Environmental Best Practices

1. Environmental Best Practices Air Quality Issues 2010 Hershey Conference Maria Stanco, AEA Environmental Program Manager March 3, 2010

2. Air Quality Issues • Brief overview of required Air Quality Analysis • Common Mistakes • Helpful Hints NOTE: This presentation relates to simple projects. Not those requiring dispersion analysis

3. Air Quality Requirements • National Environmental Policy Act (NEPA) • Applies to all federal actions • Exemptions for smaller airports • Clean Air Act (Conformity) • Applies to all federal actions in nonattainment areas • Project may be exempt or Presumed to Conform Although requirements may differ, generally same analysis fulfills requirements for both

4. Guidance • Air Quality Procedures for Civilian Airports and Air Force Bases (2004) • General Conformity Guidance Q&A (1994) • General Conformity Guidance for Airports Q&A (2002) • Desk Reference for Airports Actions (2007)

5. NEPA vs. General Conformity Analysis

6. NEPA Process • Overview • Is airport’s activity level above FAA thresholds for requiring a NAAQS analysis • Complete emissions inventory – including construction emissions • Evaluate whether concentrations are below de minimis levels

7. Airport Activity Threshold for “NAAQS Assessment” General Aviation & Air Taxi Operations (000) THRESHOLD Million Annual Passengers (MAP) Source: Air Quality Handbook, Figure 4, p. 20

8. Construction Emissions • Considered “direct” project emissions • EDMS has no built-in methodology • Recommended EPA tools • NONROAD model

9. General Conformity Process Ensures that Federal Actionsdon’t interfere with SIPs Federal Action - No new violations - No increase in the frequencyor severity of existing violations - No delay in timely attainment Nonattainment or Maintenance Area? Exempt? Routine maintenance, etc. 15 non-runway project categories: small upgrades and system improvements that do not change the capacity or operational environment of the airport (i.e., emissions) Presumed to Conform? Emissions Inventory?

10. AEA Commercial Service AirportsNonattainment and Maintenance Status Ozone CO PM10 PM2.5 Source: VALE website

11. CAA Exempted Actions • Examples • Actions covered by Transportation Conformity • Actions having net total direct and indirect emissions below deminimis levels • Routine installation of NAVAIDS • Routine maintenance and repair activities • Transfer of ownership of real property

12. PTC Project Categories Items in blue have quantitative or “indexed” ranges

13. Common Mistakes • Yes – May have to do air quality analysis even if airport in attainment areas • Yes – Conformity applies in maintenance areas • Yes – Have to evaluate construction emissions even if project will not affect airport operations – Use NON-Road Model • No – Don’t normally do air dispersion analysis. Do inventory first. Exception for “hot spot” analysis needed for traffic intersections.

14. Best Practices • Follow Desk Reference and Air Force Air Quality Guide • Use questions on revised Short Form EA Form as a quick guide– will lead you through process • Keep abreast of changes in air quality area designations – they change

15. Be Aware • New ozone nonattainment standards – may change classifications – lower threshold levels • HAPS analysis Guidance Sept 2009. EAs for major projects (new terminal, new runway, other major construction) If required to do NAAQS inventory must also do inventory for HAPs. • CEQ issuing guidance in 2010 on GHG