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30 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting Comparative evaluation of screened options Screened option 1: Screened option 2: Red YellowGreen Screened option 3: Regulatory Red YellowGreen Screened option 4: Regulatory Red Yellow Red YellowGreen Green Environmental Regulatory Regulatory Environmental Financial Environmental Environmental Financial Logistical Logistical Financial Total Logistical Financial Total Logistical Total Total Selected options to be pursued with a more detailed analysis Figure 5. Methodology for comparative evaluation of the screened options. are no obstacles, yellow means that some obstacles exist that can be remediated, and red means that significant challenges are present and the option needs to be redrawn. Additional detail that can be used to evaluate options against each criterion is discussed in the following sections. 3.5.1 Regulatory What are the main regulatory elements that should be considered in the evaluation of an alternative jet fuel project? There are three general regulatory elements that should be considered in the evaluation of an alternative jet fuel project. For each of these elements, this handbook indicates the main ques- tions and associated information that the airport should consider when evaluating alternative jet fuel projects. For more detailed information, please consult the references indicated in the fol- lowing and in Section 6. In addition, given the complex technical issues surrounding fueling sys- tem and airfield design, engaging an aviation consultant engineer familiar with these topics may be advisable to assist with locating a processing facility. The main regulatory elements discussed here are as follows: FAA policies and regulations Environmental reviews and permitting Energy policy FAA policies: How do FAA policies and regulations affect airport plans to produce and distribute alternative jet fuels? FAA policies and regulations largely control what can or cannot be done in the airport setting. The construction and operation of alternative jet fuel infrastructure is no exception. The FAA

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How Can Alternative Jet Fuels Be Integrated into the Airport Setting? 31 compiles and maintains a number of documents, including Advisory Circulars (ACs), Orders, and references to other documents that should be considered when evaluating the feasibility of placing alternative jet fuel infrastructure in the airport setting. The FAA and FAA-related docu- ments most likely to be relevant for alternative jet fuel projects are as follows (see Section 6.1 for full citations): FAA AC 150/5070-6B, Airport Master Plans FAA AC 150/5200-33, Hazardous Wildlife Attractants on or Near Airports FAA AC 150/5230-4A, Aircraft Fuel Storage, Handling, and Dispensing on Airports FAA AC 150/5300-13, Airport Design FAA Order 5050.4B, National Environmental Policy Act (NEPA) Implementing Instructions for Airport Projects FAA Order 5190-6b, Appendix R, Airport Compliance Manual FAA Order 5190-7, Minimum Standards for Commercial Aeronautical Activities FAA Order 1050.1E, CHG 1, Environmental Impacts: Policies and Procedures, Paragraph 304 Title 14 of the Code of Federal Regulations Part 77, Objections Affecting Navigable Airspace Title 14 of the Code of Federal Regulations Part 139, Certification of Airports National Fire Protection Association (NFPA) 407, Standard for Aircraft Fuel Servicing Best Practices for Environmental Impact Statement (EIS) Management Environmental Desk Reference for Airport Actions Together, these documents point to three key items: (1) compliance with all applicable airport design specifications, (2) an evaluation of environmental impacts, and (3) proper documentation of proposed changes. These items are briefly discussed in the following subsections. In addition to the FAA documents listed previously, it is important to indicate other resources available to jet fuel handlers. For example, the American Transport Association (ATA) pub- lishes ATA Specification 103: Standard for Jet Fuel Quality Control at Airports (ATA 2009c). This document includes recommended specifications that have been developed to provide guid- ance for safe storage and handling of jet fuel at commercial airports. While these recommen- dations are not mandatory, they are very closely followed by all major airlines and airports in the United States. FAA policies: What airport design specifications and standards should be consulted when planning siting and design of an alternative jet fuel processing plant? Alternative jet fuel processing facilities located on the airport are subject to the same FAA policies and regulations governing any other type of airport facility. In particular, on-airport processing plants and storage facilities must comply with FAA AC 5300-13, Airport Design, which forbids locating fuel storage facilities in the runway protection zones (RPZs). In addi- tion, AC 5300-13 does not allow objects not essential to air navigation or ground maneuver- ing purposes, such as fuel processing facilities, in the runway object free areas (ROFAs), run- way safety area (RSAs), or obstacle free zones. Also of importance is 14 CFR Part 77, Objections Affecting Navigable Airspace, which establishes standards for determining obstruc- tions to air navigation by defining criteria for imaginary surfaces that must not be pierced by any structure, including fuel production and storage facilities. Another consideration is that the proposed project must be shown on the airport layout plan (ALP), as indicated in FAA Order 5190-6b. Near-airport and off-airport alternative jet fuel processing plants located outside of the airport limits are not subject to the FAA policies and regulations governing on-airport facilities; however, near-airport and off-airport facilities must still comply with 14 CFR Part 77. For example, objects such as light poles, trees, construction cranes, and even tall buildings (sometimes miles away from the airport) can be in violation of 14 CFR Part 77 and would, therefore, present a potential hazard

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32 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting to aircraft operating in the area. Form 7460-1, Notice of Proposed Construction or Alteration, needs to be completed and filed with the FAA prior to construction for an airspace analysis and determination for either on-airport, near-airport, or off-airport projects. FAA policies: Are alternative jet fuel projects at airports eligible for Airport Improvement Program funding? Costs associated with alternative jet fuel production are not Airport Improvement Program (AIP) eligible. Refining and manufacturing of aviation fuels, whether from conventional or alternative feedstocks, are not aeronautical activities. The handling, storing, and delivery of jet fuels to an airplane may be considered aeronautical activity as long as 100% of the fuel is delivered to aircraft on the airport and not distributed elsewhere. Therefore, on-airport fuel storage is eligible but only using non-primary airport entitlements. Furthermore, since the production of alternative fuels is not an aeronautical activity, leases will need to be at fair market value. For more information, airports are encouraged to contact their local FAA office. Contact information for FAA regional offices is available at http://www.faa.gov/about/office_org/ headquarters_offices/arp/regional_offices/. FAA policies: What items must be considered to ensure compatible planning with existing and future surroundings? Being a good neighbor is often a principle that airports adopt since it can enable a mutually beneficial relationship between airport operators and surrounding developments and avoids potentially costly litigation. In order to avoid conflict with airport surroundings, land-use zoning must be done carefully in the areas near an airport. In general, zoning rules and regulations vary considerably from one jurisdiction to another and it is not practical to summarize them in this document. Airports should consult ACRP Report 27: Enhancing Airport Land Use Compatibility (Ward et al. 2010) for a deeper discussion of this topic. Nevertheless, there are a few general observations that can help airports evaluate alternative fuel projects with respect to zoning: Obstacles to air navigation: The FAA requires that there be no object, man-made or natural outgrowth, 200 ft from the ground level of the airport and within a 3-nautical-mile radius of the established reference point of the airport. Other requirements are listed in Federal Aviation Regulations (FAR) Part 77. Noise assessment: If construction of alternative jet fuel facilities requires modifications to existing airspace procedures, the FAA and airport would need to comply with NEPA require- ments. This may require a proper environmental impact statement (EIS) before the FAA can approve route changes when there is a significant noise impact on the affected population. Noise impacts from the alternative jet fuel facility on the immediate surroundings should also be investigated for potential permitting review requirements. Agricultural land near airports: The FAA recommends against using airport property for agricultural production because agricultural crops can attract wildlife (FAA 1997b). If the airport requires agricultural crops as a means to produce income necessary for the viability of the airport, it needs to follow the crop distance guidelines established in AC 150/5300-13, Appendix 17. Airports should be advised that the FAA may require a wildlife hazard assess- ment (WHA) or a wildlife hazard management plan (WHMP) when specific triggering events occur on or near an airport, as specified in 14 CFR Part 139, Certification of Airports. Such events include an aircraft striking wildlife, an aircraft engine ingesting wildlife, or observing wildlife of a size or in numbers capable of causing an aircraft strike or engine ingestion. The WHA plan must be conducted by biologists with appropriate training and education as spec-

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How Can Alternative Jet Fuels Be Integrated into the Airport Setting? 33 ified in AC 150/5200-36. Agricultural land use is compatible with airport operations from a noise sensitivity perspective (FAA 2001). Environmental reviews: What environmental review requirements should be considered? Jurisdictions at the federal, state, and local levels require permits for those activities or facilities they view as affecting the environment, safety, or equity of the surrounding population. Alterna- tive jet fuel plants affect each of these three components. In general terms, the main categories of interest in the environmental review and permitting process tend to be the following: Water quality, including environmental impact on drinking water, groundwater, wastewater, and surface waters, including storm water, coastal areas, wetlands, and floodplains. Air quality, including environmental impact of gaseous and other emissions. Impacts to endangered species or historic, coastal, or other environmental resources by facility construction, operation, maintenance, or access. Land quality, including solid waste disposal, hazardous waste handling and disposal, and spill prevention, reporting, and cleanup. Land-use planning and zoning, including impacts to shared infrastructure such as roads and railways. Environmental reviews: What guidance is there to meet the environmental permitting requirements? At the federal level, alternative jet fuel projects need to comply with NEPA and applicable laws protecting sensitive environmental resources. NEPA outlines a process by which agencies are required to determine if their proposed actions have significant environmental effects. Depending on the severity of the environmental effects, a categorical exclusion (CE), environmental assess- ment (EA), or EIS may be required (see FAA Order 1050.1E for more information). In particu- lar, the environmental issues addressed in the Environmental Desk Reference for Airport Actions (FAA 2007) or Appendix A of Order 1050.1E should be investigated during the NEPA process. This must occur before the FAA can make a decision on approving an alternative jet fuel facility. For alternative jet fuel projects on the airport, airports should refer to FAA Order 1050.1E, which is the FAA's umbrella guidance for NEPA compliance. Installation of on-airport fuel facil- ities requires the FAA to issue an unconditional approval to an airport layout plan. This requires the FAA to complete its environmental analyses under NEPA and other laws, such as special pur- pose laws, protecting sensitive species (see the Desk Reference for Airport Actions for more infor- mation). Other actions of the FAA that may be applicable to alternative jet fuel production include federal funding and release of federal lands. Additional reviews related to Clean Air Act statutory programs, such as New Source Review and New Source Performance Standards, may be required. These address construction permits or installation of emission control technologies for new facilities or modification of existing major sources that might result from locating an alternative jet fuel facility at or near an airport. Note that these reviews are not limited to non-attainment areas. A Clean Water Act permit may also be required. At the state and local level, there is a high degree of variation in terms of environmental review and permitting requirements and regulations. They often vary from one jurisdiction to the next. Many states are developing review processes and integrated guidance materials on environmental review and permitting activities relative to infrastructure that may be applicable to alternative jet fuel projects (see Section 6.2). Furthermore, the EPA maintains a database of state-specific regulatory information at http://www.epa.gov/lawsregs/states/ index.html#state.

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34 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting How can the FAA's regulatory and environmental review considerations of an alternative jet fuel project be evaluated? To evaluate the regulatory aspects of an alternative jet fuel project, use "Worksheet 2: Regula- tory Considerations," provided in Section 5.2.2. The following evaluation guide is recommended for grading the different options after Table 9 in the worksheet has been completed: Green: The project can meet all regulations and other considerations. (Only boxes in "Meets Regulation/Consideration" column are checked.) Yellow: The project is likely to meet all regulations and other considerations with some extra effort. (Most boxes in "Meets Regulation/Consideration" column and only a few in "Likely to Meet Regulation/Consideration" column are checked.) Red: The project cannot meet all regulatory and other considerations. (One or more boxes in "Does Not Meet Regulation/Consideration" column are checked.) After completing the grading, fill in the appropriate circle in the "Green," "Yellow," or "Red" column in the "FAA regulations and environmental review" row of "Worksheet 6: Evaluation Summary" in Section 5.2.6. Energy policy: What governmental and nongovernmental entities have stated their support for alternative jet fuel projects? Support for alternative jet fuel projects comes from various entities and policies, including the federal government and nongovernmental organizations (NGOs). This section summarizes some of the most visible entities and policies and indicates how they may be helpful to alternative jet fuel projects: The current administration in the White House: The White House has a policy framework that supports both biofuel production and the allocation of funds to aviation fuel sources. These policies include a commitment made in 2009 by the USDA to allocate funds to biofuels development (USDA 2009) and the 2010 Biofuels Interagency Working Group report high- lighting aviation fuel deployment. This report calls for using pre-established market outlets and customer purchase commitments to stimulate production of feedstocks and biofuels (EPA 2010e). These policy support statements culminated in August 2011 with a White House initiative that provides a $510 million, 3-year commitment by the Navy, USDA, and DOE of multiple alternative fuel projects (The White House 2011). White House policy statements are of significance to airports since they can help airport leadership establish priorities and identify agencies tasked by the White House to implement alternative fuel support programs. FAA: The FAA Office of Environment and Energy sets policy and offers programs to monetize the benefits of using alternative fuels. Relevant initiatives sponsored by this office include: NextGen Environmental Working Group: This group, part of the Joint Program Develop- ment Office (JPDO), sets goals for carbon and particle emission reductions associated with aviation traffic growth projections enabled by NextGen. One important use of alternative fuels is to offset carbon growth associated with this traffic growth. Partnership for Air Transportation Noise and Emission Reduction (PARTNER) Proj- ect 20--Emissions Characteristics of Alternative Aviation Fuels: This project character- izes particle emission measurements for a series of alternative fuels (PARTNER 2010a). Airports can use Project 20's measured outcomes to establish actual particle outcomes for specific process outputs under consideration. PARTNER Project 27--Environmental Cost-Benefit Analysis of Ultra Low Sulfur Jet Fuels: This project established the health effects of particles for use in conjunction with the FAA's Aviation Portfolio Management Tool (APMT) suite (PARTNER 2010b). While not an alternative fuel in itself, low-sulfur versions of conventional jet fuel are currently under evaluation by FAA as a possible complement to alternative fuel options to contain sulfur and related particle costs.

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How Can Alternative Jet Fuels Be Integrated into the Airport Setting? 35 PARTNER Project 28--Environmental Cost-Benefit Analysis of Alternative Jet Fuels: This project quantifies aviation-specific GHG emission levels for a range of alternative fuel options that may be proposed for adoption by airports and their stakeholders (PARTNER 2010c). Airports can use these results in conjunction with Section 2.4 to establish the actual GHG benefits for specific feedstocks and processes. The FAA has other programs that may be of interest for alternative aviation fuel projects. These include: Voluntary Airport Low Emissions (VALE) Program: VALE was established in 2004 to help commercial service airports in designated air-quality non-attainment and maintenance areas reduce airport ground emissions (FAA 2011b). VALE allows airport sponsors to use the AIP and passenger facility charges (PFCs) to finance low-emission vehicles and certain infrastructure projects. However, projects that use alternative jet fuels are not eligible for funding under VALE. Participation in the program could still be valuable for airport spon- sors as a means to gain valuable experience structuring projects that reduce air emissions using other clean-energy fuels. Sustainable Master Plan Pilot Program: This program was recently introduced by the FAA and is evaluating ways to make sustainability a core objective at every airport (FAA 2011a). It is funding long-range planning documents at 10 airports around the country. These doc- uments, called Sustainable Master Plans and Sustainable Management Plans, will include initiatives for reducing environmental impacts, achieving economic benefits, and increas- ing airport integration with local communities. The program is projected to end in late 2012. This program may provide valuable information to airports interested in integrating alternative jet fuel projects into their sustainability initiatives. Public/private partnerships and coalitions: Several organizations focused on the development and deployment of alternative jet fuels have been formed over the past few years. These include: Commercial Aviation Alternative Fuels Initiative: CAAFI is a coalition of government and private-sector organizations, including the FAA Office of Environment and Energy; Aero- space Industry Association (AIA), representing manufacturers; ATA, representing airlines; and Airport Council InternationalNorth America (ACINA), representing airports (CAAFI 2010). CAAFI's 350 members represent nearly 250 separate entities, including some 17 U.S. government agencies. CAAFI may be contacted through its public website, www.caafi.org. Airport personnel can also join CAAFI for no membership charge and gain access to all documentation and guid- ance on its password-protected site. ATA/Defense Logistics Agency Alliance: In March 2010, the ATA signed an agreement with the Defense Logistics Agency (DLA, formerly the Defense Energy Support Center or DESC) to pursue joint policies for the purchase of alternative fuels. The alliance seeks to align pur- chasing policies, promote deployment, and pursue common economic policies (ATA 2010b). The alliance covers over 90% of all jet fuel purchased in the United States. It main- tains teams on deployment, contracting, and the environment, and will work with potential project developers to establish means of best accessing those markets. Farm to Fly: The Farm to Fly coalition of interest between U.S. Department of Agriculture, the ATA, and Boeing was formed in July 2010 (ATA 2010a). The coalition brings together agriculture, energy, and aviation interests to support deployment activity, initially working on bottom-up models for developing fuel supplies for aviation regions of the United States. Other regional coalitions: There are regional initiatives focused on partnerships for the de- velopment of alternative fuel projects in specific geographic areas. Examples include the Georgia Center of Innovation for Energy (GCI 2011), the Hawaii Renewable Energy Alliance (HREA 2011), Clean Fuels Ohio (CFO 2011), and the Sustainable Aviation Fuels

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36 Guidelines for Integrating Alternative Jet Fuel into the Airport Setting Northwest (SAFN) in the U.S. Pacific Northwest region (SAFNW 2011a). SAFN just pub- lished a detailed report analyzing and evaluating the potential for alternative jet fuel production in their region (SAFNW 2011b). Aviation-related nongovernmental organizations: The entities listed in the following may help airports in the development and evaluation of alternative jet fuel projects by sharing best practices, case studies, and other expertise. International Air Transport Association and its stated industry goal of carbon neutral growth by 2020 (IATA 2010). Air Transport Association and its policy on alternative fuels (ATA 2010c). Airport Council InternationalNorth America (ACINA) and its sustainability and business policies (ACINA 2010). Sustainable Aviation Fuel Users Group and its policies (SAFUG 2011). Non-aviation-related nongovernmental organizations: There are nongovernmental organi- zations not directly associated with aviation that have participated in alternative jet fuel forums and are aware of the development of alternative jet fuel. Even though their policies are not necessarily focused exclusively on aviation alternative fuels, they offer different perspectives that may be important to consider when evaluating projects. These entities include: Roundtable on Sustainable Biofuels (RSB) and its best practices (RSB 2010). Environmental NGOs: Several environmental NGOs, such as the National Resources Defense Council and the World Wildlife Federation, have participated in alternative jet fuel forums at the request of CAAFI in the United States and the Sustainable Way for Alterna- tive Fuel and Energy in Aviation (SWAFEA) in Europe. Energy policy: What programs exist to fund studies and other nonrecurring investments in alternative jet fuels? Readers should consult with CAAFI to determine which of the programs presented in the fol- lowing can be useful to identify and support potential alternative jet fuel projects at their facilities. The following programs may exist at the federal, state, or local levels: Biomass Crop Assistance Program (BCAP) associated with the 2008 USDA Budget Autho- rization section 9000 for renewable energy (USDA 2010c). Value-added grants and state enterprise grants for rural renewable energy project evaluation and development (USDA 2010p, USDA 2010m). The execution of this type of projects needs to be submitted for funding in many cases through agricultural institutions. One example of this process is afforded by a proposal made via the Soy Bean Growers Association in Ohio (OHSOY 2010) for a brownfield plant conversion to produce alternative jet fuel. Military Title III programs that can enable initial plant construction for national defense priorities (Finnessy 2006). The August 2011 three agency announcement to support the development of advanced bio- fuels is supported by a $510 million commitment (The White House 2011). The rules con- cerning how these funds will be used have not been finalized as of October 2011, but it is expected that this program will be an important source of funding for alternative aviation fuel projects over the next 3 years. Energy policy: What programs exist that may allow recurring support for alternative jet fuel projects? The following policies may take a variety of forms, including tax incentives, insurance for crops, and tax credits for alternative jet fuels. The details of these policies may still have to be refined, so airports are encouraged to contact CAAFI for guidance. These programs may exist at the federal, state, or local levels: