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Air Quality 101. Association of California Airports September 18, 2009. Overview. Typical Air Quality Regulations Common Definitions Some Aviation Hot Topics In the Air. HMMH Corporate Overview. Services Offered Noise and Vibration Control Airport and Airspace Planning Air Quality
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Air Quality 101 Association of California Airports September 18, 2009
Overview • Typical Air Quality Regulations • Common Definitions • Some Aviation Hot Topics • In the Air
HMMH Corporate Overview • Services Offered • Noise and Vibration Control • Airport and Airspace Planning • Air Quality • Renewable Energy • GHG Management • Practice areas • Aviation Services • Rail Noise and Vibration • Highway Noise • Industrial/Commercial/Entertainment • Climate and Energy
Air Quality Regulations • Federal • Clean Air Act Amendments (CAA) • National Environmental Policy Act (NEPA) • State • California Environmental Quality Act (CEQA) • Air Resource Board (ARB) • Local • Local Air Pollution Districts (35)
Federal Regulations Clean Air Act Amendments – Federal Law Regulating Air Quality • Clean Air Act 1970 • Established the National Ambient Air Quality Standards (NAAQS) • Established State Implementation Plans (SIPs) to achieve NAAQS • Others (control motor vehicle emissions, NESHAPs, NSPS) • 1977 Amendments • Authorized Prevention of Significant Deterioration (PSD) • Established non-attainment areas with respect to NAAQS • 1990 Amendments • Authorized Acid Deposition control • Control 189 toxic pollutants (hazardous air pollutants (HAPs)) • Title V Permitting
Federal Regulations • NEPA • Enacted January 1, 1970 • Consider environmental effects in the federal agency decision making • Established Environmental Assessment (EA’s) • Typically for projects with no significant impacts. Usually smaller less controversial projects. • Environmental Impact Statement (EIS) • Usually for larger more controversial projects, more beefier than EA.
State Regulations • California Environmental Quality Act • Established in 1970 to supplement NEPA • Applies to certain activities by state and local public agencies • Most development projects are subject to CEQA • Review of the project and its effects • Very similar to NEPA but must show compliance with state and local standards • Goal to avoid, minimize, and mitigate damage to environment
State/Local • Air Resources Board (ARB) • Sets and enforces emissions standards (mobile, fuels, consumer products) • Sets health based air quality standards • Monitors air quality • Conducts research • Oversees and assists local air quality districts permitting • Local Air Quality Districts • 35 Air Districts • Regulate air permits and comment on CEQA
Definitions • National Ambient Air Quality Standards (NAAQS) – developed by EPA to protect public health (Primary Standards) and welfare (Secondary) • Contains six criteria pollutants • California Ambient Air Quality Standards – Similar to NAAQS but more restrictive in some areas (e.g. SO2, 1-hour NO2, 1-hour CO etc.) • Non-attainment • Area designated by EPA as not meeting the NAAQS • Attainment • Area designated by EPA which meets the NAAQS • Maintenance • Previously designated non-attainment subsequently redesignated to attainment • De-minimus Levels • Impacts above de-minimus levels are considered significant. Levels are set based on attainment status. Keep impacts below these levels. • Emission Inventory • Typically reported in tons per year (tpy). Rate of emission for a group of sources. • Dispersion Modeling • Typically estimated in mircrograms per cubic meter (ug/m3). Ground level concentration predicted through dispersion algorithms from emission sources. • General Conformity • Only apply in non-attainment and maintenance areas. If not on FAA Presumed to Conform List, then applicability analysis is conducted (i.e. emission inventory). • If net emissions below de-minimus levels, and not regionally significant, no further action. Otherwise; • Conformity determination conducted using dispersion modeling for NAAQS compliance.
EDMS • Emission Dispersion Modeling System (EDMS) • Preferred model by FAA for use at civil and military airports • Capabilities • Emissions Inventory • Air Dispersion Modeling • Aircraft emissions, GSE, APU, idle/taxi, combustion, mobile sources • LTOs emissions (i.e. below 3,000 feet) • For dispersion uses meteorological data from airport
Lead • EPA Lowered Standard January 2009 • From 1.5 ug/m3 to 0.15 ug/m3. Three month average instead of quarterly. • Lead is still in General Aviation Gas (AvGas) • EPA currently conducting a follow up study at Santa Monica Airport. • Air and Soil emissions. Not a risk assessment. • Previous monitoring results below standard. • Purpose of study • Develop a model to regulate emissions in the future. • SMO chosen because there are no industry within a mile of the site to skew the results • Study will be available in 2010.
PM2.5 • What is it? • Mixture of extremely small particles and droplets • Regulated via NAAQS • Sources • Aircraft are primary emitters at airports, Combustion sources, mobile source, naturally occurring (i.e. forest fires, biological), others. • Health Implications • Premature deaths (heart and lung disease), children and elderly especially sensitive • EPA believes PM2.5 poses the greatest health risk • Airport studies have shown increases in (PM2.5 and benzene) concentrations at airports, but direct correlation to airport operations was inconclusive. Spikes and inconsistent patterns.
Airport Emission Sources • Aircraft Operations • Ground Support Equipment, Auxiliary Power Units • Shuttles, Vans, Taxis • Passenger Vehicles • Cargo Trucks • Construction Equipment • Combustion equipment (i.e. boilers and egens)
General Conformity 101 • Conduct emission inventory for Project (EDMS) • Airside • Construction • Direct and Indirect Emissions • Net emissions (Project emissions above baseline) • If total net emissions below de minimis and not regionally significant, then: • NEPA – action is considered insignificant • General Conformity – Analysis is complete, no General Conformity Determination needed.
Mitigation • Stay out of General Conformity (i.e. air quality dispersion modeling vs. NAAQS) • Stay below De Minimus (i.e. impacts are considered insignificant and analysis done) • Reduce air quality impacts (alternate fuels, electrification) • Plan ahead, develop a long–term air quality plan
In the Air • AEDT • GHG Cap and Trade • Proposed GHG Standard • Proposed 1-hour NO2 Standard • California AB-32
AEDT • Aviation Emission Design Tool • Currently being developed by FAA/DOT Volpe • Incorporate air quality and noise • Replace EDMS, INM, Noise Integrated Routing System (NIRS) • What’s new in AEDT • Multiple radar formats • Input trajectories from NextGen • Validation using flight recordings • Incorporate SAGE Data (fuel burn emissions data) • Scheduled Release 2011
Cap and Trade • American Clean Energy and Security Act of 2009 (aka Waxman-Markey Bill) • Aviation is not explicitly called out in the Bill • Jet fuel refining is part of cap and trade • Fuel more expensive • No viable alternative to Jet Fuel (biofuels?) • Applies to aircraft manufacturing sector (>25K TPY CO2 from fossil fuel combustion) • Main feature is the Cap and Trade program • Allocated Allowances (i.e. Cap) • Purchase additional allowances from other companies (i.e. trade) • Require high emitting industries to reduce there output to specific targets • Incentives to reduce (bank) • Basically it will cost the buyer for additional credits and reward the seller by reducing emissions • Current version does not include emission standards • 2012 European Union preparing for Cap and Trade for aviation
Greenhouse Gas Standard • Newly Created Additional GHG Standard • EPA designated categories not covered by Cap and Trade • Airport stationary sources could be subject to this aggregate emissions category. • Unclear if EPA can or might aggregate stationary sources. Ex. Heating and cooling plants > 25,000 tpy of CO2 would exceed 10,000 tpy proposed threshold. • Bears watching
Proposed EPA 1-Hour NO2 Standard • Currently an annual standard • Proposing a new short-term standard • Proposal ranges from 150 ug/m3 to 188 ug/m3 • Not new to CA under CEQA (current 1-hour NO2 is at 339 ug/m3) • Hourly monitored data at some airports > proposed standard (LAX, SAC, SAN, LGB) • Significant for airports since located near highways and aviation emissions are higher in NOx • Many airports could be located in 1-hour NA, thereby subjecting to General Conformity for NO2 • Public comment closed Sep 14, rule by Jan 2010. Attainment designations by Jan 2012, conformity reviews by 2013.
AB-32 • Global Warming Solutions Act of 2006 • Cut GHG emissions to 1990 levels by 2020 • Effective 2012 • Only EPA and FAA have authority to regulate emissions from Aircraft • Recently reached settlement with San Diego Airport • Reduce emission from expansion • Green building certification • Alternate energy airport shuttles • Gate electrification • Electric or alternative Fuel vehicles • Future projects should think about mitigation (i.e. Massachusetts MEPA GHG Policy)
Thank You for your time…For more information, please contact: • Phil DeVita, CCM • pdevita@hmmh.com • www.hmmh.com