Directors and environmental compliance managers at commercial service airports around the country face increased demands from ever-changing air quality regulations. It’s often difficult to navigate the myriad of air rules and controls required by federal, state, or local agencies.This is especially true as the U.S. Environmental Protection Agency (EPA) continues to rapidly review and revise limits for the most common pollutants. Strengthening these limits, known as National Ambient Air Quality Standards (NAAQS), will cause many areas currently defined as healthy areas (i.e., attainment areas) to become unhealthy (i.e., non-attainment) for one or more of the standards. Therefore, it’s important for airports to keep up with non-attainment area requirements. Often, these requirements can affect program decisions for capital projects such as airport expansions and airport operations. Federally sponsored facilities must also comply with the National Environmental Policy Act (NEPA) for capital projects.
Air Quality Designations
The NAAQS are set by EPA to protect public health and the environment from six of the most common air pollutants. Standards are set for carbon monoxide, lead, nitrogen dioxide, particulate matter (PM10), fine particulate matter (PM22.5), ozone, and sulfur dioxide. The Clean Air Act (CAA) requires EPA to review and revise, if necessary, these standards every five years. No later than one year following a revision of an air quality standard, states or tribes must submit recommendations to the EPA identifying areas that do not meet the revised standard. However, the EPA Administrator may require the recommendations to be submitted sooner. Assuming the data is sufficient, EPA must finalize designations no later than two years following promulgation of a new or revised standard. Once EPA finalizes the designations, states, tribes, or local governments have three years to submit plans that show how they will attain the standards. Areas that do not meet the standards are known as non-attainment areas.
Due to a backlog, EPA is now promulgating revisions to the NAAQS at a rapid pace. Once an area is designated non-attainment, facilities in this area become subject to new requirements like New Source Review, Reasonably Available Control Technology, and General Conformity Programs. General Conformity requires airports to offset emissions before expansions or modifications at the airport are approved. Airports in these areas remain subject to the General Conformity regulations for many years after the area attains the standard and becomes a maintenance area.
Increasing numbers of non-attainment areas
Overall, the number of counties designated as nonattainment or maintenance (and therefore subject to General Conformity) for the criteria pollutants has nearly doubled in the past ten years. In 2000, 685 counties were designated either as non-attainment or as maintenance for all of the criteria pollutants. As seen in Table 1, many of these counties were designated as nonattainment or maintenance for more than one criteria pollutant. In 2010, more than 1,000 counties were designated either as nonattainment or maintenance. During the past 10 years, many of the standards revised by the EPA are more stringent than the previous standard. In some cases, the form of the standard has also changed. The zeroes in Table 1 are cases where the EPA revised the form of the standard. As Table 1 illustrates, the most dramatic increases were in ozone and particulate matter. The lead standard was recently revised and 17 new areas were identified as nonattainment during the first round of designations. It is anticipated that more areas will be added during the second round. The lead designations will be important to some commercial service airports.
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Table 1. Number of Counties Listed as Nonattainment or Maintenance for Primary NAAQS[1] |
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According to the Federal Aviation Administration (FAA), there are 494 commercial service airports in the U. S. Approximately 155 of these airports are located in nonattainment or maintenance areas and are thus eligible for Voluntary Airport Low Emission (VALE) funding. The number of airports in non-attainment areas is expected to increase in the near future once ozone designations are finalized. |
Opportunities
The above sections describe some of the requirements and challenges airports may experience in the near future. However, there are opportunities to help promote a healthy environment while updating airport infrastructure and equipment. One such opportunity is the Federal Aviation Administration’s (FAA) VALE Program.
In 2003, Congress enacted a law to help commercial service airports meet their obligations under the CAA and improve air quality in areas with unhealthy air. The Vision 100-Century of Aviation and Reauthorization Act (Vision 100) directed FAA to establish a voluntary emissions reduction program to improve air quality at commercial service airports in nonattainment or maintenance areas. Subsequently, in 2005, FAA established the VALE Program. VALE provides funding to airports in nonattainment or maintenance areas to upgrade existing stationary or mobile sources utilizing low emission technologies. Depending on the size of the airport, 75 percent or 95 percent of eligible costs for clean technologies can be funded. In addition, participants can earn emission credits to meet current or future CAA requirements. The VALE program has provided $82.5 million for airport improvements, which has resulted in a total of $108 million for improvement projects. Figure 1 shows a breakdown of the main project categories funded through the VALE program:
Many of the measures that help airports comply with CAA requirements on capital projects and in airport operations will also support sustainability objectives. These measures can produce a number of co-benefits to aviation operations, including increased competitiveness through reduced operating and life-cycle costs, reduced environmental impacts, enhanced community relations, and lower overall business risk.
Figure 1. Project Categories Funded by VALE since 2005[2]
Summary
The challenges posed by increasingly stringent air quality regulations can seem daunting for airport managers. Standards are being revised at a rapid pace and it can be difficult to keep up with the increasingly strict requirements. In fact, the eight-hour ozone standard is currently being revised and will likely result in many additional non-attainment areas. At the same time, there are programs like VALE that offer airport sponsors a unique opportunity to update equipment and infrastructure at a subsidized cost while reducing air pollutants in unhealthy areas. Airport managers should keep abreast of both the compliance requirements and opportunities that exist related to improving air quality at airports, improving community relations, and updating airport infrastructure and equipment.
