An EPA Refresher

Directors and environmental compliance managers at commercial service airports around the country face increased demands from ever-changing air quality regulations. The U.S. Environmental Protection Agency (EPA) continues to rapidly review and revise...


Directors and environmental compliance managers at commercial service airports around the country face increased demands from ever-changing air quality regulations. The U.S. Environmental Protection Agency (EPA) continues to rapidly review and revise limits for the most common pollutants. Strengthening these limits, known as National Ambient Air Quality Standards (NAAQS), will cause many areas currently defined as healthy areas (i.e., attainment areas) to become unhealthy (i.e., non-attainment) for one or more of the standards.

Therefore, it’s important for airports to keep up with non-attainment area requirements. Often, these requirements can affect program decisions for capital projects such as airport expansions and airport operations. Federally sponsored facilities must also comply with the National Environmental Policy Act (NEPA) for capital projects.

Air Quality Designations

The NAAQS are set by EPA to protect public health and the environment from six of the most common air pollutants. Standards are set for carbon monoxide, lead, nitrogen dioxide, particulate matter, fine particulate matter, ozone, and sulfur dioxide. The Clean Air Act (CAA) requires EPA to review and revise, if necessary, these standards every five years. No later than one year following a revision of an air quality standard, states or tribes must submit recommendations to EPA identifying areas that do not meet the revised standard.

Assuming the data is sufficient, EPA must finalize designations no later than two years following promulgation of a new or revised standard. Once EPA finalizes the designations, states, tribes, or local governments have three years to submit plans that show how they will meet it.

Due to a backlog, EPA is now promulgating revisions to the NAAQS at a rapid pace. Once an area is designated non-attainment, facilities in this area become subject to new requirements like New Source Review, Reasonably Available Control Technology, and General Conformity Programs. The latter require airports to offset emissions before expansions or modifications at the airport are approved. Airports remain subject to the General Conformity regulations for many years after an area attains the standard and becomes a maintenance area.

Increasing numbers of non-attainment areas

Overall, the number of counties designated as non-attainment or maintenance (and therefore subject to General Conformity) for the criteria pollutants has nearly doubled in the past ten years. In 2000, 685 counties were designated either as non-attainment or as maintenance for all of the criteria pollutants. Many of these counties were designated as non-attainment or maintenance for more than one criteria pollutant. In 2010, more than 1,000 counties were designated either as non-attainment or maintenance.

During the past 10 years, many of the standards revised by the EPA are more stringent than the previous standard. In some cases, the form of the standard has also changed. The most dramatic increases were in ozone and particulate matter. The lead standard was recently revised and 17 new areas were identified as non-attainment during the first round of designations. It’s anticipated that more areas will be added during the second round. The lead designations will be important to some commercial service airports.

Opportunities

The above sections describe some of the requirements and challenges. However, there are opportunities to help promote a healthy environment while updating airport infrastructure and equipment. One such opportunity is the Federal Aviation Administration’s (FAA) VALE Program.

In 2003, Congress enacted a law to help commercial service airports meet their obligations under the CAA and improve air quality in areas with unhealthy air. The Vision 100-Century of Aviation and Reauthorization Act (Vision 100) directed FAA to establish a voluntary emissions reduction program to improve air quality at commercial service airports in non-attainment or maintenance areas. Subsequently, in 2005, FAA established the VALE Program.

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