Special Report on Airport Related Air Pollution
Controlling Airport-Related Air Pollution
Prepared by Northeast States for Coordinated Air Use Management and Center for Clean Air Policy
June 2003
NESCAUM, which is an association of the air quality control agencies in the eight northeast states:
* Members of Northeast States for Coordinated Air Use Management Anne Gobin, Acting Bureau Chief
* Connecticut Department of Environmental Protection, Bureau of Air Management James P. Brooks, Bureau Director
* Maine Department of Environmental Protection, Bureau of Air Quality Barbara Kwetz, Deputy Director of Air Programs
* Massachusetts Department of Environmental Protection, Bureau of Waste Prevention Robert Scott, Acting Director
* New Hampshire Department of Environmental Services, Air Resources Division William O’Sullivan, Administrator
* New Jersey Department of Environmental Protection, Office of Air Quality Management David Shaw, Acting Director
* New York Department of Environmental Conservation, Division of Air Resources Stephen Majkut, Chief
* Rhode Island Department of Environmental Management, Office of Air Resources Richard A. Valentinetti, Director
* Vermont Department of Environmental Conservation, Air Pollution Control Division Kenneth A. Colburn, Executive Director
* Northeast States for Coordinated Air Use Management
FULL REPORT:
http://64.2.134.196/workgroup/aircraftport/Aviation_Final_Report.pdf
Executive Summary
This report was undertaken by the Northeast States for Coordinated Air Use Management (NESCAUM) and the Center for Clean Air Policy (CCAP) as part of an effort to assist policymakers at the national, state, and local levels in better understanding the contribution of the aviation sector to air pollution problems and in developing control options for reducing airport-related emissions.
Airport-related activities result in the emission of a host of air pollutants that adversely affect public health and the environment, including nitrogen oxides (NOx), hydrocarbons (HC), particulate (PM), carbon monoxide (CO), and toxics. NOx and HC are precursor emissions of ground-level ozone, which causes lung irritation and aggravates diseases such as asthma, chronic bronchitis, and emphysema.
Particulates have adverse cardiopulmonary effects and contribute to regional environmental problems such as haze and acid rain. Toxics such as benzene and formaldehyde are known or probable human carcinogens. Nationally, the number of aircraft operations (defined as one takeoff or one landing) has grown substantially from around 15 million in 1976 to almost 30 million in 2000, a cumulative growth of about 105 percent.
While emissions from most source sectors are declining due to the implementation of more stringent control programs, the growth in air travel 1 and the continued lack of federal control programs for aircraft engines is resulting in increased pollution from airports. States in non-attainment of criteria pollutant National Ambient Air Quality Standards (NAAQS) are required by federal law to reduce ambient levels of these pollutants. Given the existence of stringent control programs for other industry sectors, reductions in airport-related air pollution are necessary in order for states to lower emissions to meet air quality and public health goals. Absent control measures to reduce airport-related emissions, further emissions reductions from other sectors will be needed in order for states to attain air quality requirements.
The study involved:
(1) quantifying airport-related emissions for three Northeast airports;
(2) assessing control options;
(3) outlining various policy options for achieving cost-effective reductions; and
(4) outlining and assessing legal opportunities and barriers to actions by states. This report contains six chapters.
Chapter I - introduces the issue and describes the study.
Chapter II - presents the results of the emission inventory assessment for several airports in the Northeast and explains the methodology NESCAUM used. The inventory includes non-military aircraft, auxiliary power units (APU), and ground service equipment (GSE). Stationary source emissions were not estimated.
Chapter III - is an assessment of technological and operational control options for various sources of emissions at airports.
Chapter IV - highlights policy options available to reduce airport-related emissions and provides case studies of approaches currently in place or proposed in the U.S. and abroad.
Chapter V - evaluates and summarizes statutory and regulatory options and constraints with regard to controlling airport-related pollution.
Chapter VI - summarizes the findings and recommendations of the study.
A. Emissions Inventories for Three Selected Airports
· In aggregate, aircraft at Logan International Airport (Boston, MA), Bradley International Airport (Windsor Locks, CT), and Manchester Airport (Manchester, NH) emitted 3,538 tons of NOx, 4,461 tons of CO, and 700 tons of HC in 1999. Combined aircraft-related emissions of benzene totaled 20 tons at Logan, Bradley, and Manchester in 1999. For comparison, aggregate benzene emissions from the largest stationary sources in Massachusetts, Connecticut, and New Hampshire combined totaled six tons in 1996.
· At the three airports studied, 85 percent of airport NOx emissions are from aircraft. Of aircraft emissions, air carriers contribute the majority of the NOx. In 1999, air taxi operations contributed one-third of aircraft-related HC emissions and air carrier operations contributed two-thirds.
· Auxiliary power units and ground service equipment combined account for approximately 15 percent of aviation-related NOx emissions at the three airports studied.
· Significant increases in airport operations are predicted over the next decade at airports in the Northeast region. Aircraft operations are projected to grow by 8 percent at Logan, 30 percent at Bradley, and 14 percent at Manchester over the next ten
years.
· Regionalization, or the shift in traffic from larger to smaller airports, will cause rapid expansion at smaller airports over the next decade in the Northeast.
B. Control Options
· In the long term, cost effective options to reduce fuel consumption and criteria pollutants from aircraft engines are technically feasible; an example of such options is aerodynamic aircraft bodies.
· Aircraft operational changes such as single engine taxi and reduced use of reverse thrust (used at the pilot’s discretion) cost little or nothing to implement and provide fuel-use savings and emissions reductions.
· Electrification of ground support equipment provides reductions in all pollutants, and can save the airport operators and air carriers money over the long term due to the increased efficiency of electric motors compared to gasoline and diesel engines.
· Gate electrification is one of the most cost-effective options examined in this study. Gate electrification in some cases provides a cost benefit within two years of installation.
· Operation of factory-built, dedicated compressed natural gas (CNG) and liquid propane gas (LPG) ground service equipment reduce emissions of NOx, HC, CO, and PM relative to gasoline and diesel-powered equipment. Conversions from diesel or gasoline to CNG/LPG provide NOx and PM reductions but can sometimes increase HC and CO emissions.
· A federal program called the Federal Aviation Administration’s Inherently Low-Emission Airport Vehicle Pilot Program (ILEAV) provides financial incentives for airports to reduce emissions by introducing clean alternative fuel ground service and ground access vehicles into fleets. A total of ten airports have been selected to receive funding.
C. Policy Options
· A variety of regulatory and policy options exist for states, localities, and airport operators to control airport-related emissions. Innovative programs have been initiated at many airports around the world.
· While emission standards are in place for aircraft engines, most engines currently in production emit NOx at levels below the national standards. Efforts at the national and international levels to increase the stringency of engine emission standards could play a role in reducing air pollution from aviation and in driving technology development.
· “Cap-and-trade” or airport “bubble” approaches have the potential to limit airport-related emissions, provide flexibility in achieving reductions, and encourage the use and development of cleaner technologies. The operators of Logan Airport (Massport) have established a cap on airport emissions; any emissions increases that result from airport activity must be offset by on-airport emission reductions, reductions near the airport, or by purchasing emission credits.
· Fee-based strategies, such as increased or variable landing fees, are another potentially useful tool that officials at the state, local, and airport level can use to reduce emissions. Variable aircraft landing fees are have been implemented at Zurich and Geneva Airports in Switzerland, and at nineteen airports in Sweden. The fees are emissions-based and result in a greater charge being levied on higher polluting aircraft entering those airports.
· Regulatory approaches such as 1) promoting or requiring the purchase of cleaner alternatives when fleet vehicles or equipment are replaced or added; and 2) developing a declining fleet emissions target can be utilized to achieve emissions reductions from ground service equipment and ground access vehicles.
· Emission reductions can also be achieved through voluntary agreements.
Currently, states, the airline industry, the US EPA, the FAA, environmental groups and others are discussing a voluntary national program to reduce airport-related emissions.
· Voluntary agreements at the local level are also possible to reduce emissions from aircraft ground activities (taxi and gate operation), ground service equipment, ground access vehicles, and stationary sources. A voluntary agreement has been reached at airports in the Dallas-Forth Worth and Houston areas of Texas, where the airlines have agreed to reduce NOX emissions from ground service equipment. A similar program is being developed for airports in southern California.
D. Regulatory Context
· The International Civil Aviation Organization (ICAO) and its Committee on Aviation and Environmental Protection (CAEP) seek to coordinate the development of consistent international standards for aircraft engines.
· US EPA is required by Section 231 of the Clean Air Act Amendments of 1990 to regulate aircraft engine emissions and has generally adopted the standards recommended by ICAO as the applicable federal standards in the U.S.
· The Clean Air Act provides states with some authority to require emissions reductions at airports, although legal barriers constrain this authority.
· States (within narrow confines) could impose controls on ground operation of aircraft.
Regulations that do not impact safety and the movement of aircraft are most likely to avoid preemption.
· States may petition EPA to control aircraft engine emissions to more stringent standards.
The Administrative Procedure Act provides that “interested person[s]” have the right to petition an Agency to amend or repeal a rule.5 Since the EPA sets standards for aircraft engine emissions as part of its rulemaking capacity, any interested person may petition the Agency to revise the rule.
· Emissions controls for ground service equipment could be implemented through “in-use limits” on their operation, provided that fleet operators have options available that do not require modifications to the equipment.
· States that are proprietors of airports can impose requirements on fleets operating within the airport. A fleet emission requirement could be established, provided that the fleet operator had options available to meet the requirement without modifying the fleet engines.
· States acting as proprietors of airports may be able to impose landing fees on airplanes, provided that the fees are “reasonable” and used wholly for “airport or aeronautical purposes.” · States may be permitted, as a condition of modifying or expanding an airport, to set a limit on airport emissions under the “indirect source review” provisions of the Clean Air Act.
E. Conclusions
· Airport-related emissions are increasing while emissions from nearly all other major source sectors are decreasing.
· There are a host of technical and operational control options for reducing airport-related emissions.
· Establishing an airport emissions cap can serve to encourage the introduction of control technologies such as gate electrification, less polluting aircraft engines, and alternative fuel ground service equipment and ground access vehicles.
· National and international agreements to encourage the development of less polluting, more efficient aircraft engines and more aerodynamic aircraft bodies can result in aircraft that pollute substantially less, are quieter, and burn less fuel than today’s airplanes.
· States have some authority under the Clean Air Act to require emissions reductions from airport sources.
· Without technology forcing emission standards that provide incentives for reductions in criteria pollutants and more efficient engines, NOx emissions from aircraft engines will likely increase for the foreseeable future.