SUSTAINABILITY & RENEWABLE ENERGY€¦ · OH MR. SUN, SUN, MR. GOLDEN SUN, PLEASE SHINE DOWN ON...

35th Annual Airport Law Workshop

SUSTAINABILITY & RENEWABLE ENERGY

Elizabeth Leavitt

Port of Seattle

Sarah Keane

Kaplan Kirsch & Rockwell

Session #20

35TH ANNUAL AIRPORT LAW WORKSHOP

AIRPORT ENERGY AND SUSTAINABILITYMEETS THE LAW

2

Potential legal hurdles and opportunities: AIP funding for comprehensive planning

VALE grants for specific projects

ALP and Master Plan conformity

Lease or license arrangements

NEPA and other environmental compliance

Airspace, glint and glare review (solar, wind)

Power purchasing arrangements


OH MR. SUN, SUN, MR. GOLDEN SUN, PLEASE SHINE DOWN ON ME…

3

Drivers:

Local or state energy / climate goals

Long-term cost savings

Lots of open land and rooftops

Potential legal hurdles:

ALP and Master Plan conformity

Lease or license arrangements

NEPA and other environmental compliance

Airspace, glint and glare review

Power purchasing arrangements


START WITH THE MAP

4

Update the ALP if:

Changing use of airport property

Ground-mounted or change building max height

Require new footprint or change the footprint of existing structures


LEASE ? RELEASE?

5

• Consult with FAA & show prudent financial benefit

• Consider limited-scope license insteadLeasing?

• Get “written consent” from FAA• Formal release usually not required Deed restricted?

• May need release from grant assurances • Cumbersome process

Federally funded land?


LIONS AND TIGERS AND BEARS, OH MY!AKA….ENVIRONMENTAL REVIEW

6

NEPA triggered if:

FAA takes a formal action

Categorical Exclusion available if:

Max 3 acres (all equipment)

Not going to hurt birds or bats

Contracts include requirements to control dust, sedimentation, storm water and spills

Plus state and local requirements Image source: Audubon


BLINDED BY THE LIGHT?

7

Part 77 notice and review

Glint and glare review Solar glare

Hazard analysis tool

Image source: ForgeSolar


FEEL THE POWER!

Power purchase agreements Private party develops and owns project

Airport sponsor purchases power

Net metering arrangements Airport sponsor owns the project

“Behind-the-meter” directly offset purchases from the utility

8

35TH ANNUAL AIRPORT LAW WORKSHOP 9

HOW FAR CAN YOU GO?

Image source: Chattanooga Times Free Press

Sustainability and Renewable Energy

Elizabeth Leavitt

Senior Director

Engineering, Environment, and Sustainability

10


1. Meet all increased energy needs through conservation and renewable sources

2. Meet or exceed agency requirements for stormwater leaving Port-owned or -operated facilities

3. Reduce air pollutants and carbon emissions…

11

CENTURY AGENDA OBJECTIVES

GHG Type 2020 Goal 2030 Goal 2050 Goal

Scope 1 and 2 15% lower* 50% lower* CO2 Neutral

Scope 3 -- 50% lower** 80% lower**

* Compared to 2005 levels; ** Compared to 2007 levels

Century Agenda sets clear and ambitious targets


0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

2010 2015 2020 2025 2030 2035

Liquid Fuels

Projected Load Growth

2011 Baseline

Electricity

Natural Gas

PORT-WIDE ENERGY FORECAST

12

MM

BT

U

Maritime electricity


0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

2010 2015 2020 2025 2030 2035

PORT-WIDE GHG EMISSIONS FORECAST

13

Liquid Fuels

2011 Baseline

Electricity

Century Agenda Goal

Projected Emissions

To

nn

es

CO

2

Natural Gas


Energy efficiency Stage 3 Mechanical

Lighting upgrades

Renewable natural gas Boilers and bus fleet

Renewable diesel

Green Fleet

PSE’s Green Direct (wind power)

14

CARBON REDUCTION STRATEGIES

Port is pursuing multiple carbon reduction strategies


0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

2010 2015 2020 2025 2030 2035

IMPACT OF SUSTAINABILITY STRATEGIES

15

Liquid Fuels

2005 Baseline

Electricity

Natural Gas

Century Agenda Goal

Conservation

To

nn

es

CO

2

Projected Emissions


RENEWABLE NATURAL GAS (RNG)

Replace CNG in boilers and buses

3 main sources

Landfills, wastewater treatment plants, and dairy farms

Currently in negotiations and expect to use fuel in 2020

Will meet carbon goals ten years early

When used in buses, receive federal credits (RINS) that reduce price

16

RNG market has evolved considerably in the last 5 years


CARBON REDUCTIONS IN SEA-TAC BUS FLEET RELATIVE TO CNG

17

RNG Electric

Emissions reduced relative to CNG (tons CO2/year) 1,220 1,200

$/ton of CO2 reduced relative to CNG $0 $925

RNG and electricity reduce similar amounts of carbon but at different price


COMPARING COSTS AMONG STRATEGIES

18

Strategy Approximate Cost/MT Carbon

% Carbon reduced/year

AV Solar: Main parking garage $10,000 0.3

Renewable natural gas (boilers) $400 70

Convert buses to electric $900 10

Stage 3 Mechanical Conservation $300 4

Renewable Diesel (fleet) $125 2

Green Direct – Wind $61 5

RNG Buses $0 5

Solar projects result in relatively high cost per ton of carbon reduced


Greater opportunities for strategic partnerships

Projects cost-effective due to:

Economies of scale

~25% “more sun” in eastern WA

Power purchase agreements (PPAs) in collaboration with other Ports

19

SOLAR AND WIND PROJECTS IN EASTERN WA

Off-site projects likely meet Port goals at lower cost


SUSTAINABLE AVIATION FUELS (SAF) PROGRAM

Goal: bring sustainable aviation fuels (SAF) to Sea-Tac International Airport

Key strategies Develop an Airline-Airport Cooperative

Model to work together on carbon reduction

Pursue legislative policies to bring down the high cost of SAF

Pursue FAA approval of the co-benefits of SAF (e.g., reduction of ultra-fine particles)

Education and advocacy

20

Program focuses on four strategies aimed at reducing the incremental cost of SAF


SAF CO-BENEFIT

21

FAA authorizes grant funds for Pre-Conditioned Air to reduce emissions

10% SAF also reduces particles, sulfur, and UFP, but small amounts

Federal funds could reduce the incremental cost of SAF and help spur market


LOW CARBON FUEL STANDARD (LCFS)

WA is at a competitive disadvantage for renewable fuels

The most effective policy instrument to build SAF market is a Low Carbon Fuel Standard like California

22

??

Policy harmony is needed to develop a SAF market outside California


Sustainable Project Initiative Incorporating sustainability into Port decision-making in capital

development projects

Analyze alternatives to reduce energy and greenhouse gases for larger capital projects

Transportation Management Association (TMA) Bring airport tenants together to provide more options for

carpooling

Create stronger advocacy for improved transit

23

EMERGING SUSTAINABILITY INITIATIVES

Transparency at Commission an underlying factor


ATTORNEY ADVERTISEMENT. The contents of this presentation, current at the date of publication, are for reference purposes only and do not constitute legal advice.The contents do not reflect the official opinion of Kaplan Kirsch & Rockwell LLP. Responsibility for the information and views expressed within this document lies entirely with the author(s).© 2019 Kaplan Kirsch & Rockwell LLP

QUESTIONS

SUSTAINABILITY & RENEWABLE ENERGY€¦ · OH MR. SUN, SUN, MR. GOLDEN SUN, PLEASE SHINE DOWN ON...

Documents

Transcript of SUSTAINABILITY & RENEWABLE ENERGY€¦ · OH MR. SUN, SUN, MR. GOLDEN SUN, PLEASE SHINE DOWN ON...