Handbook for Considering Practical Greenhouse Gas Emission Reduction Strategies for Airports (2011)

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Understanding the common greenhouse gas accounting principles, unique characteristics of the airport, and airport’s inventory processes is imperative to selecting appropriate greenhouse gas reduction strategies. This section of the Handbook identifies the following: IV.1 Sources of Airport-Related Greenhouse Gas Emissions IV.2 Boundaries of Airport Greenhouse Gas Inventories IV.3 Mitigation versus Offsetting IV.4 Relationship between Greenhouse Gas Reduction and Other Airport Documents, Processes, and Programs IV.5 Importance of Coordination with Tenants and Other Stakeholders IV.6 Regulations and Voluntary Reporting and Mitigation These sections provide an important foundation for understanding the information presented in the Handbook, AirportGEAR, and the individual Fact Sheets. The information presented in Sections IV.1 and IV.2 is summarized from ACRP Report 11: Guidebook on Preparing Airport Greenhouse Gas Emissions Inventories. IV.1 Sources of Airport-Related Greenhouse Gas Emissions ACRP Report 11: Guidebook on Preparing Airport Greenhouse Gas Emissions Inventories iden- tifies the basic range of sources of greenhouse gas emissions at airports. While every airport is different, and because of the unique sources that may operate at any one individual airport, airport operators should carefully consider the boundaries of their operation and the types of traditional activities at the airport as well as activities unique to that airport. IV.1.1 Traditional Greenhouse Gas Emission Sources at Airports Traditional greenhouse gas emission sources encompass the activities found at the majority of airports and include the following: • Aircraft operations, including auxiliary power units (APUs) • Ground support equipment—the ground vehicles that service aircraft • Stationary source emissions – Facility/building power (electricity, natural gas, oil) – Emergency generator fuel use – Refrigerants 55 S E C T I O N I V Greenhouse Gas Accounting Principles and Other Considerations

• Surface vehicle travel – Airport service equipment/fleet vehicles (i.e., snow removal, aircraft rescue and fire fighting, etc). – Airport employee commute and administrative travel – Tenant support ground travel and employee commute – Public ground travel • Airport recycling • Construction and maintenance project activities As is discussed later, the accounting of greenhouse gas emissions assigns the designation Scope 1, 2, or 3 to each source category, based on the ownership and control of the source discussed later in Section IV.2. IV.1.2 Non-traditional Greenhouse Gas Emission Sources at Airports Many airports have non-traditional sources that operate within the airport that may also warrant consideration in the inventory or emission reduction activities. Section IV.2 identifies considera- tions of the boundaries of a greenhouse gas inventory that warrant consideration. Non-traditional activities, or activities that may not occur at every airport, could consist of the following: • Aircraft maintenance and/or aircraft manufacturing • Farming of residual airport-owned lands • Natural resources extraction (e.g., mining, drilling, etc.) on airport-owned lands • Commercial development use of airport lands The following section identifies the boundaries of the inventory relative to the types of sources that typically occur at an airport. IV.2 Boundaries of Airport Greenhouse Gas Inventories As noted in the previous section, a wide variety of sources of greenhouse gases occur at an airport. Many of the sources of emissions are not owned by the airport operator, and there may be many owners of similar sources at one airport (e.g., multiple airlines, multiple ground transportation service providers). The accounting of greenhouse gas emissions in inventories relies on a set of boundaries that relate to the authority of the inventorying entity over the sources reported. These boundaries are noted by categorizing the emissions (Scope 1, Scope 2, and Scope 3) and depend on the organization represented in the inventory. The boundaries relate to organizational structure and operational boundaries. IV.2.1 Organizational Structure Organizational structure reflects the control through ownership, legal agreements, joint ven- tures, etc. of specific sources. In the case of most airports, the organization boundaries typically represent the following: • A city or county department or division (i.e., aviation department) • An airport authority (which is typically a separate political entity) • A port district (for which the airport may be a single focus or there may be multiple divisions) • A department of a state (i.e., state transportation department, aviation division) When considering organizational source control, thought must be given to activities supplied by sister entities to avoid double counting. For instance, in a city organization, some police and 56 Handbook for Considering Practical Greenhouse Gas Emission Reduction Strategies for Airports

fire departments provide services to the airport. If the inventory is specific to the airport, only the vehicles and activities owned by the airport would be included in the airport inventory. The city police and/or fire department inventory would include the airport police and fire activities, if that other department owned the sources (i.e., vehicles). IV.2.2 Operational Boundaries Once an entity has determined its organizational boundaries in terms of the operations that it owns or controls, it then sets its operational boundaries. When developing a greenhouse gas inventory, emissions are often categorized as Scope 1, 2, or 3. Each scope of emissions indicates the relative amount of control that the airport has over the sources of emissions and, poten- tially, how the airport may be regulated. The WRI adopted the terms “Scope 1,” “Scope 2,” and “Scope 3,” which have become standards for inventories and are defined as follows: • Scope 1 emissions are from sources that are owned and controlled by the entity. For example, emissions from combustion in airport-owned boilers, furnaces, vehicles, etc. are considered to be Scope 1. Scope 1 sources for an airport operator typically include airport service/fleet vehicles, certain stationary sources, airport-owned aircraft, and refrigerant use by the airport operator. Existing and emerging regulations often focus on Scope 1 emissions. • Scope 2 emissions are from the electricity or steam purchased by the airport. In this case, the practice is to associate electrical and steam purchases to the entity that receives the bill, which may or may not be the consumer. Therefore, if the airport operator receives the elec- trical and steam bill and then later invoices its tenants, the airport operator reports all air- port electrical consumption as Scope 2. If tenants are directly billed by the utility provider, the electrical consumption of the tenant is reported as Scope 3. Scope 2 emissions are often included in voluntary reporting registries. • Scope 3 emissions are a consequence of the activities of the entity, but occur at sources owned or controlled by another party. At an airport, these emissions would be associated with ten- ant aircraft operations, tenant ground support equipment, tenant ground vehicle movement, and public vehicular access to and from the airport. Scope 3 emissions can account for up to 90% to 95% of greenhouse gas emissions in an airport’s inventory. Airports may influence Scope 3 emissions but cannot directly control them. Because airports may wish to reflect the influence that they have over emissions of some of their tenants’ activities, inventories may be structured in a way that captures and identifies that influence. These structures maintain the Scope 1/2/3 designations but then organize sources according to influence and control often called “groups” or “categories.” Table IV-1 shows an example inventory as reported in ACRP Report 11 showing three groups reflecting influence and control. As Table IV-1 shows, some airport operators have the ability to control the movement of ground vehicles on airport roadways, but in some cases may not be able to dictate the types of ground vehicles. Other airports have no control over ground access use. Therefore, for those air- ports that wish to reflect their control of airport roadway use, the controllable emissions would be separated from the uncontrollable emissions, but both would be labeled as Scope 3. This type of reporting correctly notes the scope but then also identifies the influence that the entity may have over other sources. As a result, some airports have created three or more categories of emis- sions, reflecting the degree of control that the airport has over Scope 3 sources. In the case of the example in Table IV-1, three categories are shown (airport owned or controlled, tenant owned or controlled, and public owned or controlled). Greenhouse Gas Accounting Principles and Other Considerations 57

IV.3 Mitigation vs. Offsetting One important element of capturing and accounting for emissions is the recognition and explanation of changes in source emissions over time and the actions and strategies designed to reduce emissions. Some refer to this as “taking credit” for an emission reduction. However, “credit” is a term of art used in criteria pollutant emissions evaluations. Credits can refer to many actions, including: • Program Compliance Credit: Gaining recognition for an action by a participant in a program for purposes of achieving compliance with the goals of the program. • State Implementation Plan (SIP) Credit: A form of program compliance credit, where the emission reductions enable criteria pollutant SIP goals to be achieved and are recognized by the USEPA. • Marketable Credit: A commodity reflecting an emissions reduction that can be traded or sold. Marketable credits may or may not enable program compliance. For greenhouse gases, these are often also referred to as offsets. Because of its other uses, “credit” should be used with caution in reference to greenhouse gas. Mitigation and offsetting are terms used for greenhouse gas. Actions and strategies that the air- port operator has taken to reduce emissions from sources it owns or controls reflect mitigation. Offsetting reflects the actions or strategies taken to reduce emissions from sources that are not owned or controlled by the sponsor, and include the purchase of commercially available emis- sion reduction credit(s) for actions on- or off-airport. 58 Handbook for Considering Practical Greenhouse Gas Emission Reduction Strategies for Airports Table IV-1. Example of airport-wide emissions inventory. User/Source Category WRI Scope Current Emissions (metric tons CO2e) A: Airport Operator Owned/Controlled 004,142noitpmusnoclacirtcelE 000,11liognitaeh&saglarutaN 000,011selcihevteelftropriA Ground access vehicles (all vehicles on airport roads) 1/3 14,567 769,66dellortnoC/denwOrotarepOtropriAlatoT B: Airlines/Tenants/Aircraft Operator Owned/Controlled tfarcriA 000,0413dnuorG 000,7023tf000,3otdnuorG 000,098,13tf000,3evobA 000,732,2)tfarcriA(latotbuS 000,033sUPA 045,63tnempiuqetroppusdnuorG 872,13selcihevsseccadnuorG 03rewopytilicaf/secruosyranoitatS Total Airlines/Tenants/Operator Owned/Controlled 2,274,818 C: Public Owned/Controlled 764,5323selcihevcilbuP 764,13selcihevetavirpdnaselttuhS Total Public Owned/Controlled 236,934 Total Categories A–C 2,578,719 )258(gnilcyceretsaW 768,775,2snoissimElatoTdnarG Source: Modified from ACRP Report 11 (Table 1-1)

It was beyond the scope of ACRP Report 11 to address how mitigation and offsetting were to be reflected in an airport’s emissions inventory. However, a few airports have embraced mitigation planning in the presentation of their inventories. The inventory format shown in Table IV-1 would form the basis for further reporting mitigation or offsets. To illustrate the emission reduction, a supplemental table should be created to note what the emissions would have been if the action had not been taken. Table IV-2 provides an example of how mitigation can be captured in the inventory. The supplemental table would present a condition referred to as the Business as Usual (BAU) condition, or the without-mitigation-or-offset information. BAU should reflect the condition that would be expected in a specific timeframe as if the mitigation or offsetting action had not occurred. Often the BAU requires projections or estimates that reflect a linear projection of emissions based on the ratio of activity to a known emission level. Then a comparison of BAU emissions to the actual emissions indicates a change. In many cases, the emission change can be directly traced to an action taken by the airport. In other cases, the change is due to a change by another party, particularly a party that owns or controls the source (e.g., an airline or the FAA). As Table IV-2 shows, to provide transparency of the emissions change, the inventory should note the emissions with and without the action that was taken, so that it is clear how a declared emissions change occurred. IV.4 Relationship Between Greenhouse Gas Reduction and Other Airport Documents, Processes, and Programs While emission reduction actions should be coordinated with the airport’s inventory, not every airport has or would be expected to generate a greenhouse gas emissions inventory. Many other airport processes and programs will influence when, how, and where airports consider emission reduction strategies. Each of these processes or programs was considered in the review of the emission reduction strategies documented in Section II. These activities could include the following: • Financial issues and grant assurances • Planning and development, including Capital Improvement Projects • Airport energy management and operational practices The following subsections briefly discuss these activities. IV.4.1 Financial Issues and Grant Assurances With specific exceptions, most US airports are owned by units of local government (cities and counties). Some states also own and operate airports, and some governmental entities have created authorities to oversee airports, such as airport authorities or port districts. Airport ownership itself would not affect the mitigation practices other than reflecting the ownership and control of the sources, noted in Section IV.2. Aviation is a highly regulated industry, with considerable financial and operational oversight. Federal statutes and rules typically take priority over (and in many cases preempt) state and local regulation. This is particularly true in the case of airports, which, in addition to being closely monitored by the FAA for safety and other purposes, are highly dependent on FAA fund- ing for capital improvements. In implementing emission reduction strategies, airport opera- tors must comply with a complex regulatory scheme that is overseen by the FAA but also subject Greenhouse Gas Accounting Principles and Other Considerations 59

60 Handbook for Considering Practical Greenhouse Gas Emission Reduction Strategies for Airports Mitigation Summary )047,87(wolebyrammuseeSnoitagitimderosnops-rotarepotropriA )000,1()000,1(–stesffoderosnops-rotarepotropriA Emissions change due to activities by another party Unknown (12,480) Airport Operator-Sponsored Mitigation Summary Implementation of gate PCA/400 Hz power = Change in APU use (aircraft APU fuel )000,8(000,22000,033)noitpmusnoc = Project-related electrical consumption 2 41,400 41,700 + 300 Subtotal (7,700) Building energy efficiency action (reduction effect) = Installation of energy efficient lighting main )000,1(007,04007,142lanimret = Installation of energy efficient lighting )004(003,04007,042EesruocnoC )004,1(ANANlatotbuS lanimrettropriaotliarthgilfogninepO = Reduced public travel to airport on surface road 3 235,467 164,827 (70,640) = Increase in airport electrical consumption 2 40,300 41,300 + 1,000 )046,96(latotbuS )047,87(noitagitiMderosnopS-rotarepOtropriAlatoT Business as usual reflects emissions if emission reduction action(s) had not been implemented. Actual emissions reflect actions that have been taken to reduce emissions. NA: not applicable as both represent emissions from electrical and cannot be added. User/Source Category WRI Scope Emissions (Metric Tons CO2e) Business as Usual Actual with Mitigation Change Airport Operator Owned/Controlled )001(003,14004,142noitpmusnoclacirtcelE 000,1000,11liognitaeh&saglarutaN –000,01000,011elcihevteelftropriA Ground access vehicles (all vehicles on airport roads) 1/3 14,567 14,567 – Subtotal Airport Operator Owned/Controlled 66,967 66,867 (100) Airlines/Tenants/Aircraft Operator Owned/Controlled Aircraft )002,4(008,531000,0413dnuorG )082,8(027,891000,7023tf000,3otdnuorG 000,098,13tf000,3evobA 1,890,000 – )084,21(025,422,2000,732,2latoTtfarcriA )000,8(000,22000,033sUPA –045,6045,63tnempiuqetroppusdnuorG –872,1872,13selcihevsseccadnuorG AN3rewopytilicaf/secruosyranoitatS NA NA Subtotal Airlines/Tenants/Operator Owned/Controlled 2,274,818 2,254,338 (20,480) Public Owned/Controlled )046,07(728,461764,5323selcihevcilbuP 764,13selcihevetavirpdnaselttuhS 1,467 – Subtotal Public Owned/Controlled 236,934 166,294 (70,640) Total Airport, Tenant, and Public Source Emissions 2,578,719 2,487,499 (91,220) –)258()258(gnilcyceretsaW –stesffodesahcrup-rotarepotropriA (1,000) (1,000) GRAND TOTAL AIRPORT-WIDE EMISSIONS 2,577,867 2,485,647 (92,220) Table IV-2. Example inventory that identifies mitigation.

to oversight laws (e.g., city and county ordinances) as well as the contracts between the airport operator and its tenants. The Airport Improvement Program and its predecessor the Airport Development Aid Pro- gram (ADAP) have been notable sources of federal dollars at an average airport. An AIP grant to an airport can cover a substantial portion of the costs of improvements addressing airport safety, capacity, security, or environmental projects, at up to 95% of the project cost. Such grants require compliance with a list of 39 “grant assurances” as a condition. The other primary source of funds at larger commercial service airports is the Passenger Facility Charge, which has notable FAA oversight. The grant assurances not only apply to the federally funded improvements but also to all of an airport’s operations, as acceptance of these funds designates the airport as a public use airport. Likewise, although some of these conditions have a limited term, others are perpetual. Thus, the requirements imposed by grant assurances are relevant to not only airport operators themselves but also their tenants and other users. These assurances can affect either how monies are collected and used or the types of programs that are in place. The important grant assurances relevant to greenhouse gas emission reduction strategies include the following: • Grant assurance 5 requires that the airport not sell, lease, or encumber any part of its title or other interests in the property. • Grant assurance 16 requires conformity of the airport with plans and specifications. Specifi- cally “any modification to the approved plans [Airport Layout Plans], specifications, and schedules shall also be subject to approval of the Secretary. . . .” • Grant assurance 19 requires the airport to be operated at all times in “a safe and serviceable condition” and in accordance with the minimum standards. • Grant assurance 22 requires that the airport must be available as an airport for public use on reasonable terms and without unjust discrimination to all types, kinds, and classes of aero- nautical activities, including commercial aeronautical activities offering services to the public at the airport. • Grant assurance 24 requires the airport to maintain a self-sustaining fee and rental structure. • Grant assurance 25 requires airport revenues to be used only for aeronautical purposes. The FAA can prohibit the airport operator from receiving AIP funds if the airport is found in violation of a grant assurance and does not bring itself into compliance. Section II documents the evaluation criteria and information for strategies identified by this study. Reflected in that analysis of the individual emission reduction strategies was the potential for airport operators to become in conflict with grant assurances. Airports are encouraged to con- sult the FAA concerning potential conflicts if strategies to reduce emissions are not currently part of their current operation. IV.4.2 Planning and Development, including Capital Improvement Projects Once an airport has received federal funding, its facilities must then continue to conform to the currently approved Airport Layout Plan (ALP) per grant assurance 16. Planning at airports can take many forms, including a Master Plan, ALP Updates, Sustainability Plans, documenta- tion under the National Environmental Policy Act (NEPA), and/or general mitigation planning. Guidance concerning airport development project planning is found in FAA Advisory Circular (AC) 150/5070-6B, Airport Master Plans, and other FAA Advisory Circulars. While the FAA has guidance concerning facility planning, airport operators are not required to follow a specific planning process, as that process can be tailored to local needs. However, airport facility layouts Greenhouse Gas Accounting Principles and Other Considerations 61

are subject to airport design standards to ensure consistency and safety. These standards are defined through a number of Advisory Circulars, including AC 150/5300-13, Airport Design. In analyzing the strategies documented by this project, a review of FAA Orders and Advi- sory Circulars was conducted. For instance, if an airport was undertaking planning for a replacement hangar, the tools developed for this project could be consulted concerning var- ious facets associated with the administration, planning, design, construction, and operation of the replacement hangar. Examples of how greenhouse gas emission reduction strategies might be reflected in airport planning and development could include the following: • Climate Action or Sustainability Planning where broad-based policies for reducing emissions are being considered. The Handbook and AirportGEAR could be used to aid in identifying emission reduction actions or strategies for inclusion in those plans and how they might achieve goals and objectives in these plans. • Project/Capital Improvement Project (CIP) Planning. As airports consider individual devel- opment projects, the Handbook and AirportGEAR can be used to illuminate issues, benefits, and costs associated with various strategies that could be embraced in the project. IV.4.3 Airport Energy Management and Operational Practices Airport energy management (AEM) activities can consist of planning and development activities or general facility management. Airport facilities use large amounts of energy. The ter- minal facilities—the facilities that host passengers using commercial service airports—are the largest consumers of airport energy (e.g., lighting, heating, ventilation, air conditioning, etc.). Because of this consumption and associated financial cost, some airport operators have reduced operating expenses by focusing on energy efficiency, considering both energy supply and energy consumption. Airports have initiated energy audits and in some cases have assigned job responsibilities to airport staff for energy management. It is anticipated that the Handbook and AirportGEAR will be useful tools for airport staff and other parties interested in managing and conserving energy use associated with airport facilities. IV.5 Importance of Coordination with Tenants and Other Stakeholders Given that many of the largest sources of emissions at airports are controlled by tenants or affect emissions of tenants (see Table IV-3), airport operators are encouraged to coordinate with their tenants (1) to accurately inventory these sources and, (2) if seeking emission reductions, to 62 Handbook for Considering Practical Greenhouse Gas Emission Reduction Strategies for Airports Airport Airport Owned/Controlled Tenant Owned/Controlled Public Airport Access Owned/Controlled ONT 1.5% 81.1% 17.4% SAN 1.5% 92.3% 6.1% SEA 1.4% 90.4% 8.0% PDX 2.6% 88.4% 9.0% LAX 1.7% 93.4% 4.9% Aspen 2.6% 95.4% 2.0% Hillsboro 0.5% 95.8% 3.6% Van Nuys 0.9% 90.5% 8.6% Source: Synergy Consultants, based on reports by the airports above. Table IV-3. Distribution of emissions by ownership and control.

coordinate and communicate with these parties concerning feasibility and cost-effective emis- sion reduction actions. Based on a few inventories prepared to date, the distribution of emissions based on owner- ship and control indicates that the airport operator can control a small portion of emissions associated with an airport (on average less than 3% of the total airport-related emissions). How- ever, airport operators may be in a position of supporting the emission reduction of its tenants (i.e., airlines, aircraft operators, tenants, etc.) as well as the public that uses the airport. There- fore, this Handbook recommends that as airport operators consider plans to reduce greenhouse gas emissions, they coordinate with the tenants and public users. There are an extensive number of example actions that airport operators can take to reduce emissions associated with their tenant and public activities. The example in Table IV-2 identi- fies two actions that were taken by the airport: one that affected emissions by the airlines using one of the concourses and another that reduced the public ground travel emissions. First, the installation of pre-conditioned air/400-hertz power at the gates reduced aircraft operator APU emissions (a Scope 3 emission), while slightly increasing airport electrical consumption (a Scope 2 emission). This action resulted in a net reduction in airport-wide emissions as shown. Because the substantial majority of emissions at an airport (typically over 90% of total airport- related emissions) are owned and/or controlled by other parties (i.e., tenants and the public), airport operators are encouraged to work with these parties to identify and implement strategies that are mutually beneficial in reducing greenhouse gas emissions. IV.6 Regulations and Voluntary Reporting and Mitigation The Handbook and AirportGEAR can aid airport operators in complying with federal, state, and local regulations and emissions reporting and mitigation. This section of the Handbook discusses the regulations and requirements that were in place at the time of publication. Regulatory require- ments are evolving and the airport operator should refer to current legislation. Potential future requirements are also included here as an example of the types of legislation that may be encountered, even though the information listed may be outdated shortly after publication. At the time of this publication, greenhouse gas mitigation activities are voluntary unless an airport has committed to mitigation measures as part of NEPA or state regulation, such as the California Environmental Quality Act (CEQA) or the Massachusetts Environmental Policy Act (MEPA). IV.6.1 Current Regulations and Requirements In December 2009, the USEPA Administrator signed two important greenhouse gas findings: • Endangerment Finding: The Administrator found that the current and forecast concentra- tions in the atmosphere of six key greenhouse gases threaten the public health and welfare of current and future generations. • Cause or Contribute Finding: The Administrator found that the combined emissions of greenhouse gases from new motor vehicles and new motor vehicle engines contribute to the greenhouse gas pollution that threatens public health and welfare. While these findings themselves do not place any regulatory or mitigation requirements upon airport operators and airport-related activities, under current US regulatory schemes, they would be a prerequisite to anticipated future controls on mobile sources. Subsequent to the findings, litigation has been brought seeking to overturn the findings. Greenhouse Gas Accounting Principles and Other Considerations 63

As the USEPA moves to place regulatory requirements on greenhouse gas emissions, it has promulgated the following requirements: • Mandatory Reporting of Greenhouse Gases Rule. The rule requires reporting of greenhouse gas emissions from specific sources—relatively large emitters and suppliers of fossil fuels or industrial greenhouse gases—to enable the USEPA to collect emissions data to inform future policy decisions. Under the rule, suppliers of fossil fuels or industrial greenhouse gases, manu- facturers of vehicles and engines, and facilities that emit 25,000 metric tons or more per year of greenhouse gas emissions are required to submit annual reports to the USEPA. In addition, facil- ities that operate certain sources, such as power generators, are automatically triggered to report under this rule, regardless of whether or not the threshold of 25,000 metric tons is exceeded. • Greenhouse Gas Emissions Standards and Fuel Economy Standards. In April 2010, a final rule occurred covering model years 2012 through 2016 for passenger cars, light-duty trucks, and medium-duty passenger vehicles. The rule making requires these vehicles to meet an esti- mated combined average emissions level of 250 grams of carbon dioxide per mile, which is equivalent to 35.5 miles per gallon if the automobile industry were to meet this carbon diox- ide level solely through fuel economy improvements. • Stationary Source Emissions (Prevention of Significant Deterioration/Title V Tailoring Rule). Historically, stationary sources subject to certain emissions levels were subject to exten- sive regulations under the Clean Air Act New Source Review process. The USEPA refined these regulations to include greenhouse gases (i.e., tailoring rules). Starting in 2011, existing and new major sources of greenhouse gases, defined currently as those facilities emitting 75,000 metric tons of carbon dioxide equivalent or more per year, will be subject to Title V permitting, which could include restrictions and controls for greenhouse gas emissions. At this time, it is expected that airlines, as corporate entities, are subject to these requirements and that approximately 10 to 20 US airports meet the requirements to report their greenhouse gas emissions, particularly those airports that have co-generation plants. A smaller subset of these airports may also be subject to the Title V Tailoring Rule. It is recommended that airport oper- ators conduct a greenhouse gas inventory to determine if the regulatory thresholds of 25,000 metric tons for the Mandatory Reporting Rule and 75,000 metric tons for the Title V Tailoring Rule are exceeded. Many of the airline partners operating at the nation’s commercial service international air- ports are also subject to various emissions trading schemes (Europe and Australia). The most widely debated, given the amount of air traffic, is the European Union Emission Trading System (EU ETS). Under the EU ETS, implementation has occurred in stages, with the initial focus having been on the largest sources of emissions. These large emitters must monitor and annu- ally report their carbon dioxide emissions. Starting January 1, 2012, aviation emissions will be subject to the EU ETS. For emissions in excess of their designated allowance, parties are required to either reduce emissions or purchase offsets. Litigation by US carriers was initiated over the EU ETS. Prior to the 2009 USEPA actions and recent national level legislative efforts, many states and local communities, feeling that the federal government was not acting aggressively enough to address climate change, began to enact requirements to reduce greenhouse gases. Regional emis- sions reduction programs include the following: • Regional Greenhouse Gas Initiative (RGGI). RGGI has established a cap-and-trade program affecting power plants with generating capacity of 25 MW or greater. A cap-and-trade system is an economic incentive program designed to reduce emissions by establishing a cap and enabling those who emit under the cap to sell their unused emissions allocation to those who are not able to reduce emissions in as cost effective a manner. 64 Handbook for Considering Practical Greenhouse Gas Emission Reduction Strategies for Airports

• Western Climate Initiative (WCI). WCI members agreed to jointly set a regional emissions target and establish a cap-and-trade program covering multiple economic sectors. The green- house gas emissions target for WCI members is 15% below 2005 levels by 2020, or approxi- mately 33% below business-as-usual levels. The regional target is designed to be consistent with existing targets set by individual member states and does not replace these goals. A cap- and-trade program, beginning in 2012, will cover emissions from electricity and large indus- trial and commercial sources and, beginning in 2015, will cover emissions from transportation and other residential, commercial, and industrial fuel use. • Midwest Greenhouse Gas Reduction Accord (MGGRA). MGGRA members agree to estab- lish regional greenhouse gas reduction targets, including a long-term target of 60% to 80% below current emissions levels, and to develop a cap-and-trade system to meet the targets. Par- ticipants will also establish a greenhouse gas emissions reductions tracking system and imple- ment other policies, such as low-carbon fuel standards, to aid in reducing emissions. In addition, an extensive amount of state and local level emissions programs are in place and are too numerous to list. IV.6.2 Potential Future Regulations and Requirements At the time this Handbook was prepared, the primary federal, state, and local regulations gov- erning greenhouse gases require one or more of the following: • Reporting of annual emissions over a designated threshold (i.e., USEPA mandatory report- ing rule requiring facilities generating more than 25,000 metric tons, WCI requiring reporting for facilities over 10,000 metric tons). • Increased production and use of renewable energy where states and local government are seeking to use a greater quantity of renewable energy. • Emissions standards and/or fuel consumption/economy standards. While federal level car- bon dioxide emissions standards have not been promulgated, fuel consumption standards for surface vehicles have been promulgated not only on the federal level, but by several US states (California, Oregon, Washington) as well. In addition, meetings of the International Civil Avi- ation Organization have discussed various aircraft-related energy efficiency goals. • Mitigation. Such requirements would principally arise from state or local climate action laws that seek to achieve an emissions reduction in the future relative to a past emission. However, international and some regional programs have adopted a cap-and-trade requirement that could require emissions reduction. The following legislative efforts that are under deliberation in the US House of Representa- tives and Senate are indicative of these types of likely future requirements: • The American Clean Energy and Security Act of 2009 (H.R. 2454, also known as the Waxman- Markey Bill) as passed by the House would establish an economy-wide, greenhouse gas cap- and-trade system and critical complementary measures to help address climate change and build a clean energy economy. Except in unusual conditions, this act would not be expected to apply to airports unless airports are producing power or fuels or operate large stationary sources emitting more than 25,000 tons per year of greenhouse gases. The act would establish emission caps that would reduce emissions for all covered entities to 3% below their 2005 lev- els in 2012, 17% below 2005 levels in 2020, 42% below 2005 levels in 2030, and 83% below 2005 levels in 2050. The proposal also calls for regulations to limit black carbon emissions in the United States. • The Senate’s Clean Energy Jobs and American Power Act of 2009 (S. 1733, known as the Kerry-Boxer Bill) would establish a cap-and-trade system to reduce greenhouse gases. Simi- lar to the House Waxman-Markey Bill, this legislation would not be expected to directly affect Greenhouse Gas Accounting Principles and Other Considerations 65

airports other than in cases where there are large stationary sources or where the airport gen- erates power. The act would establish emission caps that would reduce emissions for all cov- ered entities to 3% below their 2005 levels in 2012, 20% below 2005 levels in 2020 (lower than that of the House bill), 42% below 2005 levels in 2030, and 83% below 2005 levels in 2050. • The American Power Act (Kerry-Lieberman Bill) is similar to the Waxman-Markey Bill as well as the Kerry-Boxer Bill with an economy-wide cap-and-trade system. Transportation fuels would be regulated at the point of distribution or import. In addition, this bill includes a “hard collar” on the price of carbon offsets. • The Carbon Limits and Energy for America’s Renewal Act of 2009 (S. 2877, known as the Cantwell-Collins Bill) would require greenhouse gas emissions to be reduced by 20% relative to 2005 levels by 2020, 30% relative to 2005 levels by 2025, 42% relative to 2005 levels by 2030, and 83% relative to 2005 levels by 2050; these levels are similar to the Kerry-Boxer Bill. The act would require the Secretary of the Treasury to establish a program to reduce emissions by (1) placing a gradually declining limitation on the quantity of fossil carbon permitted to be sold and (2) requiring each first seller to surrender periodically a number of carbon shares equal to the quantity of covered carbon it produces or imports. • The American Clean Energy Leadership Act of 2009 (S. 1462), similar to H.R. 2454, con- tains extensive provisions concerning energy production, energy efficiency, renewable energy standards, etc. • The Clean Energy Act of 2009 (S. 2776) was introduced by Senators Webb and Alexander to promote investment and development of clean energy technologies, including nuclear power and other resources. It would result in the expenditure of $20 billion over 20 years to fund a series of loan guarantees; nuclear education and workforce training assistance; research into nuclear reactor lifetime extension; and the development of solar power, biofuels, and alterna- tive power technologies. • The Clean Energy Partnerships Act of 2009 (S. 2729) would require the Secretary of Agricul- ture and the USEPA to establish (1) a program to govern the creation of credits from emis- sion reductions; (2) an advisory committee to provide scientific and technical advice on the establishment and implementation of such an offset program; and (3) a carbon conservation program to provide incentives to implement projects that reduce greenhouse gas emissions through conservation easements, sequestration contracts, and timber harvest or grazing con- tracts. It would require the USEPA to establish a registry to record approved credits issued under such an offset program. 66 Handbook for Considering Practical Greenhouse Gas Emission Reduction Strategies for Airports