Development of the ELGs represents the culmination of years of effort by EPA to quantify and more strictly regulate the stormwater discharge of deicing chemicals. Over the past ten years some airports have, either voluntarily or because of regulatory pressure, spent millions of dollars to deal with this expensive and technically challenging issue. Ongoing efforts by the most sophisticated and aggressive facilities will probably form the basis for systems and measures EPA will ultimately decide are technologically and financially feasible for all airports.
The most vulnerable facilities will be those which, due to a lack of knowledge or regulatory scrutiny, have been operating with no discharge permit whatsoever. Those would be well advised to conduct, sooner rather than later, a self-audit using qualified personnel acting under any applicable state environmental audit enforcement shields that may be available.
Besides representing a body of information that EPA will use to impose technology-based Clean Water Act limits on airports and air carriers, the public information in the ELG questionnaires could potentially be scrutinized to identify presently noncompliant facilities.
Further information about the ELG process can be found on EPA's website at http://www.epa.gov/waterscience/guide/airport/index.html.