Airport Air Quality Management 101 (2018)

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19 Air quality regulations that apply to airports derive from national environmental laws that apply very broadly. Over time, these laws have resulted in a regulatory structure that sets limits on pollutant emissions from aviation activities and imposes requirements that either limit the growth of or reduce emissions. This section describes the important components of those regu- lations that apply to airports. 6.1 The CAA The CAA is the primary, overarching air quality law in the United States. The CAA establishes EPA as the agency responsible for setting appropriate federal ambient air quality standards and developing regulations to meet those standards. Under the CAA, EPA identified six common criteria pollutants that must be limited or managed to protect public health and environmental welfare against the effects of outdoor air pollution. These pollutants are NO2, SO2, PM, CO, O3, and Pb. For these pollutants, EPA set primary and secondary concentration limits known as the National Ambient Air Quality Standards (NAAQS). The primary limits are health-based standards geared toward protecting people who are sensitive or at risk, including asthmatics, children, and the elderly. The secondary limits are designed to prevent impacts to animals, vegetation, and physical structures, as well as preventing reduced visibility. After establishing the specific standards, EPA works with state and local governments to designate geographic regions as either meeting or not meeting the NAAQS based on the most recently available air monitoring data. Areas with monitored outdoor air concentrations within the NAAQS are considered attainment areas; areas with out- door air concentrations in excess of the NAAQS are considered nonattainment areas. If a non attainment area improves its air quality so that it subsequently meets the NAAQS, EPA will designate the area as a maintenance area. An area may also be designated as unclassifiable when there are insufficient data. While EPA sets most regulatory standards, it works through other agencies to establish programs to reduce emissions and thus achieve the standards. The programs are often source spe- cific, applying to mobile, stationary, or area sources to accom- modate their different operational practices. With respect to aircraft engines, the CAA requires EPA to consult with the FAA and provides the FAA with the authority to enforce EPA’s aircraft engine emissions standards through its certification S E C T I O N 6 Air Environmental Regulations Applicable to Airports Criteria Air Pollutants • Nitrogen dioxide (NO2) • Sulfur dioxide (SO2) • Particulate matter (PM) • Carbon monoxide (CO) • Ozone (O3) • Lead (Pb)

20 Airport Air Quality Management 101 regulations. FAA is responsible for ensuring these regulations do not pose conflicts with safety and other aircraft operational requirements. One important provision of the CAA for airports is general conformity, which ensures that actions occurring in nonattainment or maintenance areas that receive federal funding, support, approval, or permitting are accounted within, or do not in any way interfere with, the attain- ment strategy of an EPA-approved SIP. Thus, through this mechanism, federal agencies ensure that proposed project emissions from their actions at airports located in nonattainment areas conform to the applicable SIP. General conformity requirements apply only to transportation- related (e.g., airport) activities funded by federal agencies in nonattainment or maintenance areas. In summary, the purpose of general conformity is to • Ensure that federal activities do not cause or contribute to new violations of the NAAQS, • Ensure that actions do not increase the frequency or severity of any existing violation of the NAAQS, and • Ensure that attainment of the NAAQS is not delayed. The CAA’s transportation conformity rules similarly apply to federal funding and approval of highway and transit projects occurring in nonattainment or maintenance areas. For other emissions sources at airports, there are a variety of permitting programs administered by state agencies. SIPs are the collection of air quality measurements, modeling, regulations, controls, programs, and other measures used to identify air quality issues and to remedy or prevent violations of the NAAQS. These requirements are the means through which the govern- ment enforces environmental regulations in nonattainment and maintenance areas. The CAA also established the new source review (NSR) program to ensure environmental protection while allowing economic growth. The NSR helps to maintain air quality standards when stationary sources are modified or added. In areas that do not meet one or more of the national air quality standards (e.g., nonattainment areas), nonattainment new source review (NNSR) ensures that new emissions do not slow progress toward cleaner air. NSR is a pre-construction permitting program for stationary sources with three types of permitting requirements: (1) new source review permits are required for new major sources or major sources making a major modification in a nonattainment area, (2) prevention of significant deterioration (PSD) permits are required for new major sources or a major source making a major modification in an attainment area, and (3) minor NSR may be necessary in both attainment and nonattainment areas. These permits are highly dependent on the attain- ment status of the area by pollutant type and the amount of emissions. Because these permits apply only to stationary emission sources, they have limited applicability to airports. Title V of the CAA requires major emitters to have an operating permit. A facility is considered “major” if it has the “potential to emit” more than 100 tons per year of a regulated air pollutant (for some pollutants and source types, the limit is lower for designation as “major”). For an airport, the emissions considered within the 100 tons per year emissions potential would include facili- ties like aircraft refueling and repair operations, central utility plants, power generation facilities, wastewater treatment equipment, emergency diesel generators, and boilers. Major facility oper- ating permits (Title V permits) include applicable facility operating requirements, monitoring requirements, recordkeeping requirements, and reporting requirements. Mobile source emissions from sources such as aircraft, GSE, and motor vehicles are not included as part of Title V. 6.2 NEPA NEPA promotes the general enhancement of the environment and is separate from, although closely aligned with, the CAA. NEPA requires FAA and other federal agencies to consider the environmental impacts of their actions, which could include grants, loans, leases, permits, and

Air Environmental Regulations Applicable to Airports 21 approval of plans or projects. NEPA applies to most airport construction projects dependent on FAA funding or approval. NEPA requires quantifying, evaluating, and addressing GHGs as well as criteria pollutants. Some actions that are subject to NEPA also trigger the CAA’s general conformity provision. Most design and operating constraints that air quality regulations impose on airports flow through FAA. They arise during the agency’s review of an airport’s capital plans (e.g., expansion, facilities modification, and construction planning). Relatively few sources require a permit from a government agency, and these typically relate to operation of station- ary facilities (e.g., incinerator, boiler, central utility plant, or maintenance hangar). Regulations applicable to airports are illustrated in Figure 1. 6.3 Criteria Pollutants from Airport Operations Aircraft, cars, trucks, and other vehicles operating at the airport emit criteria pollutants as a result of the combustion of fuel (see Section 3: Airport Emissions and Sources). Aircraft engines, for example, produce CO2, which makes up about 70% of the exhaust, and water vapor (H2O), which comprises about 30%. Less than 1% of the exhaust is composed of NO2, SO2, CO, and PM. The exhaust also includes partially combusted or unburned hydrocarbons (UHCs) and other trace compounds. Many of the pollutants that form in the combustion process transform when they are emitted to the atmosphere. Some gases condense to form aerosol particles whereas some pollutants chemically react with compounds in the ambient air to produce yet other chemical species. Likewise, cars, trucks, and ground vehicles produce gaseous and particle emissions. Current research indicates that, with regard to airport emissions, the human health effects of PM and NOx are generally the most significant. Most of the aviation-related PM that reaches airport communities is particle emissions that are released on the airport. At most airports, aircraft are the largest source of these emissions. Emissions from boilers dedicated to indoor heating requirements and incinerators used for waste reduction result from fossil fuel combustion. These large stationary emission sources at airports, as well as paint booths and fire-training facilities, are the most likely to be covered by an air quality permit. 6.4 HAPs HAPs are pollutants for which EPA did not establish NAAQS but which are still regulated under the federal CAA because of their potentially adverse effects on human health and the environment. Also known as air toxics, these pollutants are composed of a wide array of organic and inorganic compounds. The toxics identified in an aviation-related emissions inventory will depend on the type of airport sources that are evaluated and, in some cases, the type of fuel and other characteristics of the emission sources. Such emissions are present in the exhaust of mobile equipment including aircraft, APUs, GSE, and motor vehicle engines and, to a lesser extent, Figure 1. Application of air quality regulations to airports.

22 Airport Air Quality Management 101 from boilers, fuel facilities, and other stationary sources. The most common toxics found at airports are formaldehyde, acetaldehyde, benzene, toluene, acrolein, and 1,3-butadiene. Other sources of HAPs associated with airports are regulated under the CAA if their emissions exceed established thresholds and they meet the definition of a major stationary or area source. These may include aircraft repair and maintenance facilities, engine test cells, central heating plants, painting operations, and other airport support services that generate air emissions. 6.5 GHG Emissions CO2, the most abundant GHG, is a nationally regulated pollutant for which there is no NAAQS to set specific emission limits; however, there are recordkeeping and reporting require- ments that apply to airport stationary sources and emission standards that have been adopted for mobile source engines. NEPA also requires assessment of GHG emissions, which includes in addition to CO2 emissions, emissions of methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), hydro- fluorocarbons (HFCs), and perfluorocarbons (PFCs). When preparing an inventory of emissions sources, the emissions are reported as direct, indirect, and optional. For airports, these categories are defined as the following: • Scope 1—direct emissions, which include airport operator emissions associated with fuel necessary to power airport-owned, on- and off-road vehicles and direct energy necessary to power airport facilities such as natural gas, diesel, and fuel oil; • Scope 2—indirect emissions, which primarily includes purchased electricity; and • Scope 3—indirect and optional emissions that include tenant emissions, public ground travel on- and off-airport, and airport employee commute emissions. Within this context, the aviation industry has made significant effort to reduce GHG emis- sions in recent years. The Airports Council International (ACI) developed the Airport Carbon Accreditation (ACA) carbon management certification standard, which is used by airports internationally to manage and reduce their GHG emissions. The Airport Carbon and Emissions Reporting Tool (ACERT) is a tool for tracking and managing progress in an airport’s ACA pro- gram. (A video providing instructions for using ACERT can be found in the Resource Library.) The Climate Registry, an international non-profit organization, has developed a program for measuring, verifying, and reporting climate emissions. Today, many airports voluntarily par- ticipate in these programs to track, manage, and reduce their GHG emissions. Airports began developing sustainability plans several years ago to improve their long-term viability without being forced into action by federal, state, or local regulations. In many of these plans, fuel efficiency and energy conservation are priorities that in turn reduce GHG emissions. 6.6 International Regulation of Aviation Emissions 6.6.1 Current Regulations The EPA and FAA traditionally work within the standard-setting process of the International Civil Aviation Organization’s (ICAO’s) Committee on Aviation Environmental Protection (CAEP) to establish international emission standards and related requirements that individual nations later adopt into domestic law. ICAO has established international certification limits for NOx emissions from jet engines. EPA has adopted ICAO’s certification standards as national regulations. FAA, in turn, enforces these standards through engine certification.

Air Environmental Regulations Applicable to Airports 23 Current NOx emission standards for aircraft engines were established in 2014 and tighten prior standards. This is the fifth change since the original standards were agreed to in 1981. New certification standards for aircraft are regularly being considered to further reduce aircraft total NOx emissions. ICAO also has established aircraft engine certification standards that limit smoke emissions, as measured by a smoke number. The smoke standards took effect in 1983. Since smoke is an indicator of PM emissions, these standards have been indirectly influencing aircraft PM emissions for the past 30 years. ICAO has now proposed PM certification standards for engines that, once finalized, will be adopted by EPA. 6.6.2 Future Regulations The FAA is presently working through ICAO to evaluate policy options to limit or reduce GHG emissions from international aviation, focused on aircraft emissions. ICAO has developed a range of standards, policies, and guidance material for the application of integrated measures to address aircraft noise and engine emissions. Current efforts include progress on new air- craft technology advancement, operational improvements, and development and deployment of alternative fuels. FAA supported CAEP’s development of an aircraft CO2 emission standard. The standard is designed to reduce aircraft CO2 emissions by integrating fuel-efficient technologies into future aircraft design and development. The aircraft CO2 emission standard was developed such that effective improvements observed through the CO2 standard correlate with reductions of CO2 emissions by aircraft during day-to-day operations. ICAO, with the support of FAA and the U.S. aviation industry, developed a global program to reduce GHG emissions from international aviation. The Carbon Offsetting and Reduction Scheme for International Aviation is a policy tool composed of market-based measures (MBMs) designed to achieve environmental goals at a lower cost and in a more flexible manner than is the case with traditional regulatory measures. These efforts contribute to achieving ICAO’s aspirational goal of carbon neutral growth by 2020 using a 2005 baseline. Essential References for Section 6: Air Environmental Regulations Applicable to Airports • Aviation Emissions, Impacts & Mitigation: A Primer, U.S. FAA Office of Environment & Energy, 2015 • Aviation Emissions and Air Quality Handbook, Version 3, Update 1, FAA Office of Environment & Energy, January 2015 • Airport Air Quality Manual, International Civil Aviation Organization, 2011 • Climate Change 2014 – Impacts, Adaptation, and Vulnerability, Fifth Assessment Report of the Intergovernmental Panel on Climate Change, 2014 • Environmental Impacts: Policies and Procedures, FAA Order 1050.1F, July 2015 • National Environmental Policy Act Implementing Instructions for Airport Projects, FAA Order 5050.4B, April 2006 • U.S. Aviation Greenhouse Gas Emissions Reduction Plan, June 2015 • Airport Carbon Emissions Reporting Tool (ACERT), Airports Council International- North America (ACI-NA)