Presented to: By: Date: Federal Aviation Administration Environmental Best Practices Air Quality...

Presented to:

By:

Date:

Federal AviationAdministrationEnvironmental Best

Practices

Air Quality Issues

2010 Hershey Conference

Maria Stanco, AEA Environmental Program Manager

March 3, 2010

2 2Federal AviationAdministration


Maria Stanco

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



Maria Stanco

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



Maria Stanco

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)



Maria Stanco

NEPA vs. General Conformity Analysis

NEPA General Conformity

All Airports (where there’s a Federal action)

Airports in nonattainment and maintenance areas

All criteria pollutants Emphasis on criteria pollutants causing violations

All Reasonable Alternatives Proposed action/No action

De minimis thresholds De minimis thresholds

Activity Level Thresholds CAA exemptions and FAA Presumed to Conform



Maria Stanco

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



Maria Stanco

Airport Activity Threshold for “NAAQS Assessment”

0

50

100

150

200

250

300

0 0.5 1 1.5 2 2.5 3 3.5 4

NAAQS Assessment Should be Considered

NAAQS Assessment not Required 2.6 MAP

180,000 Operations

Gen

eral

Avi

atio

n &

Air

Tax

i Ope

rati

ons

(000

)

Million Annual Passengers (MAP)

THRESHOLD

Source: Air Quality Handbook, Figure 4, p. 20



Maria Stanco

Construction Emissions

• Considered “direct” project emissions

• EDMS has no built-in methodology

• Recommended EPA tools– NONROAD model



Maria Stanco

General Conformity Process

- No new violations

- No increase in the frequencyor severity of existing violations

- No delay in timely attainment

Exempt?

Nonattainment or Maintenance Area?

Emissions Inventory?

Presumed to Conform?

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)

Ensures that Federal Actionsdon’t interfere with SIPs

Federal Action

Presented to:

By:

Date:

Federal AviationAdministration

Ozone

CO

PM10

PM2.5

AEA Commercial Service AirportsNonattainment and Maintenance Status



Maria Stanco

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



Maria Stanco

1. Pavement Markings2. Pavement Monitoring Systems3. Non-Runway Pavement Work 4. Aircraft Gate Areas on Airside5. Lighting Systems 6. Terminal and Concourse Upgrades7. New HVAC Systems, Upgrades, and Expansions8. Airport Security9. Airport Safety10. Airport Maintenance Facilities11. Airport Signage12. Commercial Vehicle Staging Areas13. Low Emission Technology and Alternative Fuel Vehicles14. Air Traffic Control Activities and Procedures15. Routine Installation and Operation of NAVAIDS

PTC Project CategoriesItems in blue have quantitative or “indexed” ranges



Maria Stanco

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.



Maria Stanco

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



Maria Stanco

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

Presented to: By: Date: Federal Aviation Administration Environmental Best Practices Air Quality...

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