Proposed Effluent Guidelines For Deicing Heat Up

Many industry associations respond critically to the EPA’s proposed rulemaking.


Mitigating the environmental impact of deicing operations has continued to be a strong focus for the industry. In 2009, the Environmental Protection Agency unveiled its new proposed effluent guidelines to regulate deicing operations at airports — which have drawn sharp criticism from industry associations.

Regulation Basics

Under the proposed rule introduced last year by the EPA, primary commercial airports that conduct deicing operations with more than 1,000 annual scheduled departures, more than 10,000 annual departures and less than 460,000 gallons of fluid would be required to collect 20-percent of the spent fluid. The EPA’s recommended technology for compliance is glycol recovery vehicles. By EPA’s estimates, about 96 airports would be subject to the regulation.

Primary commercial airports with more than 1,000 annual scheduled departures, and more than 10,000 annual departures that use more than 460,000 gallons of fluid annually would be subject to a 60-percent collection rule. The EPA designated central deicing pads as best available technology (BAT) to meet compliance. According to the EPA, 14 airports would be subject to the 60-percent rule.
Airports would also be required to treat the fluid collected before discharge by recommended treatment processes, which include an anaerobic fluidized bed treatment system (AFB).

Also under the proposed rule, new sources of deicing fluid runoff would be subject to the regulation. “New Source” would apply to a new primary airport and a new runway constructed at a primary airport.

Among the benefits of the proposed rule asserted by the EPA include improved water quality adjacent to and downstream of about 70 airports around the country. The oxygen depletion, measured as chemical oxygen demand (COD), would be reduced by 39.9 million pounds a year.

In the EPA’s view, the rule is needed in addition to current permitting processes. “Although all airports have discharge permits, most permits require airports to prepare a stormwater pollution prevention plan and occasionally test their discharges. These permits do not include specific requirements for collection and treatment of deicing wastes. As a result, a number of airports have inadequate systems for collecting spent deicing fluids. Several large airports have no systems at all — their deicing wastewaters are all discharged untreated into local water bodies.”

The EPA has estimated the cost to the industry would be about $91.3 million annually.

Industry Response

In its comments submitted to the EPA, the National Air Transportation Association stated its concern about the agency’s uniform approach. “NATA is concerned that the EPA’s one-size-fits-all-approach to dealing with deicing runoff does not adequately account for the unique operations at our nation’s commercial service airports,” says Michael France, NATA’s director of regulatory affairs, in the association’s comments. “The specialized operations of individual airports and the effect their efficient operation has on the national airspace system do not lend themselves to this type of standardized approach to environmental regulation.”

And that concern has echoed throughout the industry. “I think overall we see a problem with a lack of real flexibility in what’s been proposed,” says Jessica Steinhilber, senior director, environmental affairs at ACI-NA.

In the ACI-NA’s comments submitted to the EPA, it points out that the agency did not accurately assess the environmental benefits. “We think the EPA has overestimated the amount of fluid being used,” she says.

In fact, ACI-NA asserted that the EPA’s approach could discourage the use of more environmentally friendly technology. “The way that the rule is set up, it doesn’t necessarily encourage pollution prevention practices,” she says. “There is no real incentive in the way the EPA has proposed the rule.”

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