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67 1. Replace Refrigerants with Natural or Lower Global Warming Potential Gases, Incorporate Intelligent Fault Diagnosis for HVAC Refrigerant Systems, and Install Microchannel Components and Heat Exchangers (ACRP 56 RF-01, RF-02, RF-04) Airports can reduce hydrofluorocarbon emissions by retrofitting or replacing systems to use alternative re- frigerants that have lower global warming potential. It is of note that under the Montreal Protocol, designed to protect the stratospheric ozone layer, hydrofluorocar- bons will be virtually phased out by 2020, after which they can no longer be manufactured.694 Airports can also reduce the GHG impact of refriger- ants by preventing equipment leaks and recovering refrigerants when no longer in use to prevent their re- lease into the ambient air.695 For example, airports might consider incorporating intelligent fault diagnosis for HVAC refrigerant systems, which allows for more effective detection of leaks. Such real-time performance monitoring can be particularly helpful in the detection of slow leaks, which are difficult to detect with conven- tional refrigerant sensors. Airports can also reduce the amount of refrigerant that is needed in a heating and cooling system by installing components such as micro- channel components and multilouver fin heat exchang- ers. These technologies can replace older, less efficient technologyâthis added efficiency contributes to reduc- ing GHG emissions. Additionally, these components are smaller than conventional components, and they re- quire less refrigerant. ACRP 56 ranks three measures from the refrigerant category in its top 20 GHG reduction measures. These measures aim to replace higher global warming poten- tial refrigerants with lower global warming potential refrigerants, to monitor refrigerants to prevent leaks into the ambient air, and to reduce the need for refrig- erants generally. As discussed in Section III.A.5., the CAA regulates many refrigerants, fire control sub- stances, and other chemicals that can deplete strato- spheric ozone. Specifically, it places certain restrictions on the use of refrigerants in stationary sources and mo- tor vehicles.696 Because airports already face a number of manda- tory duties associated with refrigerants, sponsors that take steps beyond these duties may be able to generate GHG reduction credits for the airport. Additionally, airports seeking to reduce GHGs through altering the use or monitoring of refrigerants should also consider whether the costs of implementing such changes will 694 U.S. Environmental Protection Agency, What You Should Know about Refrigerants When Purchasing or Repair- ing a Residential A/C System or Heat Pump (2010), http://www.epa.gov/ozone/title6/phaseout/22phaseout.html (last visited June 16, 2012). 695 INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE, FOURTH ASSESSMENT REPORT: CLIMATE CHANGE 2007, 6.4.15 (2007), available at http://www.ipcc.ch/publications_and_data/ ar4/wg3/en/ch6s6-4-15.html. 69642 U.S.C. § 7671g. implicate any FAA grant assurances. In particular, Grant Assurance 24, discussed in Section III.C.4, re- quires that airport owners or operators maintain a schedule of charges that will make the airport as self- sustaining as possible, given the circumstances. Air- ports probably cannot spend disproportionate resources for a small gain for the airport, especially if airlines or other users challenge such spending. V. CONCLUSION This digest identifies a range of GHG-mitigation measures being implemented and considered by air- ports and provides an introduction to the legal issues surrounding them. Three general observations may be drawn from the digest. First, the existing regulatory environment is com- plex and is complicated by several layers of preemption under multiple federal statutes and the many require- ments of federal sponsor grant assurances and other regulations. Aviation rules were generally produced without contemplation of GHG-related issues, and there is currently little in the way of federal and state guid- ance to advise airports specifically considering GHG reductions. Second, the overlay of state and local authority can create further legal considerations for airports seeking to reduce their GHG emissions, particularly where an action implicates areas of traditional state or local con- trol such as utility regulation, zoning, or building and safety codes. A comprehensive examination of each of these measures in all of the states and localities is be- yond the scope of this digest, but Sections III.G through III.K highlight some of the important areas for airports to investigate during project development. Third, state and federal laws and regulations relat- ing to the direct control of GHG emissions are continu- ally evolving, and there is considerable uncertainty about the scope of potential controls and whether and how they will apply to airports or the aviation sector. Airports will need to ensure that they continue to follow these developments, as well as those of state and local jurisdictions.
