Handbook for Evaluating Emissions and Costs of APUs and Alternative Systems (2012)

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10 C h a p t e r 2 This chapter expands on the background information presented in Chapter 1. The informa- tion presented herein provides a broad overview of the major issues and considerations associ- ated with planning and implementing alternative systems at airports. Information contained in this chapter is intended to provide a solid basis from which to conduct the quantitative and qualitative assessments described in Chapters 3 and 4. The considerations described in this chap- ter are grouped into the following categories: • Implementation and operation, • Regulations, • Environmental, • Costs, and • Funding. 2.1 Implementation and Operation Airport capital improvement projects are increasingly being challenged by agencies and indi- viduals on environmental grounds. Noise and air pollution are often listed as concerns by airport neighbors. Criteria pollutant emissions (e.g., carbon monoxide [CO], nitrogen oxides [NOx], and sulfur oxides [SOx], etc.) and, more recently, greenhouse gas emissions (e.g., carbon diox- ide [CO2], methane [CH4], etc.) associated with airport operations are being targeted and/or scrutinized by state and regional air quality management agencies. Airport operators have been working with airlines and other stakeholders to identify opportunities to reduce emissions from airport sources. Some airport operators have replaced gasoline- and diesel-powered on-airport vehicles and equipment with electric or alternative fuel vehicles and equipment. Similarly, the provision of alternative ground power and PCA systems at airports is a tested method of reduc- ing APU fuel burn and related pollutant emissions. As discussed previously, POU units are usually mounted on the underside of the Passenger Boarding Bridge (PBB). The POU gate equipment is generally much larger than the central sys- tems’ individual gate equipment. However, central systems also require space within the airport terminal facility and/or central plant, and therefore, central systems have greater total space requirements. While some central system components such as AHUs and 400 Hz gate boxes may be mounted on the PBB, a dedicated facility needs to be built to serve as the central plant to house the chillers and frequency converters for a central system. This, coupled with the need for distribution systems between the central plant(s) and the gate utilization equipment, is why central systems have significantly higher capital costs than POU systems. It should be noted, however, that central systems also allow for the use of existing airport boilers for heat energy Considerations for Planning the Implementation of an Alternative System

Considerations for planning the Implementation of an alternative System 11 (i.e., for supplying heated air to aircraft cabins). The lower cost of natural gas relative to grid electricity makes the central system with airport boilers an attractive option. As explained in Chapter 4, central systems are also more energy efficient than POU systems, as a result of effi- ciencies gained by centralizing the core equipment. Central systems also have lower maintenance costs, on average, than POU systems (ASE 2011). The implementation of alternative systems typically requires infrastructure support/upgrades. Both central and POU systems require electrical infrastructure including components such as electrical feeders, breakers, and bus taps. Typically, POU-style systems require significantly more electrical power related upgrades than central systems (ASE 2011). Once a central system is built, it is fixed and cannot be easily moved, except for some of its PBB-located components (e.g., AHUs and gate boxes). In contrast, a POU system can be detached from its mounting location on a PBB and relocated to another location fairly readily (e.g., another gate, terminal, etc.). The modular nature of POU systems makes them attractive from a flexibility- of-use standpoint. Since each POU unit is independent, it can be replaced, moved, or upgraded without concern for impacts on other POU units. In order to ensure proper use of alternative systems, airport operators need to work closely with the airlines and their ground handling companies. While securing buy-in from airlines regarding the use of alternative systems is virtually guaranteed at the corporate level, since the systems repre- sent a win-win situation for the airlines (i.e., reduces fuel usage and emissions usually at the expense of the airport operator), it is often more difficult to secure cooperation from airline personnel based at airports and pilots. Airlines play an important role in ensuring the proper use of alternative sys- tems. Airlines need to ensure that their personnel and contractors are both trained and willing to use the alternative systems. Although airlines can potentially fund the construction of alternative systems (either in-part or in-whole), airport operators typically fund and take ownership of alterna- tive systems since they are difficult to relocate to another facility (especially central systems). 2.2 Regulations This section provides some context for regulations that directly or indirectly govern either the use of APUs or alternative systems at airports. Regulations and policies discussed in this section encompass the following: • Airport Rules and Regulations/Policies, • Clean Air Act and General Conformity Requirements, • The National Environmental Policy Act (NEPA), and • The FAA’s VALE Program. The following sections briefly discuss these regulations and policies. 2.2.1 Airport Rules and Regulations/Policies Airport operators enact formal rules and regulations that apply to their tenants across a num- ber of administrative and operational areas. These regulations and/or policies are often reflected in airport lease and use agreements. Such policies can be implemented to reduce emissions as well as to reduce noise exposure. As these policies can vary from airport to airport, users of this Handbook are advised to review the individual policies of their airport. According to the Boeing Commercial Airplane website (Boeing 2011), 25 US airports have restrictions on the use of APUs. These restrictions range from limits on the duration of APU use, to conditions on when the APU can be used (e.g., restriction on APU use during nighttime hours).

12 handbook for evaluating emissions and Costs of apUs and alternative Systems 2.2.2 Clean Air Act and General Conformity Requirements Airport activity is subject to compliance with many federal regulations, including the federal Clean Air Act of 1977 (CAA), as amended. Under the Clean Air Act, the United States Environ- mental Protection Agency (USEPA) has established National Ambient Air Quality Standards (NAAQS) for a series of criteria pollutants, including carbon monoxide (CO), nitrogen dioxide (NO2), particulate matter (PM—coarse and fine particles), sulfur dioxide (SO2), lead (Pb), and ozone (O3). Geographic areas in which concentrations of these pollutants are determined to be in excess of the NAAQS are designated as nonattainment areas (NAAs) and are subject to controls enacted by the state to achieve attainment. While many regions of the United States have achieved attainment of the NAAQS, many are still subject to control plans (called maintenance plans) to ensure continued compliance. These plans (and plans developed to bring the nonattainment areas into compliance of the NAAQS) are referred to as State Implementation Plans (SIPs). The CAA Amendments of 1990 require federal agencies to ensure that their actions conform to the appropriate SIP. Conformity is defined as demonstrating that a project conforms to the SIP’s purpose of eliminating or reducing the severity and number of violations of the ambient air quality standards and achieving expeditious attainment of such standards. Most federally- funded and approved actions or projects at an airport are subject to the “General Conformity” regulations (40 Code of Federal Regulations [CFR] Part 93, Subpart B). General Conformity applies to federal actions occurring in nonattainment and maintenance areas for any of the criteria pollutants. A conformity determination is required for a project/action proposed to be located in a main- tenance or nonattainment area if the project’s total direct and indirect emissions would equal or exceed the annual de minimis emissions levels specified in 40 CFR 93.153. Project-related emissions for airport projects are often found to be de minimis, but projects involving a substantial increase in aircraft operations or notable construction activity often require a conformity determination. 2.2.3 National Environmental Policy Act (NEPA) In addition to the requirements of the Clean Air Act, before undertaking a federal action, the federal agency must first comply with the provisions of the NEPA. Federal actions undertaken by the FAA range from providing federal funding to airport operators to approving airport layout plans. The purpose of NEPA is to consider early in the decision-making process the probable environmental effects of a federal action and to enable decision makers to have this information before making their decision. Two FAA Orders provide guidance regarding airport projects and compliance with the NEPA. FAA Order 1050.1E Environmental Impacts: Policies and Procedures provides overall NEPA guidance for all FAA divisions. FAA Order 5050.4B National Environ- mental Policy Act (NEPA) Implementing Instructions for Airport Projects provides guidance to the Airports Division of the FAA which oversees the review of airport development projects. FAA guidance identifies three paths toward compliance with the NEPA. Certain projects as defined in FAA Orders 1050.1E or 5050.4B, which are shown not to create significant effects (i.e., no extraordinary circumstances), may be categorically excluded from detailed environmental evaluation. For other projects, an Environmental Assessment (EA) is required to determine if significant impacts, as defined in the FAA Orders, would occur. If significant impacts would occur, the FAA is required to prepare an Environmental Impact Statement (EIS). If no signifi- cant impacts would occur, the FAA can issue a Finding of No Significant Impact (FONSI). The use of APUs does not constitute a federal action. However, approval of the installation of PCA or gate based ground power at an airport might be a federal action since the project might necessitate a change in the footprint of the passenger terminal facilities and a revision of the airport layout plan. Installation of PCA and/or ground power is not specifically listed as being

Considerations for planning the Implementation of an alternative System 13 categorically excluded from NEPA review in FAA Order 1050.1E. However, installation of alter- native systems is similar to other actions that are categorically excluded, and thus, that approach is often used to comply with the requirement of the NEPA. 2.2.4 The FAA’s VALE Program The VALE program was established in 2004 through the Century of Aviation Reauthorization Act legislation (VISION 100) to help commercial service airports in designated nonattainment and maintenance areas implement emission reduction actions. The VALE program allows airport spon- sors to use the Airport Improvement Program (AIP) and Passenger Facility Charges (PFCs) to finance the purchase of low emission vehicles, refueling and recharging stations, gate electrification, and other airport air quality improvement projects. As of March 2011, the FAA had funded the installation of PCA and/or ground power at 11 airports through the VALE program (FAA 2011b). As a condition to obtaining a VALE grant, the state in which the airport is located must agree to issuance of Airport Emission Reduction Credits (AERCs). To be AERC eligible, the project/ emissions must meet the following criteria: • Quantifiable—Emission reductions are quantifiable if they can be measured in a reliable manner and the method of calculation can be replicated using a publicly available model. • Surplus—Emission reductions are considered surplus if they are not otherwise required by federal, state, or local regulations or relied on to meet other applicable air quality attainment or maintenance requirements for a particular NAAQS. The emission reductions associated with the use of PCA and/or ground power are considered surplus if there are no applicable federal, state, or local regulations requiring the emission reductions. • Permanent—Emission reductions must be permanent throughout the lifetime of the equip- ment. Since ground power and PCA systems are infrastructure, emission reductions associated with those systems are usually considered permanent by design. • Adequately Supported—The sponsor of the project must have adequate funding, personnel, and resources to implement and verify the approved low emission measures on schedule. • Federally Enforceable Emission reduction measures are generally considered to be federally enforceable if they meet the following criteria: • The measures are independently verifiable. • A complete schedule to implement and verify the measures has been adopted by the airport sponsor. • Violations of the emission reduction credit (ERC) requirements are practicably enforceable in accordance with the Clean Air Act, USEPA and state regulations, and FAA grant assurances. • Liability for violations can be identified. • Required airport emissions-related information is publicly available. The emission reductions are enforceable through FAA’s grant assurance provisions and through the four VALE program special conditions (i.e., tracking, labeling, keeping equipment for its useful life, and replacing equipment in kind). 2.3 Environmental Considerations The main environmental issue driving the implementation of alternative systems at airports is emissions of criteria pollutants and greenhouse gases. Criteria pollutants such as CO, NOx and SOx impact local/regional air quality whereas greenhouse gases such as CO2 potentially have global impacts (i.e., climate change).

14 handbook for evaluating emissions and Costs of apUs and alternative Systems Many airports have recommended controls on the use of APUs or the implementation of ground-based infrastructure to reduce the use of APUs while aircraft are parked. In general, air- craft APUs generate higher noise levels than components of alternative systems (see Chapter 4). APUs and alternative systems are generally not associated with water quality or hazardous waste issues at airports, except possibly in the context of maintenance activities. Aircraft are often the most significant source of criteria pollutant and greenhouse gas emis- sions at airports. While the majority of aircraft-related emissions correspond to the operation of the main engines, APU-related emissions can also be notable. The use of alternative systems can reduce direct/local emissions from APUs, but since alternative systems use grid electricity, there are indirect emissions to consider (i.e., emissions are essentially transferred to the power plants where electricity is generated). Local air quality can potentially be improved by employing alternative systems at airports since their use results in localized reductions of criteria pollutant emissions. The positive effects of alternative systems with respect to global climate change are less pronounced since it does not matter where greenhouse gas emissions occur—unlike criteria pollutants, greenhouse gases are significant at a global level. As discussed later in this Handbook, potential reductions in APU-related emissions of criteria pollutants and greenhouse gases are generally not identical to the increase in emissions at power plants associated with the use of an alternative system at an airport. A variety of factors explain these differences in emissions including the chemical composition and combustion characteristics of jet fuel and coal as well as various other factors including inefficiencies associated with electric power transmission (e.g., energy loss through electric power transmission lines). Although accounting for greenhouse gas emissions at off-site locations may give the appear- ance of life-cycle emissions, only the end-state emissions are addressed in this Handbook. Upstream emissions associated with the manufacture and handling of fuels and equipment are outside the scope of the planning-level assessments described in this Handbook. In addition, data contained in this Handbook regarding emissions associated with electricity production reflect national averages in terms of utility mix (e.g., percent coal-fired power plants vs. hydro- electric, natural gas, etc.). Users with access to higher fidelity (e.g., regionally-specific) data can use that information to compute emissions instead of the national average data presented in the Handbook. 2.4 Costs Airport operators need to carefully consider costs associated with implementing and operat- ing alternative systems since they involve major up-front capital investments and potentially significant operating costs and maintenance expenditures: • Capital costs refer to costs associated with base equipment, installation, and utility infrastruc- ture upgrades necessary to support alternative systems. Typically, POU-style systems have lower initial installed costs, whereas due to the construction costs of the central plant as well as the electrical and mechanical distribution systems required, central systems generally have larger initial capital costs. The modularity of POU systems also provides flexibility in staging the roll-out of these systems since the airport operator has the option to implement the POU systems at a few gates over time. This flexibility allows airport operators and tenants who will use the alternative systems time to adjust to their usage and, in the case of some airports, more options if funding is limited. • Operating costs refer to costs associated with using the alternative systems to supply electric power and heated or cooled air to aircraft. Typically, the largest operational cost is related to purchasing electricity from the local utility company. Central systems typically have lower operating costs due to certain efficiencies that are specific to central systems including thermal

Considerations for planning the Implementation of an alternative System 15 storage. The use of a thermal storage system by central systems allows electrical consumption to be transferred to off-peak billing times. In contrast, POU systems are typically less efficient than central systems and have higher operating costs than central systems. • Maintenance costs refer to costs associated with fixing or upgrading alternative system com- ponents to keep the systems operating properly. Typically, central systems have lower main- tenance costs than POU systems. The differences in maintenance costs between POU and central systems become more pronounced as the quantity of aircraft gates served by the alter- native system is increased. This is due primarily to the fact that in a central system, as the gate count increases, the central plant does not necessarily need to be expanded to accommodate the extra load. That is, the number of chillers and frequency converters at the central plant generally stays the same as the number of serviced gates increases. It is also generally under- stood that central systems tend to use more durable components—industrial-type equipment rather than the commercial type equipment used for POU systems (ASE 2011). Hence, the failure rate for central system components is often less than that for POU systems. To properly compare these systems on a cost basis, life-cycle cost assessments should be con- ducted taking into account varying ranges of numbers of gates expected to be serviced by the alternative systems and the years of expected service. To conduct such assessments, the following variables need to be considered: • Aircraft types or categories expected to be serviced; • Aircraft/APU operations or number of Landing and Takeoff (LTO) cycles; • APU times in mode (TIM) values that the alternative systems will duplicate; • Electric utility costs (both consumption and demand costs); • Natural gas costs (i.e., cost of natural gas used by airport boilers); and • Annual average and seasonal ambient conditions. Life-cycle cost assessments should be completed keeping in mind the life spans for each type of alternative system. For example, POU systems have a life span of approximately 15 years and central systems are considered to have a life span of 20 years or more (ASE 2011). The FAA’s VALE program guidance suggests that POU PCA units have a life span of about 13 years, and POU ground power equipment is expected to have a life span of about 20 years (FAA 2010b). 2.5 Funding There are various potential sources for funding the implementation of alternative systems. These include: • PFC Funds; • AIP Grants; • General Airport Revenue Bond (GARB) or Special Facility Bonds; • VALE program grants; and • Private initiatives (e.g., airline funding). Currently, the PFC program allows commercial service airports controlled by public agen- cies to charge up to $4.50 per enplaned passenger. The money can be used for various pur- poses including safety, security, and environmental improvements. AIP funding is provided by the FAA to support various projects including programs designed to mitigate environmental impacts/concerns. The AIP program is a cost-share program where the FAA will fund 75% to 80% of eligible project costs for large- and medium-sized airports and 95% of eligible project costs for projects at general aviation airports. Bonds can be issued by an airport-owning or related entity to support various airport funding needs including initiatives and development plans. The VALE program is specifically aimed at reducing ground-level emissions from airport activities.

16 handbook for evaluating emissions and Costs of apUs and alternative Systems Although, the source of the funds for the VALE program are PFC and AIP monies (since the VALE program is specifically geared toward reducing airport-related criteria pollutant emis- sions), VALE funds are considered a separate funding source for the purposes of this research. In addition to airport and FAA funding sources, the implementation of alternative systems can be cost-shared with the airlines; however, in most cases the airport operator or the airlines will invest in the systems alone. In those situations where an airline purchases the alternative system equipment, details regarding the ownership of the various pieces of equipment will need to be worked out between the airport and the airline. An important consideration that may influence the choice of implementing POU or central systems has to do with the source of the funding. If the funding is a grant (e.g., through the VALE program) that cannot be used for other purposes, an airport operator may not care as much about the cost differences between different alternative systems and will focus on other aspects (e.g., flexibility of use). When an airport operator has more control over the source of funding (e.g., funds from the PFC program) it may be more difficult to commit significant capi- tal resources to implementing a central system, when the capital outlay for a few modular POU systems is much lower.