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CONTENTS I. Introduction, 3 II. Airport Sources of Greenhouse Gas Emissions, 3 A. Airport and Aviation Contribution to Climate Change, 4 B. Airport Sources of GHG Emissions, 4 C. Airport Ownership and Operating Control Over Sources, 6 III. Legal Requirements or Obligations that can Affect Airportsâ Efforts to Reduce GHG Emissions, 8 A. Federal Clean Air Act, 8 B. Federal (Non-CAA) Preemption of Aviation Regulation, 17 C. Federal Legal Restrictions on Rates, Charges, and Use of Revenue, 20 D. Federal Airport Improvement Program, Voluntary Airport Low Emissions Program, and Passenger Facility Charges, 23 E. Federal Legal Restrictions on Exclusive Rights and the Imposition of Conditions and Standards, 24 F. Federal Requirements Concerning Airport Design, Construction, Security, and Hazards, 25 G. State Laws and Regulations Governing GHG Targets and Reporting of GHG Emissions, 27 H. Federal and State Regulations and Requirements Relating to Renewable Energy Projects, 29 I. State and Local Land Use and Zoning Authority Over Airport Development (Other than Renewable Energy), 31 J. Federal National Environmental Policy Act and Comparable State-Level Requirements, 32 K. General Environmental Laws that May Apply to Development or Energy Projects, Including at Airports, 36 IV. Airport Practices to Reduce GHG Emissions and Potential Legal Implications, 37 A. Aircraft Operations, 38 B. Business Planning, 43 C. Construction, 47 D. Carbon Sequestration, 49 E. Energy Management, 50 F. Ground Service Equipment, 53 G. Ground Transportation, 55 H. Materials and Embedded Energy, 58 I. Operations and Maintenance, 59 J. Performance Measurement, 60 K. Renewable Energy Production, 61 L. Refrigerants, 66 V. Conclusion, 67 Table of Acronyms, 68
