Guidebook of Practices for Improving Environmental Performance at Small Airports (2010)

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14 CHAPTER 3 Air Quality Airports are comprised of a complex and diverse array of air pollutant emissions sources associated both with normal operations and maintenance, as well as development projects constucted in support of short- and long-term improvements. These emissions sources are broadly categorized as mobile emissions sources and stationary emissions sources. Mobile emissions sources emit air pollutants as a product of fuel combustion associated with transportation, and include aircraft, ground support equipment (GSE), auxiliary power units (APU), motor vehicles, and construction equipment. Stationary emissions sources emit air pollutants as a product of either fuel combustion from fixed sources, or through evaporation of fuels and chemicals during refueling, storage, and maintenance practices. Examples of stationary sources at an airport include fuel tanks, refueling facilities, emergency generators, boilers, space heaters, paint booths, and deicing facilities. Some air pollutants occuring from these mobile and stationary sources are heavily regulated on a federal level, while others are not. This chapter identifies compliance and other air quality concerns that are common to small airports, describes existing federal regualtions for these air pollutants and their sources, and suggests how the management of these emissions can be enhanced. The federal requirements applicable to air quality include the following: • Airport and Airway Improvement Act of 1982 • Clean Air Act of 1970, as amended (CAA) The topics presented in Chapter 3 include the following: • Jurisdictional Authority • General Regulations • Air Pollutant Regulations • General Conformity Regulations • Mobile Source Regulations • Stationary Source Regulations • Regulations on Ozone Depleting Substances • Airports and Greenhouse Gases • Airports and Ultrafine Particulate Matter In addition, other specific proactive measures an airport can undertake to both facilitate and surpass compliance with federal air quality regulations are detailed in Appendices A-1 through A-5 of this Guidebook.

Air Quality 15 3.1 Jurisdictional Authority Airports typically represent a wide and diverse array of air emissions sources. As such, many federal, state, and local level agencies participate in the regulation and enforcement of aviation-related air quality issues. Often, airport operators cannot explicitly regulate air quality environmental issues at their airport, especially if it is a public use airport. For example, EPA and FAA jointly develop emissions standards for aircraft engines, and FAA is charged with enforcing the standards. However, airport operators may not prohibit engines in violation of federal standards from operating at their facility. Instead they must report violations to FAA. To assist airport operators in determining which agencies are responsible for regulation and enforcement of air quality matters at their airport, Table 2 provides a generalized overview of the agencies involved in air quality management and environmental issues, and denotes their specific roles and responsibilities. Table 2. Federal, state and local agencies involved in air quality management. Level Agency Roles and Responsibilities Approves state air quality plans Develops regulations and policies pertaining to air pollution Designates areas with respect to attainment of outdoor air quality standards Enforces violations of federal air quality regulations Sets air emissions standards for engines, fuels and other emissions sources (in consultation with FAA with respect to aircraft) Environmental Protection Agency Sets outdoor air quality standards for air pollutants Certifies aircraft engines, fuels, pilots, and airports Conducts research on aviation related environmental issues Enforces violations of aircraft environmental practices and standards Serves as lead federal agency on many environmental assessments of airport-related developments, improvements, and other actions Federal Federal Aviation Administration Sets emissions standards for aircraft engines and fuels (jointly with EPA) Coordinates with other state and local agencies to develop emissions budgets for sources in their jurisdiction Develops air quality management and implementation plans Enforces violations of state and federal air quality laws Installs and maintains outdoor air monitoring networks Air Quality Agency Issues permits on select sources of air emissions, if required by state or federal law Assists in enforcing aviation-related regulatory issues at the state and local levels State Department of Transportation Develops motor vehicle emissions budgets used in regional air quality planning, including those vehicles that may travel on airport roadways Local Metropolitan Planning Organizations / Regional Planning Organizations Assists state agencies in regional air quality planning, especially with respect to transportation Associated Activities • None

16 Guidebook of Practices for Improving Environmental Performance at Small Airports 3.2 General Regulations Airport and Airway Improvement Act of 1982 The Airport and Airway Improvement Act of 1982 applies to many airport regulatory requirements, including those related to air quality. Generally, the Airport and Airway Improvement Act of 1982 regulates the award of grant funding to airport development projects involving the airport location, runways or runway extension(s), to ensure that the development projects conform to all necessary environmental regulations. Section 47106(c)(1)(B) specifically notes that projects with air quality impacts can only receive funding and approval if: 1. There exists no reasonable alternative to the project that would circumvent the environmental impact; and 2. Reasonable mitigation measures have been applied to account for the adverse effects. Small Airport Applicability Compliance Attainment Strategies • Quantify air emissions associated with airport improvements to determine where emissions mitigation is most beneficial to reducing the overall air quality impact. State agencies and private contractors are available to help with this process. Key Terms • Mitigation—Any action taken in pre-emption or response to an adverse environmental impact (including those associated with air quality), meant to decrease or negate the severity of that impact. Additional Resources • 49 U.S.C. Section 47106(c)(1)(B), as amended Associated Activities • Aircraft deicing/anti-icing • Aircraft operation • Aircraft lavatory service • Auxiliary power unit operation • Building operation/ maintenance • Bulk fuel and oil storage/handling • Cargo handling • Chemical storage/handling • Degreasing • Demolition/ construction/ development • Fire fighting training/testing/ flushing • Ground service equipment operation • Grounds maintenance landscaping • Incinerator operation • Motor vehicle operation • On-airport power generation • Painting • Pavement deicing • Refueling • Runway rubber removal • Spill response • Vehicle/ equipment/aircraft maintenance • Washing • Waste generation/ disposal Small airports are often eligible for federal funding to assist with infrastructure improvements such as runway and taxiway extension and resurfacing, installation of runway safety areas, and terminal or hangar expansions. The Airport and Airway Improvement Act of 1982 requires that the project sponsors of federally funded improvements, including the airport, should apply all reasonable measures to mitigate the air quality impacts from implementing these improvements. The construction air emissions source practices outlined in Appendix A-3 may be considered mitigation measures that satisfy this requirement should the need arise.

Air Quality 17 3.3 Air Pollutant Regulations Clean Air Act of 1970, as Amended Title I of the CAA establishes EPA authority to safeguard human health and environmental welfare with respect to air pollution. Under §108(a) and §109 of the CAA the EPA Administrator must make an endangerment finding on air pollutants documented to cause or contribute to air pollution or endanger the public health. The EPA Administrator must also promulgate National Ambient Air Quality Standards (NAAQS) for these pollutants. EPA has issued NAAQS for the following “criteria” pollutants: carbon monoxide, nitrogen dioxide, sulfur dioxide, ozone, particulate matter with mean diameters of 10 micrometers or less (PM10), particulate matter with mean diameters of 2.5 micrometers or less (PM2.5) and lead, representing the maximum allowable levels of these pollutants in outdoor air. States must install and maintain outdoor air monitoring networks by which to gauge compliance with the NAAQS. Areas with monitored concentrations below the NAAQS are given an “attainment” status. Areas with concentrations higher than the NAAQS are considered “non-attainment” of that NAAQS. “Maintenance areas” correspond to geographic areas that were previously non- attainment, but have since remediated the problem. Some pollutants (e.g., ozone) require severity-based non-attainment designations. States with non-attainment areas must submit State Implementation Plans (SIPs) that outline emissions reduction strategies to be employed to attain the NAAQS by EPA’s prescribed deadlines. Additionally, the Prevention of Significant Deterioration (PSD) program regulates new sources of air pollution in non-attainment areas to prevent worsening of current infractions, creating new infractions, or otherwise delaying NAAQS attainment. Section 112(b) helps EPA regulate Hazardous Air Pollutants (HAPs), a class of air pollutants for which human toxicity data exists, but EPA has not currently established NAAQS. Section 112 also allows EPA to set National Emissions Standards for Hazardous Air Pollutants (NESHAPs) for the pollutants listed in 112(b), including asbestos, which inform emissions source operators of the level of required emissions controls needed to maintain the NESHAP. Importantly, §176(c)(4) of the CAA establishes the General Conformity Rule for non-attainment areas, which is discussed in a later section of this chapter. Small Airport Applicability General aviation airports are the most numerous of all airport types in the United States, and many of these airports exist in EPA’s NAAQS non-attainment areas. Small airports in non-attainment areas must comply with their local SIP by showing that air emissions associated with the airports’ operations and development do not hinder the areas’ ability to meet air quality goals in a timely manner. Associated Activities • Aircraft deicing/anti-icing • Aircraft operation • Aircraft lavatory service • Auxiliary power unit operation • Building operation/ maintenance • Bulk fuel and oil storage/handling • Cargo handling • Chemical storage/handling • Degreasing • Demolition/ construction/ development • Fire fighting training/testing/ flushing • Ground service equipment operation • Grounds maintenance landscaping • Incinerator operation • Motor vehicle operation • On-airport power generation • Painting • Pavement deicing • Refueling • Runway rubber removal • Vehicle/ equipment/aircraft maintenance • Washing • Waste generation/ disposal

18 Guidebook of Practices for Improving Environmental Performance at Small Airports Compliance Attainment Strategies • Quantify air emissions associated with airport operations and development to help state air quality agencies accurately represent airport activity in their air quality plans. State agencies and private contractors are available to help with this process. • Communicate with state agencies to determine whether local air monitors are placed near the airport, and understand the monitoring data with respect to the state’s air quality goals and EPA’s NAAQS. • Ask state air quality agencies to assist in ensuring that newly installed air emissions sources comply with NESHAP and PSD requirements. Key Terms • Attainment/Non-attainment—An area that has monitored air pollutant concentrations below the established NAAQS is considered “attainment.” An area with concentrations above the NAAQS is considered “non-attainment.” • Endangerment Finding—An EPA ruling after review of available evidence declaring that an air pollutant causes or contributes to the deterioration of human health or environmental welfare. This finding is requisite for EPA to establish NAAQS, or otherwise regulate the air pollutant under the CAA. • Hazardous Air Pollutants (HAPs)—Any compound listed in §112(b) of the CAA having no established NAAQS but for which toxicity data exists. • National Ambient Air Quality Standards (NAAQS)—Maximum acceptable levels of regulated air pollutants, including an acceptable margin of error, meant to safeguard human health (primary NAAQS) and environmental welfare (secondary NAAQS). • National Emissions Standards for Hazardous Air Pollutants (NESHAPs)—A series of emissions standards set by EPA pursuant to their authority under §112 of the CAA, describing the maximum levels of HAPs listed in §112(b). Operators of HAP emissions sources must apply control technologies to ensure that emission levels do not exceed the NESHAP. • Prevention of Significant Deterioration (PSD)—A program meant to regulate new sources of air pollution in non-attainment areas in a manner such that the sources do not contribute to new infractions, exacerbate existing infractions, or otherwise delay attainment of the NAAQS. • State Implementation Plan (SIP)—A state-level compilation of air emissions levels, control strategies and timelines in non-attainment areas developed to demonstrate attainment of the NAAQS by EPA’s mandated deadline. Additional Resources • Additional information on air pollutants http://www.epa.gov/air/airpollutants.html • List of Title I Statutes http://www.epa.gov/air/caa/title1.html • 42 U.S.C. Section 7401-7515 • CAA List of Hazardous Air Pollutants http://www.epa.gov/ttn/atw/orig189.html Related Information See Section 7.5 for more information about asbestos regulations.

3.4 General Conformity Regulations Clean Air Act of 1970, as Amended The General Conformity Rule established under Title I §176(c)(4) of the CAA, dictates that all reasonably foreseeable direct and indirect air emissions caused or contributed by Federal Actions in NAAQS non-attainment and maintenance areas, of which the responsible Federal Agency (the “Lead Agency”) can feasibly control, conform to the applicable SIP. Actions that worsen existing violations are also included. The Lead Agency can exercise discretion, defining actions or components of actions that are “presumed to conform” after determining that such actions have negligible effects on air quality. Determination of conformity with an applicable SIP first involves an Applicability Test (see Figure 2). Emissions are quantified and compared against “de minimis” thresholds, over which a project or action must demonstrate conformity with the SIP. De minimis thresholds can be directly set for the criteria pollutants or indirectly set for pollutant precursors (i.e., Ozone de minimis thresholds are evaluated using levels of its precursors, oxides of nitrogen (NOx) and volatile organic compounds (VOCs), and the values depend on the severity of non-attainment). The rule mandates that project emissions failing the Applicability Test must be fully offset using emissions reduction measures or by revising the SIP emissions budget to which the emissions must adhere. If the emissions cannot be fully offset, the project may not be eligible for federal funding. Having an airport’s emissions included in the SIP is the surest way to meet conformity requirements. Associated Activities • Aircraft deicing/anti-icing • Aircraft operation • Aircraft lavatory service • Auxiliary power unit operation • Building operation/ maintenance • Bulk fuel and oil storage/handling • Cargo handling • Chemical storage/handling • Degreasing • Demolition/ construction/ development • Fire fighting training/testing/ flushing • Ground service equipment operation • Grounds maintenance landscaping • Incinerator operation • Motor vehicle operation • On-airport power generation • Painting • Pavement deicing • Refueling • Waste generation/ disposal Figure 2. The general conformity determination process. Air Quality 19

20 Guidebook of Practices for Improving Environmental Performance at Small Airports Small Airport Applicability As stated above, many small airports are currently located in EPA’s non- attainment areas, meaning that the General Conformity process would apply to all federally sponsored actions occurring at the airport. This highlights the importance of airports operating in non-attainment areas establishing a rapport with the state air quality agency to ensure that they are in compliance with all applicable air quality regulations that would have an impact on the local SIP. In April 2010, EPA revised the General Conformity regulations, allowing facilities such as airports to negotiate a “facility-wide” emissions budget with the state air quality agency, if desired. This budget could potentially allow for emissions associated with airport growth and development to be more easily accounted in a state’s air quality planning. Airports should ensure activities subject to the General Conformity process are representative of actual airport activity. Specifically, if a state air quality agency does not have airport-specific activity to use to estimate airport emissions (or emissions estimates provided directly from the airport), they will often rely on a gross estimate using national data to approximate an airport’s emissions in the planning process. This method may result in misrepresentation of the airport and potentially create complications in demonstrating that airport development conforms to the SIP. Compliance Attainment Strategies • Quantify air emissions associated with airport operations and development to help state air quality agencies accurately represent airport activity in their air quality plans. State agencies and private contractors are available to help with this process. • Make sure that all emissions sources requiring air permits have up-to-date permits, and that emissions controls on these sources are operating properly. All permitted sources are readily accounted in the state SIP. • Be cognizant of potential emissions mitigation measures that would apply to projects subject to the Conformity process. Many measures described in Appendices B-1 through B-5 provide this information. • Become familiarized with potential emissions reduction credit programs available through the state air quality agency. These credits can help demonstrate conformity if the need arises. Key Terms • Applicability Test—The process by which air emissions related to a Federal action are inventoried and compared against de minimis thresholds and subject to a regional significance test. • Applicable State Implementation Plan (SIP)—Refers to the portion(s) of the most recent SIP that have been approved by EPA under §110 and 301(d) of the CAA. • Cause or Contribute—Implies that a Federal action would cause a new violation of the NAAQS in a non-attainment area or contribute, in conjunction with other reasonably foreseeable actions, to a new violation. • Criteria Pollutant—A term describing air pollutants for which NAAQS have been established. Did You Know The General Conformity Rule of the CAA only applies to airports located within EPA’s air quality non-attainment areas. The EPA’s Green Book of Non- attainment Areas is a useful resource for airports to determine if they are subject to the General Conformity Rule. EPA’s Green Book can be accessed at: http://www.epa.gov/oar/ oaqps/greenbk/index. html

• De minimis Thresholds—Maximum allowable levels of pollutants and precursors for a Federal action, governed by the severity of non-attainment in the area within which the action occurs. • Direct/Indirect Emissions—Direct emissions are pollutant emissions that are caused or initiated directly by Federal action, taking place at the same time and location of that action. Indirect emissions refer to those emissions that are caused by the Federal action and yet occur at a distant time or place from the action, are reasonably foreseeable, and under the practical control of the Lead Agency. • Federal Action—Any action taken on part of an agency or entity of the federal government, as well as any action funded, permitted, approved or otherwise developed by the entity. • Lead Agency—The federal agency responsible for the planning, implementation and conformity determination of a federal action. • Presumed to Conform—Components of a federal action that are considered to have a negligible effect on air quality, and thus are exempted from conformity determination. • Reasonably Foreseeable—Projected future indirect air emissions that are identified at the time of conformity determination, have a known source and location, and are quantifiable. • Regionally Significant—The distinction of a federal action whereby the direct and indirect air emissions associated with it exceed 10% of the regional emissions budget. • Total of Direct and Indirect Emissions—All reasonably foreseeable and practicably controllable air emissions associated with a Federal action, some of which may be presumed to conform to the SIP. However, although such emissions would not be considered during determination, they must be accounted for in the Applicability Test. Additional Resources • General Conformity Resource http://www.epa.gov/oar/genconform/ • 42 U.S.C. Section 7506(c) • EPA’s Green Book of Non-attainment Areas http://www.epa.gov/oar/oaqps/greenbk/index.html 3.5 Mobile Source Regulations Clean Air Act of 1970, as Amended Title II of the CAA requires EPA to periodically create, update and enforce emissions and fuel standards for mobile sources of air pollution such as motor vehicles and aircraft, to which engine manufacturers and fuel refineries must adhere. This includes requirements on fuel efficiency, chemical composition of fuel (i.e., low sulfur diesel), and engine emissions factors describing how many pollutants are emitted per unit of fuel consumed. For vehicles currently in use, new or updated standards may be phased-in based on the type and size of the vehicles, their useful life, and the overall composition of the in-use vehicle fleet. Regulations under Title II not only apply to on-road motor vehicles, but to off- Helpful Hint If airport improvements don’t conform to a SIP, the related air pollution must be fully offset or mitigated, which is often costly. Many options are available to help stop this problem before it starts. For more information, refer to Mobile Air-9 Practice in Appendix A-1, Construction Air-4 Practice in Appendix A-3, and Stationary Air-2 Practice in Appendix A-2. Associated Activities • Aircraft operation • Aircraft lavatory service • Auxiliary power unit operation • Cargo handling • Demolition/ construction/ development • Ground service equipment operation • Grounds maintenance landscaping • Motor vehicle operation • Refueling • Vehicle/ equipment/aircraft maintenance • Washing Air Quality 21

22 Guidebook of Practices for Improving Environmental Performance at Small Airports road vehicles (i.e., construction and agricultural equipment), as well. Section 233 of the CAA prohibits state agencies from creating and implementing aircraft standards other than what are listed in Title II of the CAA. Small Airport Applicability EPA plans to exercise its Title II authority upon concluding a study on the health and air quality effects of leaded aviation gasoline. The end result of this activity will involve imposing piston engine lead emissions standards and limitations on the content of lead in aviation gasoline, through consultation with FAA. Although alternative technologies and fuels to eliminate lead emissions from piston engines are currently under development, they are yet to be certified for safe use in aircraft. Although the responsibility of Title II compliance rests with fuel refineries and engine manufacturers, small airports service a significant amount of general aviation operations, most of which are conducted using piston engine aircraft. Accordingly, small airports should monitor EPA actions on leaded aviation gasoline and piston aircraft closely. Compliance Attainment Strategies • The responsibility of Title II compliance is delegated to fuel refineries and engine manufacturers. Notably, FAA prohibits public use airports from regulating the types of engines allowed to operate at the facility. However, airport operators can still be proactive by reporting violations of engines or fuel standards occurring at their airports to FAA. Key Terms • Emission Factors—A term describing the rate at which an air pollutant(s) is emitted from a mobile source per unit of fuel consumed. For example, aircraft engine emissions factors are often reported in grams of pollutant per kilogram of fuel (e.g., 1.5 grams NOx/1,000 grams Jet A). Additional Resources • EPA’s Title II Requirements http://www.epa.gov/air/caa/title2.html • Descriptions of some EPA Title II initiatives http://www.epa.gov/air/peg/carstrucks.html • 42 U.S.C. Section 7521-7590 3.6 Stationary Source Regulations Clean Air Act of 1970, as Amended Title V of the CAA requires operators of stationary sources and facilities that emit air pollutants to comprehensively detail all emissions discharged from the sources and facilities. This detail, referred to as the operating permit, includes a listing of all pollutants emitted, the quantity and rate at which they are emitted, Did You Know CAA Title II regulations largely apply to fuel refineries and engine manufacturers. Nonetheless, this may affect sources in operation at airports. For instance, EPA (in consultation with FAA) plans to soon create stronger lead emissions standards for piston aircraft engines and aviation gasoline.

control technologies employed to mitigate these emissions, and compliance and violation monitoring. Periodically, the source operator must disclose and provide updates to this information to the EPA administration, neighboring states, and the public. Permits are approved and issued by EPA for durations not to exceed five years in most cases. Sources affected under Title V generally include those emitting more than 100 tons per year of any regulated (i.e., “criteria”) pollutant, although the allowable quantity can be reduced for sources operating in non- attainment areas. Moreover, the requirements of the Title V permitting program can also be adjusted at the state level. Maximum allowable HAP emissions must also be accounted for in the operating permit. Small Airport Applicability Small airports may not operate as many Title V regulated sources as larger commercial airports do, but Title V regulations still apply to small airport sources such as boilers, space heaters, paint booths, fuel storage and transfer facilities, and waste incinerators. Compliance Attainment Strategies • Ensure permits are up-to-date, and new sources are permitted prior to operation. • Aggressively inspect and maintain source emissions control technologies required to demonstrate compliance with Title V emissions limitations. • Proactively research and implement strategies to further reduce stationary source emissions, such as using different fuels or volunteering to implement the best available control technologies as they are produced. Additional Resources • Title V Permit Program http://www.epa.gov/air/caa/title5.html http://www.epa.gov/air/oaqps/permits/ • 42 U.S.C. Section 7661 • CAA List of Hazardous Air Pollutants http://www.epa.gov/ttn/atw/orig189.html 3.7 Regulations on Ozone Depleting Substances Clean Air Act of 1970, as Amended Title VI of the CAA allows EPA to regulate air pollutants that can have a damaging effect on the ozone layer, including many compounds commonly used as refrigerants or propellants. EPA identified a listing of these substances and categorized them into two categories based on their potential to deplete the ozone layer and contribute to global warming. Class I substances [identified in §7671(a)] correspond to those substances with the highest damage potential, that EPA planned to phase out of production by the year 2000, and included chlorofluorocarbons (CFCs). Class II substances [identified in §7671(b)] refer Associated Activities • Aircraft deicing/anti-icing • Building operation/ maintenance • Bulk fuel and oil storage/handling • Chemical storage/handling • Degreasing • Fire fighting training/testing/ flushing • Incinerator operation • On-airport power generation • Painting • Pavement deicing • Vehicle/ equipment/aircraft maintenance • Washing • Waste generation/ disposal Helpful Hint Regularly monitor and maintain stationary sources and control technologies to ensure compliance with Title V regulations. Opt to use more environmentally friendly alternatives wherever feasible. For more information, refer to Mobile Air-9 Practice in Appendix A-1, Indoor Air-1 Practice in Appendix A-5, and Stationary Air-2, and Stationary Air-5 Practices in Appendix A-2. Air Quality 23

24 Guidebook of Practices for Improving Environmental Performance at Small Airports to those with slightly lesser damage potential (e.g., hydrochlorofluorocarbons (HCFCs)), and accordingly the phase-out process is required to be initiated by 2015. It is expected that HCFCs will continue to be available until 2030, and recycled HCFCs may still be available thereafter. Title VI also allows EPA to set up monitoring and reporting requirements for sources emitting, producing, exporting, or otherwise transferring these compounds. Requisite to this reporting requirement is the establishment of a “baseline” production/emission level relative to the year 1989, and the periodic update of how this rate has been diminished relative to the baseline level. According to §7671(g)(b), machines and other equipment that consume, process, contain, or move Class I and II substances must be equipped with control and capture devices to limit the release of these substances to the surrounding environment and, similarly regulate the manner with which these equipment are maintained or disposed. Sections 7671(g) and (h) require refrigeration or cooling systems containing more than 50 pounds of refrigerant must not leak more than 35% of their total charge within a 12-month period. Owners of these systems are required to report leaks exceeding this threshold to EPA, as well as to arrange for replacement or retrofitting, within 30 days. For motor vehicles, air conditioning repairs and modifications must additionally conform to SAE standards. Moreover, technicians are required to apply between 10 and 25 inches of Mercury vacuum when evacuating refrigeration and cooling systems for recycling and disposal, depending on the type of system and the ozone depleting substances contained. Lastly, EPA requires technicians that maintain or service these systems to become certified. Type I technicians are allowed to become certified by submitting a mail-in, open book test to EPA. Type II, III and Universal technicians must pass a closed-book certification exam proctored by an EPA-certified organization to attain certification. Small Airport Applicability Class I and II substances are typically used at small airports in terminal area heating ventilation and air conditioning (HVAC) machinery and motor vehicle/equipment air conditioning systems, and as such are subject to handling and reporting requirements of Title VI. Compliance Attainment Strategies • Ensure that maintenance technicians have the appropriate EPA certification. • Develop a chemical inventory of refrigerants. • Regularly inspect and maintain equipment and machinery that uses Title VI regulated substances. Key Terms • Baseline—Used to describe the amount of Class I or II ozone depleting substances in use by an applicable facility in the year 1989, against which monitoring and reporting in subsequent years would be compared. Did You Know Although ozone is a harmful air pollutant at ground level, it performs a necessary environmental function at higher altitudes. Keeping an updated chemical inventory of refrigerants, and conducting routine inspections of equipment that use them, will help maintain compliance with Title VI regulations. Associated Activities • Building operation/mainten ance • Chemical storage/handling • Vehicle/equipment /aircraft maintenance Helpful Hint

• Chlorofluorocarbons (CFCs)—Chlorofluorocarbon, an example of a Class I ozone depleting substance that had commonly been used as a refrigerant or propellant in commercial and industrial applications. • Class I Substance—Any substance listed in §7671(a) of the CAA that has a very high potential to damage the ozone layer and contribute to global warming. These substances were to be phased out of production by the year 2000. • Class II Substance—Any substance listed in §7671(b) of the CAA that has a significant potential to damage the ozone layer and contribute to global warming. These substances are to be phased out of production by 2015. • Hydrochlorofluorocarbon (HCFC)—An example of a Class II ozone depleting substance that is commonly used as a refrigerant or propellant in commercial and industrial applications. • Type I Technician—A technician that services or disposes of small appliances containing ozone depleting substances, subject to the minimum certification requirements by EPA. • Type II Technician—A technician that services or disposes of high and very high pressure appliances containing ozone depleting substances, subject to the most stringent certification requirements by EPA. • Type III Technician—A technician that services or disposes of low pressure appliances containing ozone depleting substances, subject to the most stringent certification requirements by EPA. • Universal Technician—A technician that services all types of appliances or equipment that contain ozone depleting substances and are subject to regulation under Title IV, for which the most stringent EPA certification is required. Additional Resources • EPA Resource on Ozone Depleting Substances http://www.epa.gov/ozone/strathome.html • 42 U.S.C. Section 7671 3.8 Airports and Greenhouse Gases Importantly, there are currently no existing federal regulations that attempt to control or reduce the levels of greenhouse gases (GHG). However, on December 7, 2009, EPA declared an endangerment finding under Title I of the CAA, signifying that GHGs cause or contribute to negative impacts on human health or environmental welfare. This action allows EPA to begin regulating GHG using its authority under CAA. Although EPA has not yet stated how they intend to exercise this authority, available options may include establishing a market-based emissions cap-and-trade system, or establishing emissions or fuel standards for GHG sources. A GHG reporting rule has also recently been established, requiring certain facilities routinely emitting a significant amount of GHG to periodically assess and report their GHG emissions to EPA. Specifically, fossil fuel suppliers, vehicle engine manufacturers, and facilities exceeding 25,000 metric tons of Helpful Hint Consider limiting the amounts of ozone depleting substances used, opting instead for more environmentally friendly alternatives. For more information, refer to Air Evaluation-2 Practice in Appendix A-4, Mobile Air-9 Practice in Appendix A-1, Construction Air-5 Practice in Appendix A-3, and Indoor Air-5 Practice in Appendix A-5. Air Quality 25

26 Guidebook of Practices for Improving Environmental Performance at Small Airports carbon dioxide equivalent (CO2e) per year must report their emissions and activities. Recent reports have concluded that the aviation industry contributes roughly 3% to the global levels of man-made GHG in the atmosphere, and suggest that increased aviation demand will cause this percentage to increase in the future. As such, small airports should show initiative in assessing their contribution to aviation-related GHG. Many resources exist or are in development that will provide important guidance on how to quantify, report, and assign ownership to GHG. Importantly, the ACRP has developed a guidebook that walks a user through the recommended methodology to address these issues. Because GHG emissions often transcend geographic and political boundaries, they are often quantified on many spatial scales (i.e., locally, regionally, or globally). Accordingly, airport operators should be cautious in choosing which scale is best applicable to their facility when assessing GHG emissions associated with their airport. For example, a large hub commercial service airport with a considerable amount of long distance domestic and international air service may find it necessary to quantify aircraft GHG emissions at cruise altitudes between the origination and destination airports to get a sense of how many emissions are occurring on a regional or national scale. Conversely, small airports that do not typically handle many commercial air carrier service operations may be more concerned with quantifying emissions on a local or regional level, which would likely only involve aircraft emissions resulting from taxi, take-off, climb-out, and landing modes of operation. Small airport operators may obtain guidance on defining the spatial scale of their airport’s emissions assessments through coordination with state agencies, environmental professionals, and ACRP guidance documents. Small Airport Applicability Small airports will not likely exceed any existing GHG reporting thresholds, but should carefully watch for future regulations issued by EPA to assess whether those regulations could potentially apply. Compliance Attainment Strategies • Conduct a GHG emissions inventory to gauge whether reporting requirements or emissions limits apply. Private contractors are available to assist in this process. • Develop a proactive GHG reduction plan. Notably, many practices targeted at reducing fuel consumption and engine usage described in Appendices A-1 through A-5 can help structure this plan. Key Terms • Cap-and-Trade—A system by which air emissions levels are limited to a specific threshold. Emissions credits are awarded to facilities with emissions below the threshold. These facilities are allowed to sell these credits to others that are violating the threshold, so that overages and shortages cancel each other out and the limit is maintained. Associated Activities • Aircraft deicing/anti-icing • Aircraft operation • Aircraft lavatory service • Auxiliary power unit operation • Building operation/ maintenance • Cargo handling • Chemical storage/handling • Demolition/ construction/ development • Fire fighting training/testing/ flushing • Ground service equipment operation • Grounds maintenance/ landscaping • Incinerator operation • Motor vehicle operation • On-airport power generation • Painting • Pavement deicing • Refueling • Waste generation /disposal

• Carbon Dioxide Equivalent (CO2e)—An expression used in GHG assessment and reporting. To determine CO2e, individual GHG emissions are quantified and adjusted to the global warming potential of carbon dioxide. • Greenhouse Gasses (GHG)—Any gas emitted into the atmosphere that has the potential to trap heat. The most common GHG occurring at airports are carbon dioxide, methane and nitrous oxide. Additional Resources • Endangerment Finding Synopsis http://www.epa.gov/climatechange/endangerment.html • EPA’s GHG Reporting Rule http://www.epa.gov/climatechange/emissions/ghgrulemaking.html • EPA’s 2009 GHG Inventory Report http://www.epa.gov/climatechange/emissions/usinventoryreport.html • ACRP Report 11: Guidebook on Preparing Airport Greenhouse Gas Emissions Inventories http://onlinepubs.trb.org/onlinepubs/acrp/acrp_rpt_011.pdf 3.9 Airports and Ultrafine Particulate Matter As is the case with GHG emissions, there are currently no federal or state regulations on emissions of ultrafine particulate matter (UFP, or PM0.1). For the purposes of this discussion, UFP is defined as particles contained in exhaust emissions that measure 0.1 micrometers or less in diameter. UFP can be omitted from vehicle engines at higher power settings when fuel combustion temperatures are very high. Because these particles are so small, they can penetrate deep into the respiratory system and cause considerable damage to living things. In fact, UFP has been implicated in increasing risk of cardiovascular disease, pulmonary ailments, and cancer development. An increasing amount of scientific research has identified aircraft (especially jet turbine aircraft) as a significant source of UFP. Further, recent studies conducted by EPA and the California Air Resources Board (CARB) have indicated that UFP concentrations are commonly elevated in the immediate vicinity of Southern and Central California airports, including Los Angeles International (LAX) and Santa Monica (SMO). Because the state of the science regarding UFP is new and continually emerging, guidance on assessing UFP around airports is still in development. Nonetheless, small airport operators should monitor this environmental issue closely to ascertain any effects it may have on their airport. Small Airport Applicability To maintain public relations and be advised of potential regulatory developments, small airports should keep informed on this topic, especially if there is a significant amount of jet activity occurring at their facility. Associated Activities • Aircraft operation • Auxiliary power unit operation • Cargo handling • Demolition/ construction/ development • Fire fighting training/testing/ flushing • Ground service equipment operation • Grounds maintenance/ landscaping • Incinerator operation • Motor vehicle operation • On-airport power generation • Waste generation/ disposal Air Quality 27

28 Guidebook of Practices for Improving Environmental Performance at Small Airports Compliance Attainment Strategies • Communicate with federal, state, and local regulatory agencies and academic institutions to determine whether any UFP studies are planned or in place around the airport and become involved in any such studies. Taking a proactive role in assessing potential impacts can help the airport be prepared in the event of any negative public response or potential regulatory action. Key Terms • Ultrafine Particulate Matter (UFP or PM0.1)—Particles contained in exhaust emissions that measure 0.1 micrometers or less in diameter. Additional Resources • CARB Fine and Ultrafine Particulate Matter Research http://www.arb.ca.gov/research/pmr/pmr.htm • EPA Fine and Ultrafine Particulate Matter Research http://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/outlinks.centers/ center Group/1