviation-related emissions through the activities of the International Civil Aviation Organization (ICAO). ICAO’s Committee on Aviation Environmental Protection continues to consider the potential for using market-based mechanisms. ICAO is currently developing guidance for states who wish to include aviation in an emissions trading scheme (ETS) to meet their Kyoto commitments, 3   

ACRP Project 02-06 Appendices – Final September 19, 2008 and for airlines who wish to participate voluntarily in a trading scheme. Emissions from domestic aviation are included within the Kyoto targets agreed by countries. Although a signatory to the protocol, the U.S. has neither ratified nor withdrawn from the protocol. In late 1998, then Vice President Al Gore signed the protocol; however, both Gore and Senator Joseph Lieberman indicated that the protocol would not be acted upon in the Senate until there was participation by the developing countries. The Clinton Administration never submitted the protocol to the Senate for ratification due to estimates of large declines in the Gross Domestic Product associated with compliance. To date, the Bush Administration has not supported the Kyoto principles because of the exemption granted to China which recently surpassed the U.S. as the greatest emitter of carbon. • Recognizing the problem of potential global climate change, the World Meteorological Organization (WMO) and the United Nations Environment Programme (UNEP) established the Intergovernmental Panel on Climate Change (IPCC) in 1988. While not a group that has established greenhouse gas reduction goals, the IPCC plays a major role in guiding international and national emission quantification and reduction work. It is open to all members of the United Nations (UN) and WMO. The role of the IPCC is to understand the risk of human- induced climate change, its potential impacts, and options for adaptation and mitigation. The IPCC does not carry out research or establish regulation. It bases its assessments mainly on peer reviewed and published scientific/technical literature. The IPCC has completed four assessment reports, developed methodology guidelines for national greenhouse gas inventories, special reports, and technical papers. The IPCC has three working groups and an emissions inventory task force. A.2.2 Domestic Although the U.S. has not signed on to the Kyoto Protocol, a national greenhouse gas reduction goal has been established. In February 2002, the President affirmed his commitment to the UNFCCC and its central goal of stabilizing atmospheric greenhouse gas concentrations and committed the United States to a comprehensive strategy to reduce the greenhouse gas emission intensity by 18 percent by 2012. According to the USEPA web site (USEPAc 2007): Greenhouse gas intensity is the ratio of greenhouse gas emissions to economic output. The U.S. goal is to lower emissions from an estimated 183 metric tons per million dollars of Gross Domestic Product (GDP) in 2002, to 151 metric tons per million dollars of GDP in 2012. The U.S. commitment will achieve 100 million metric tons of reduced emissions in 2012 alone, with more than 500 million metric tons in cumulative savings over the entire decade. The policy focuses on reducing emissions through technology improvements and dissemination, improving the efficiency of energy use, voluntary programs with industry and shifts to cleaner fuels. Even though the U.S. has not ratified Kyoto, various regional, state, and local agencies have started to take action to quantify and/or reduce GHG emissions. 4   

ACRP Project 02-06 Appendices – Final September 19, 2008 A.2.3 State and Local The U.S. Mayors Climate Protection Agreement was launched on February 16, 2005 (the same day as the Kyoto Protocol came into effect) to advance the goals of the Kyoto Protocol through leadership and action. Two years later, when participation reached over 500 cities, the U.S. Conference of Mayors launched its own Climate Protection Center to administer and track the Agreement. Under the Climate Protection Agreement, participants commit to: • Strive to meet or beat the Kyoto Protocol targets in their own communities; • Urge their state governments, and the federal government, to enact policies and programs to meet or beat the greenhouse gas emission reduction target suggested for the U.S. in the Kyoto Protocol -- 7% reduction from 1990 levels by 2012; and • Urge the U.S. Congress to pass the bipartisan greenhouse gas reduction legislation, which would establish a national emission trading system. In addition, an extensive number of states, cities, and counties have launched climate change initiatives. A few of these are noted below: In July of 2000, the Conference of New England Governors and Eastern Canadian Premiers (NEG/ECP) adopted Resolution 25-9 on global warming and its impacts on the environment. As a result, the NEG/ECP Climate Change Action Plan was developed that includes regional emission reduction goals: • Short-term Goal: Reduce regional emissions to 1990 emissions by 2010. • Mid-term Goal: Reduce regional emissions by at least 10% below 1990 emissions by 2020, and establish an iterative five-year process, commencing in 2005, to adjust the goals if necessary and set future emissions reduction goals. • Long-term Goal: Reduce regional emissions sufficiently to eliminate any dangerous threat to the climate; current science suggests this will require reductions of 75– 85% below current levels. In June 2005, the Governor of California signed Executive Order S-3-05 which established statewide greenhouse gas emission targets and directed the Secretary of the California Environmental Protection Agency to lead the effort to achieve the targets. The targets developed are (SOC 2008). • By 2010, reduce greenhouse gases to 2000 emission levels • By 2020, reduce to 1990 emission levels • By 2050, reduce to 80% below 1990 levels California’s Global Warming Solutions Act (also known as Assembly Bill 32 or AB32) was signed on September 2006 codifying in state law the Executive Order. It sets up the first enforceable state-wide program in the U.S. to cap all greenhouse gas emissions from major industries and includes penalties for non-compliance. In March 2006, the County Executive for King County Washington issued Executive Orders on Global Warming Preparedness which directed the County to reduce greenhouse gas emissions and to prepare for anticipated climate change impacts. These Executive Orders mandated that County departments take climate change actions with regard 5   

ACRP Project 02-06 Appendices – Final September 19, 2008 to land use, transportation, environmental management and clean energy use. In October 2006, the King County Council mandated that the County submit a Global Warming Mitigation and Preparedness Plan (the “Climate Plan”), as well as an annual report in each subsequent year. Consistent with the Executive Orders, the Council required specific actions to be taken relative to emissions inventories, greenhouse gas reduction targets, land use, environmental management, emergency preparedness, energy use and transportation. Table A-1 identifies the eight (8) current regional greenhouse gas initiatives. The USEPA further indicates that as of end of 2007, only California has enacted a formal emission reduction cap, but that four other states (WA, OR, NM, and AZ) are in the process of enacting a cap, and two (WI and NJ) have proposed capping greenhouse gases (USEPAd 2007). In addition, 14 states have adopted statewide greenhouse gas targets, with two additional states proposing targets. Table A-1. Summary of Regional Greenhouse Gas Initiatives Effort Description of Activities Participating States New England Governors: Climate Action Plan A goal of achieving 1990 greenhouse gas emission levels by 2010 and 10% below 1990 levels by 2020. CT, ME, MA, NH, RI, and VT Regional Greenhouse Gas Initiative (RGGI) RGGI is an effort by Northeastern and Mid- Atlantic states to reduce CO2 emissions through a cap and trade program. Phase I (2009-2015) will stabilize emissions at 121.3 million short tons of CO2 (this is a little above 2000-2004 levels). Phase II (2015-2020) will reduce emissions by 10% below Phase 1 levels (roughly equivalent to 1990 levels). CT, DE, ME, MD (2007), NH, NJ, NY, and VT. (PA and RI are observers; MA participated in the design) The Climate Registry (TCR) TCR is an effort to develop a greenhouse gas Registry that will measure, track, verify and publicly report emissions accurately, transparently and consistently across borders and industry sectors. TCR will support voluntary, market-based and regulatory emissions reporting programs and will start accepting data in Jan. 2008. AZ, CA, CO, CT, DE, FL, HI, IL, KS, ME, MD, MA, MI, MN, MS, MO, NH, NJ, NM, NY, NC, OH, OR, PA, RI, SC, UT, VT, WA, WI, and WY. Southwest Climate Change Initiative (SCCI) Launched in 2006, the SCCI creates ways for the two states to collaborate on climate change and emission reduction strategies. AZ and NM “Powering the Plains” Initiative This initiative addresses climate issues surrounding energy and agriculture while adding value to the region's economy and mitigating the risk of climate change and other environmental concerns. IA, MN, ND, SD, and WI West Coast Governors’ Global Warming Initiative An effort between the Governors of Washington, Oregon, and California to reduce greenhouse gas emissions from their respective states. CA, OR, and WA Western Governor’s Participating states agreed to examine the feasibility of: AK, AZ, CA, CO, HI, ID, KS, MT, 6   

ACRP Project 02-06 Appendices – Final September 19, 2008 Association Clean and Diversified Energy Initiative o Developing 30,000 Megawatts of clean and diverse energy by 2015. o Increasing energy efficiency 20 percent by 2020. o Providing adequate transmission to meet the region’s needs through 2030. NE, NV, ND, OR, SD, TX, UT, WA, and WY Western Regional Climate Action Initiative The Governors of 5 western states established this initiative in 2007, committing to establish an overall regional goal to reduce greenhouse gas emissions within 6 months, develop a design for a regional market-based multi-sector mechanism within 18 months to achieve the regional goal, and participate in a multi-state greenhouse gas registry. AZ, CA, NM, OR, and WA. Source: USEPAd 2007. As part of the regional, state, and local climate action initiatives, voluntary greenhouse gas/climate registries have evolved. Many cities, counties and corporate entities have already voluntarily joined the registries. Each registry has developed its protocol for generating emission inventories as well as the verification/certification process. According to The Climate Registry (TCR), the benefits of participation in a registry are: • Demonstrate environmental leadership • Document early actions to voluntarily emissions • Identify and manage greenhouse gas risks and opportunities • Gain access to user-friendly web-based software and technical assistance as you develop your inventory • Participate in policy discussions relevant to your industry and evolving greenhouse gas policy • Gain competitive advantage by increasing operational efficiency TCR was formed in 2007 and reflects the combination of four main regional registries: California Climate Action Registry, Eastern Climate Registry, the Lake Michigan Air Directors Consortium, and the Western Regional Air Partnership. As of March 31, 2008 TCR represented 39 U.S. states, 5 Canadian provinces, and 6 Mexican states. Some of states and provinces that are members of TCR have adopted or are in the process of adopting mandatory reporting requirements, either individually or as part of regional GHG reduction programs. Thus, the registries are attempting to have a common inventory/reporting protocol. A.3 Environmental Management and Sustainability Programs As the aviation industry has grappled with the future of the aviation system and the Next Generation Air Transport System (NextGen) designed to efficiently accommodate future demand for air travel, airports individually have adopted sustainability practices. Through the Airports Council International - North America (ACI-NA), a Sustainability Committee came together with the following mission (ACI-NA 2008): “We will define and promote Aviation Sustainability as a standard business practice. 7   

ACRP Project 02-06 Appendices – Final September 19, 2008 The ACI-NA Sustainability Committee serves the Aviation Industry through specific initiatives that are tailored to the industry and created for the purpose of defining aviation sustainability as a business strategy that promotes the core benefits of economic viability, operational efficiency, natural resource conservation and social responsibility. The Committee is a cooperative and collaborative body of airport directors, consultants and relevant stakeholders whose foremost interest is one of developing and delivering these benefits for the Aviation Industry.” The Transportation Research Board (TRB) in its 2005 conference proceedings, “Integrating Sustainability into the Transportation Planning Process” envisioned sustainability at its most basic level as “one that meets the transportation and other needs of the present without compromising the ability of future generations to meet their needs.” The TRB Committee on Environmental Impacts of Aviation (AV030) has also organized a subcommittee on aviation sustainability to provide a forum for all aviation constituents to discuss these important issues. More information on this committee and their subcommittee activities can be found at http://www.trbav030.org. These efforts have defined sustainability as “a holistic approach to managing an airport so as to ensure the integrity of the Economic viability, Operational efficiency, Natural Resource Conservation and Social responsibility (EONS) of the airport.” Airports that have adopted sustainability practices may wish to quantify greenhouse gas emission reduction benefits associated with their sustainability practices. In this case, it may be the airport as a system or it may be individual projects. For the case where the desire is to inventory the airport in its entirety, the previously defined approach for Climate Change Initiatives may be used. In the case of individual sustainability projects, only the sources affected by the action might be considered. For instance, if an airport installed preconditioned air and 400-hz power at the gates, the emission reduction benefits associated with aircraft using these systems might be contrasted with the emissions associated with aircraft continuing to use their Auxiliary Power Units (APUs). It is anticipated that as planning progresses at airports and more sustainability plans are developed and implemented, airports will likely include the quantification of greenhouse gases as part of their plans both from the tactical perspective (the emission changes associated with actions), but also in a strategic sense (how future plans and policies may affect climate action goals as well as the effects of climate change on airports). A.4 Disclosure of Project/Action Effects In addition to requirements that may exist for preparing inventories to support commitments under regional, state and local climate action plans, inventories may also be required to support actions involving state and possibly federal approvals of airport improvements. In the United States, this project/action effect disclosure can occur in the form of documents prepared under the National Environmental Policy Act (NEPA) or based on state requirements that are similar to NEPA. Under the NEPA, before federal agencies can approve an action, certain environmental reviews may be required. Federal actions in the context of airports can involve the following: approval of Federal funding for airport development projects; approval of a location for a new, public use airport; approval of an Airport Layout Plan (ALP); authorizing use of Passenger Facility Charges (PFC); approval to use or transfer Federally-owned land, etc. Documents prepared in support of the NEPA address issues ranging from air quality, to noise, and cumulative impacts. 8   

ACRP Project 02-06 Appendices – Final September 19, 2008 In October 1997, the President’s Council on Environmental Quality (CEQ) circulated a draft memo for review by federal agencies concerning climate change (CEQ 1997). The draft memo concluded with: Global climate change is a serious environmental concern which, given the current state of scientific knowledge, must be viewed under NEPA as a reasonably foreseeable impact of continued emissions and changes in sinks of greenhouse gases. Thus, federal agencies must analyze the extent to which both their proposed and ongoing programs or other activities might influence such emissions and sinks, thereby continuing to, or reducing, the problems of global warming. Such analyses can best be done in the context of NEPA and should look at how federal actions may affect global climate change and, to the extent possible given the current state of scientific knowledge, how federal actions may be affected by global climate change. It is important to note that a final CEQ guidance does not appear to have been issued. Separately, FAA issues guidance for the compliance with the NEPA for FAA actions in terms of three documents: FAA Order 1050.1E Environmental Impacts: Policies and Procedures, FAA Order 5050.4B National Environmental Policy Act (NEPA) Implementing Instructions For Airport Actions, and Order 5050.4B’s accompanying Environmental Desk Reference for Airport Actions. No specific guidance is available in these documents concerning greenhouse gas emissions (FAA 2004, FAA 2006, and FAAb 2007) . Several states have adopted requirements similar to NEPA (called mini-NEPA). For instance, the California Environmental Quality Act (CEQA), Washington State Environmental Policy Act (SEPA), and Massachusetts Environmental Policy Act (MEPA), are mini NEPA-like laws. These state regulations require evaluations to be conducted for actions occurring within these states subject to certain conditions. In each of the three cited cases, the regulations are beginning to require the preparation of greenhouse gas emissions inventories, and may have specific analysis requirements: • Massachusetts Environmental Policy Act (MEPA): On December 24, 2007, the State of Massachusetts Office of Energy and Environmental Affairs issued its final policy titled “MEPA Greenhouse Gas Emissions Policy and Protocol” (MEPA 2008). The policy requires that certain projects undergoing review by the MEPA Office quantify the project’s greenhouse gas emissions and identify measures to avoid, minimize, or mitigate such emissions. In addition to quantifying project- related emissions, the policy also requires proponents to quantify the impact of proposed mitigation in terms of emissions and energy savings. Elements of this policy that would influence the approach to quantifying emissions are: “… this Policy is not intended to create a numerical GHG emission limit or a numerical GHG emission reduction target. Rather, in keeping with MEPA’s overall purpose to evaluate alternatives that avoid, minimize and mitigate environmental impacts, the Policy is intended to ensure that Project proponents and reviewers have carefully considered the GHG impact of their Projects and taken all feasible means and measures to reduce those impacts.” “The proponent is then required to quantify the potential annual GHG emissions from the proposed Project according to the GHG Quantification 9   

ACRP Project 02-06 Appendices – Final September 19, 2008 Protocol (the Protocol) outlined below (or other protocols that are accepted on a case-by-case basis), and report in the EIR on the results of the analysis. Emissions should be expressed in short tons (2,000 lbs) per year (tpy).” “… the proponent should also outline and commit to a series of mitigation measures that will help to reduce GHG emissions from the proposed Project. To demonstrate the efficacy of the mitigation, the proponent should measure emissions reductions and energy savings from the proposed measures according to the Protocol and discuss the impact of proposed mitigation…” “At the current time, the analysis will focus primarily on the primary greenhouse gas, carbon dioxide (CO2). While there are other GHGs, CO2 is the predominant contributor to global warming, and emissions can be calculated for CO2 with readily accessible data. The analysis of other GHGs may be required for certain Projects, such as methane emissions from landfills and wastewater treatment plants…” “EEA will require analysis of both “direct” GHG emissions … and ’indirect’ emissions ….” • As noted earlier, the State of California passed the California Global Warming Solutions Act, thereby being the first state to adopt limits on greenhouse gases. As a result of this act, and subsequent litigation over CEQA documents, most evaluations are now quantifying greenhouse gases. The first airport-project to include a greenhouse gas inventory was prepared for the Master Plan at Sacramento International Airport (SMF) (SC 2007). Later in 2007, a similar CEQA document was prepared for San Diego International Airport which included a greenhouse gas inventory. • At present, the Washington State Environmental Policy act (SEPA) does not specifically require the evaluation of greenhouse gases. However, the King County Climate Action Plan, which governs activities in the two most populated cities in the state, will require the preparation of greenhouse gas inventories. Effective September 1, 2007, all County environmental reviews conducted under the SEPA must include a greenhouse gas inventory per a recently enacted Executive Order. The County has indicated plans to develop significance thresholds for greenhouse gases and a requirement for mitigation by the end of 2008. On December 3, 2007, Seattle’s City Council adopted Ordinance 122574 that requires City departments that prepare environmental reviews under SEPA to evaluate greenhouse gas (GHG) emissions. To assist with that review, the City has prepared a worksheet to aid in those reviews which focus on new housing and commercial/industrial development (http://www.seattle.gov/dpd/Planning/GreenhouseGas/ClimateChangeImpactsWork sheet/default.asp ). In these cases, a NEPA or mini-NEPA evaluation by definition focuses on the project- related effects of an action that is the subject of the evaluation. As has been the case of air quality assessments for criteria pollutants, FAA guidance has limited the evaluation of air quality to the sources that are affected by the action. For example, if the proposed action is a development project that would extend a runway, only the sources that would be affected by that action (the extended runway) would be inventoried; the primary analysis function of NEPA is to consider the effect of the project relative to what would happen if the project 10   

ACRP Project 02-06 Appendices – Final September 19, 2008 were not undertaken. In the example case, the analysis may only focus on aircraft taxi movements and construction emissions. To support that analysis, documentation would be necessary to show how the project would affect existing and future aircraft operations levels (would it induce additional flights). If additional flights would be induced, then additional support activity might occur requiring the consideration of other sources. A.5 Future Regulations In addition to local efforts to require the quantification and reduction in greenhouse gases, there are have also been pushes to require regulation including the recent Supreme Court case of Massachusetts vs. USEPA. On April 2, 2007, the Supreme Court ruled on a 5- to-4 vote that USEPA does have the authority to regulate GHG emissions and that USEPA must re-evaluate its stance in not choosing to do so thus far. Other efforts include the 2008 lawsuit by California to regulate GHG emissions from mobile sources and California’s petition of USEPA to regulate industrial GHG emissions. As previously noted, several local parties are beginning to regulate greenhouse gases for all sources with possible specific controls on aviation-related emissions. It is anticipated that further regulations will develop, and some anticipate that the U.S. government may begin to regulate greenhouse gases. Evidence of movement in the U.S. toward national GHG regulations may be evident in a number of areas as noted in the following discussions. Increasing concerns have arisen with the U.S. position on the Kyoto Protocol (that the Protocol has not been adopted by the U.S.). In December 2007, the UNFCC Conference in Bali brought together representatives of over 180 countries with observers from intergovernmental and nongovernmental organizations. The two week period included the sessions of the Conference of the Parties to the UNFCCC, its subsidiary bodies as well as the Meeting of the Parties of the Kyoto Protocol. The conference culminated in the adoption of the “Bali roadmap,” which charts the course for a new negotiating process to be concluded by 2009 that will ultimately lead to a post-2012 international agreement on climate change. Ground-breaking decisions were made which form core elements of the roadmap in which the U.S. participated. While it is uncertain as to how this will affect regulation in the U.S., many believe that the roadmap process may ultimately provide a mechanism for U.S. participation. Separately, litigation and local action is moving toward increasing regulation. For instance, the Clean Air Act which regulates the emission of pollutants has provided another venue for seeing regulation. The most notable case making use of this theory was Massachusetts v. USEPA, 415 F.3d 50 (D.C. Cir. 2005) in which 12 states brought suit against the U.S. Environmental Protection Agency (USEPA). The U.S. Supreme Court decided the case on April 2, 2007 in a 5-4 decision. The court found that the Clean Air Act gives USEPA the authority to regulate tailpipe emissions of greenhouse gases, and the USEPA is required to review its contention that it has discretion in regulating CO2 and other greenhouse gases. Specifically, the court found that USEPA’s current rationale for not regulating GHG emissions was found to be inadequate, and the agency must articulate a reasonable basis in order to avoid regulation. In December 2007, the USEPA responded to the California’s waiver request with a denial of approval. Rather, the Bush Administration announced that it is moving forward with a national solution to reduce greenhouse gas emissions from autos in the form of a unified auto fuel economy standard. USEPA Administrator Johnson noted that "The Bush Administration is moving forward with a clear national solution – not a confusing patchwork of state rules – to reduce America’s climate footprint from vehicles…” USEPA determined 11   

ACRP Project 02-06 Appendices – Final September 19, 2008 12    that a unified federal standard of 35 miles per gallon will deliver significant reductions in greenhouse gas emissions from cars and trucks. In early 2008, a coalition of states, cities and environmental organizations petitioned the USEPA to determine that greenhouse gases contribute to potentially harmful air pollution and to have USEPA adopt regulations to control such emissions. The petitioners, consisting of six states and several non-governmental organizations, are seeking to have USEPA consider emissions limitations and fees, operational practices, a cap-and-trade system, and measures to reduce taxi time and increase use of ground-based electrical power. In addition to or as part of the GHG emissions tracking work, an airport could potentially position itself to generate revenues through carbon trading. As the carbon trading market becomes more established, airports may be able to take advantage of the opportunities to develop and sell carbon credits.