The Air Transport Association agrees. “They are essentially, in our view, institutionalizing the use of glycol and setting up disincentives for pollution prevention. So to us, another aspect of this is that EPA needs to think much more carefully about how to incentivize pollution prevention,” says Elizabeth Merida, spokesperson at ATA, adding, “The industry has a very proactive record here in terms of trying to push toward much more environmentally friendly products. We clearly want to keep going in that direction.”
The largest concerns within the industry, however, have remained the overall negative impact the rule could have on safety, operations and cost.
In its comments submitted to the EPA, ATA asserted the agency did not aptly consider safety and operational impacts when it designated central deicing pads as BAT for airports to comply with the 60-percent collection rule, claiming certain design imperatives were not accounted for in the proposal. Also, ATA stated, the EPA did not account for safety imperatives involved with co-locating facilities that must accompany the deployment of deicing pads.
“Indeed, ATA is confident that siting CDPs of sufficient number and size (together with their necessary appurtenances) to handle 100% of the scheduled departures at EWR, LGA, JFK, BOS, and perhaps at other airports will prove impossible,” ATA stated in its comments.
In the area of cost, the ATA questioned the EPA’s assessment, stating that errors in the agency’s calculations alone accounted for a significant underestimate. In its calculations using the EPA’s metrics, ATA stated that annual costs to the industry would be about $179.7 million.
In addition to the EPA’s error in calculations, ATA claimed in its comments, EPA’s formula failed to account for numerous costs that would be incurred by many in the industry – including airlines. “The cost associated with operational impacts is a key example: the added fuel, labor and other costs incurred by airlines as a result of operational inefficiencies imposed under the Proposed Rule fall exclusively on airlines. This potentially massive cost is not captured by an analysis focused on airport costs, even if it is assumed that 100% of these costs are passed through to airlines (as we believe they are).”
Citing such flaws in the proposal, the ATA, along with some other associations, have called for the rulemaking to be abandoned.
When asked for a response regarding comment submissions, the agency stated, “EPA received 58 comments during the six month public comment period. We are thoughtfully considering our responses to these comments as we prepare the final ELG.”
The EPA expects to finalize the guidelines in early 2011.
As the needs of the industry have changed, suppliers have responded with more environmentally friendly fluid.
... that it expects will impact some 200 primary commercial airports in the U.S. It has sent the rule for publication in the Federal Register, after which industry will be able to comment (visit...
EPA Proposes New Deicing Effluent Guidelines