Environmental Affairs Committee Work Plan

The Air Quality Working Group will continue to follow the key topics as identified in a survey conducted in December 2020 to identify key topics of interest, which prioritized the following:

1 (tie). Airport Roadmap to Net Zero (45%)

1 (tie). eGSE Lessons Learned (45%)

2 (tie). Carbon Sequestration (36%)

2 (tie). Carbon Offsets (36%)

2 (tie). Air Quality Modeling (36%)

3. SAF Emissions Benefits (32%)
4. U.S standard for CO2 emissions from aircraft engines/Forthcoming EPA aircraft emission standards (23%)
5. General Conformity Air Quality Analyses – Overview (23%)
6. SAF – Impact on Aircraft Engine PM emissions (18%)
7. Climate Research – Contrails (7%)
8. Supersonics (5%)

In 2021, webinar sessions were held on sustainable aviation fuels (SAF), construction emissions, current air quality research being conducted, lessons learned from eGSE, as well as monthly ACA question and answer sessions.

In 2022, the Air Quality Working Group proposes to coordinate 4 webinar sessions based airport interest and current trends such as need to address emerging technologies such as electric aircraft and regulatory actions (i.e. EPA’s endangerment finding process for lead from piston driven aircraft). A number of these topics correlate with the interests and expertise of other ACI-NA working groups, such as Sustainability and International.

A general overview of the contemplated webinar sessions is provided below.

Roadmap to Net Zero Carbon

1. Provide an overview of ACRP project 02-82, Developing a Roadmap to Achieve Zero Emissions at Airports from ACRP project Team.
2. Provide experience and insights from DFW, SAN or another airport that has achieved advanced levels within ACA.
3. Airport planning for net zero.

Background – In 2020, Level 4 (Transformation) and 4+ (Transition) were added to the Airport Carbon Accreditation program to align it with the objectives of the Paris Agreement to limit the increase of global average temperature to 2°C above pre-industrial levels and aim to not exceed 1.5°C.  Levels 4 and 4+ have been introduced as an interim step towards the long-term goal of supporting airports in achieving net zero carbon emissions. Level 4 and 4+ therefore encourages airports to reduce their emissions in line with the latest scientific and political developments and meet growing public and stakeholder expectations.

Carbon Mitigation – Offsets and Sequestration

1. Presentations from subject matter experts and ACA Workgroup;
   • The role of offsets and sequestration in reducing carbon emissions
   • How CORSIA impacts airlines and overall carbon emissions at airports
   • Offset procurement and the current marker
   • Technologies and methodologies for sequestration
   • What is an airport to do?

Background

As airports work toward net zero carbon, they must develop strategies to mitigate the carbon from their operations that they cannot directly reduce.  Likewise, airlines must mitigate future carbon emissions to comply with upcoming CORSIA requirements, which could present opportunities for airports to develop sequestration projects.   This session will provide airports with important insights on carbon mitigation projects and markets as well as what other industrial sectors are doing in terms of sequestration.

Lead Emissions from Piston-Driven Aircraft

The presentation could include the following items:

1. Summary of EPA Endangerment Finding Process
2. Current status of unleaded AvGas
3. Airport Case Study

Background

Aviation gasoline (AvGas), used in piston-engine aircraft, is the only transportation fuel in the United States that contains lead. The most common and reliable type of avgas is 100 octane Low Lead, also known as 100LL, which contains tetra-ethyl-lead (TEL), which is an additive used to prevent engine damage at higher power settings.   Although there are several sources of lead exposure besides AVGas, children’s exposure to lead can cause irreversible and life-long health effects. No safe blood lead level in children has been identified. Even low levels of lead in blood have been shown to affect IQ, ability to pay attention, and academic achievement. In adults, health impacts from lead exposure can include cardiovascular effects, increased blood pressure and incidence of hypertension, decreased kidney function, and reproductive issues.

The U.S. Environmental Protection Agency (EPA) on January 12 that it will evaluate whether emissions from piston-engine aircraft operating on leaded fuel contribute to air pollution that endangers public health and welfare. Under the Clean Air Act, EPA reviews information on air pollutants and sources of air pollution to determine whether they threaten human health or welfare (often referred to as an “endangerment finding”). The agency plans to issue a proposal for public review and comment in 2022 and take final action in 2023.

Transitioning to eGSE – Insights and Lessons Learned –Part 2

This webinar, conducted with the Sustainability Working Group, was well received and interest in a second webinar providing greater details.  The presentation by airport that have or are transitioning to eGSE can include the following topics:

1. Planning for eGSE Conversion and budgeting
2. Securing airline commitments
3. Operational and technical considerations
4. Evaluating electrical capacity with other emerging technologies (electric aircraft)

Background

Petroleum powered GSE is a significant source of criteria pollutant and greenhouse gas emissions at airports.  In addition, diesel emissions account for the majority of health risk from air toxics.  Elevated concentrations can extend long distances from their source, affecting the health of on-airport workers and nearby communities While eGSE yield significant environmental and operational benefits, including reduced operational costs, the transition to eGSE requires a significant investment in both electrical infrastructure and equipment.   The current financial landscape presents some additional challenges for airports.

Airports can benefit from shared insights and experiences on how to build a compelling case for transition to eGSE and how to engage with airlines on overall strategy and timeline as well as understanding key operational and equipment considerations in developing eGSE transition plans.

The Air Quality Working Group will also continue to provide the latest regulatory information and air quality trends in monthly updates to the Steering Group as well as announcements before webinars.

The CAEP/International Affairs Working Group engages and provides a voice to North American airports in shaping ACI-World’s and CAEP’s environmental policies and positions as guided by the North American Environmental Affairs Committee and Board of Directors. This Working group will actively monitor and report on developments related to aviation environmental topics, challenge areas, and best practices. The Working Group will work closely with the ACI World Environmental Steering Committee, and ACI-NA’s WEnSC members to help establish and promote effective worldwide policies and statements on aviation environmental challenges; influence international standards, legislation, policy and rulemaking by representing airports’ interests and unique perspectives on environmental matters; develop strong partnerships across the international aviation industry and among other key stakeholders on environmental topics; improve international awareness, training and sharing of information on aviation’s environmental impacts and mitigations; review materials provided by the World committee and CAEP working groups and recommend comments and feedback to these documents that represents North American airport’s practices and perspectives; and report initiatives and recommendations to the Environmental Affairs Committee and the North American Board of Directors regarding World Committee and CAEP activities and positions.

 Focus Areas:

1. Facilitate information exchange with global airports
   • Enable ACI-NA airports to learn best practices from airports in other ACI regions by hosting two meetings that feature topics implemented at international airports.
2. Tracking and reporting on global aviation mega-trends through a bi-annual email update.
3. Participate in ACI World Environmental Steering Committee and report on ICAO CAEP Working Groups (in coordination with members.)
   • Provide updates on studies and key milestones to ACI-NA airports
   • Leverage WEnSC membership to present global airport best practices (see #1)
4. Identify ways to expand outreach and education to broaden member participation (e.g. record meetings, notes/highlights, international highlight for Sustainability Newsletter)

Topics the International Issues group is tracking include:

• CORSIA implementation [pilot phase 2021]
• IPCC Updates
• ACI CO₂ Long Term Goal study
• UNFCCC COP25 results
• ACI WEnSC Updates
• Flight Shaming
• Electrification & Decarbonization
• Quality of Life
• Nexus of Sustainability and Health
• COVID Recovery
• Resiliency
• Environmental, Social & Governance Reporting (ESG)

1. Coordination with Noise Working Group for the refinement of off-airport land use policy in consideration of the Draft Advisory Circular (AC) 150/5020-1A, Noise Control and Compatibility Planning for Airports, and the FAA Neighborhood Environmental Survey.
2. Coordination of the FAA Airport Land Use Compatibility Advisory Circular 150/5190-4A, as released following FAA adjudication of comments on the draft released in 2021.
3. Collaborate with the NEPA, Noise Working Group and Legal Affairs Committee on issues related to the implementation of Section 163 in the 2018 FAA Reauthorization Bill.
4. Educate members (via calls, webinars, conference sessions) on how compatible land use policies and guidance can benefit the community and potential developers, as well as the airport; and how the airport can monitor the local government’s efforts to follow through on the implementation of the compatible land use policy/regulation.

1. Provide the committee updates to regulatory information related to FAA requirements for Wildlife Hazard Assessments, Management Plans, and training.  When applicable, work with the committee to collect and consolidate comments on draft documents or draft regulatory changes.
2. Work with the committee to provide examples of mitigation efforts that were successful at airports (via conference calls, webinar, conference session and/or memo).  Mitigation could be related to wetlands, protected species, habitats or other natural resources.  The intent is to provide a panel presentation of “best practices” and “lessons learned.”

1. Advise the Committee, and ACI-NA members in general, of changes in the regulatory environment, obtain input, and pursue improved guidance through comments and feedback provided to the FAA.
2. Provide ACI-NA members with information to understand the changes in the CEQ Regulations and keep abreast of any revisions to those CEQ regulations that may occur under the new Administration.
3. Monitor the various approaches to Section 163 documentation provided by different regions of the FAA to better understand how compliance with Section 163 affects all upcoming projects.  Share 163 examples with the Work Group.
4. Monitor all Executive Orders under the new Administration to determine how this affects Executive Order 13807 and the One Federal Decision process.
5. Provide input and feedback on the forthcoming draft of the Office of Airports NEPA Order 5050.4C and its associated Desk Reference.  This includes planning and holding a workshop on 5050.4C.
6. Promote better integration of planning and NEPA reviews, through the working group quarterly calls, conference sessions and coordination with the Operations and Technical Affairs Committee.
7. Provide input, as requested, to the Operations & Technical Affairs and Legal Committees on issues related to non-aeronautical development and NEPA requirements for Airport Layout Plan changes around which there are differing interpretations.
8. Collaborate with Noise Working Group and other working groups as appropriate to track and provide feedback on FAA’s efforts to update their community engagement manual/ guidance documents.
9. Prepare for and conduct the NEPA Workshop.
10. Mid-2022 start NEPA Chair search due to Kane’s 2023 retirement.

1. Actively engage with the FAA on the Neighborhood Environmental Survey, review materials published by the FAA and advise ACI leadership as policy is developed.
2. Continue monthly Noise WG webinars on topics of mutual interest, in lieu of 2022 Aviation Noise Conference.
3. Continue to monitor implementation of FAA’s Noise Complaint Initiative and provide support as appropriate.
4. Report on current status of major noise initiatives and research (including FAA, ASCENT, and ACRP research projects) for the benefit of ACI-NA members, and advocate for airport interests regarding future noise research projects with FAA.
5. Provide support to the ACI-NA Government Affairs department on legislative issues regarding noise. The Noise WG will also collaborate with the Legal Affairs Committee, as needed, on these matters.
6. Report on developments in noise modeling and assessment. The Noise Working Group will coordinate with FAA to disseminate information and provide an overview of changes with new model releases.
7. Track and report on noise-related issues associated with emerging technologies and participate in appropriate federal advisory committees and discussion groups. Identify potential policy implications affecting airports and advocate solutions acceptable to airports industry.  Work with NextGen Working Group (joint WG with Ops/Tech) to develop guidance materials for airports regarding NextGen implementation.
8. Coordinate with ACI World Environment Standing Committee (WEnSC) on issues related to proposed introduction of supersonic aircraft.

The Sustainability Working Group will assist Canadian and U.S. Airports within ACI-NA in continuing sustainability leadership and commitment to the “Triple Bottom Line.”  Specifically, the Working Group will support the ACI-NA’s Sustainability Policy Statement and align its mission with the overarching Sustainability Integration and Advisory Council’s future goals and recommendations.  The Working Group will also support work done by the Council and its task groups that are focused on topics such as Sustainable Aviation Fuel.

1. Foster information exchange and education about the airport industry sustainability initiatives and regulatory activities through its periodic Sustainability Newsletter, TRB and ACRP reports, webinars, and other outreach methods.
2. Create a working group session with the other ACI-NA groups engaged in Environmental, Social, and Governance (ESG) (including ESG Task Group, new Energy Task group, OPS ID, and Business Information Technology Committee) to define data needs to better assess, track, and enhance an airport’s sustainability performance and/or identify industry gaps, such as the potential electrification/alternative fuels for airport equipment (runway sweepers, plows, mowers, etc.)
3. Provide leadership from a Sustainability Working Group subject matter expert perspective on the elements of ESG and develop an ESG 101 webinar to discuss the elements of ESG with the filter of sustainability.
4. Explore partnerships with the Ops/Tech Group to discuss overall airport infrastructure and asset management strategies and explore opportunities with the newly passed Infrastructure Bill.
5. Continue to explore how certification programs are changing the aviation industry, contributing to sustainability initiatives, and how airports can better prepare for or provide flexibility to accommodate these changes.
6. Provide resources and opportunities to further ad hoc discussions regarding the socioeconomic, human health and wellness aspects of sustainability, social return on investment, community engagement, and other quality of life issues.

Mission Statement – The Waste Management Working Group prioritizes engagement, collaboration, and innovation. The Working Group monitors, reviews, and analyzes, regulations, policies, and practices relating to airport waste management issues. Areas of focus include waste reduction and reuse, donation, composting, recycling, hazardous materials management, and environmental due diligence. The Working Group provides necessary review or input on waste management issues to the Environmental Affairs Committee and provides a platform for airports to collaborate and share best practices for airport waste management among airports, industry partners, tenants, and communities.

1. Provide a forum for airports to share best management practices and facilitate information sharing on airport waste management and diversion strategies through ACI Working Group Meetings, quarterly phone conferences, and upcoming ACI-NA Environmental Affairs conferences. In 2022, facilitate and promote ACI Centerlines Connect as a tool to share resources of mutual interest, including case study information, information about emerging contaminants and specific waste streams, infrastructure procurement information, photos, plans, and other documents that airports routinely seek when developing waste initiatives.
2. Facilitate discussions with FAA, TSA, airlines, concessionaires, flight kitchens, janitorial and facility management companies, waste hauling companies and other key airport waste stakeholders to address issues of mutual importance including reduction, reuse, donation, liquid collection, recycling, checkpoint and food waste diversion, deplaned and international waste management, PPE management, and hazardous materials.
3. Continue to track, contribute to, and disseminate guidance and resources developed by regulators and industry stakeholders, including a) FAA guidance; b) ACI World/IATA guidance; c) ACRP research on waste management practices, d) international commodity market trends, e) PPE recycling and disposal practices, and f) hazardous waste regulations.

The Water Quality Working Group monitors, reviews, analyzes, and guides regulations, policies, and research relating to water quality issues impacting airports.  Areas of focus including water quality; discharge permitting; deicing; spill prevention, control and countermeasures (SPCC); water conservation; and drinking water.  The Working Group will provide necessary input and recommendations on water quality issues to the Environmental Affairs Committee.

This 2022 Water Quality Working Group (WQWG) Plan is based on the 2021 Plan and is a continuation of its critical components.  The items below outline our plan, but should circumstances arise in other areas, we will adjust our plan accordingly and keep the Committee informed as appropriate.

1. PFAS Issues: PFAS continues to be a major focus of the water quality group. Issues generally expected to be pursued further in 2022 include:

• • Coordination with ACI-NA’s PFAS “Experts” Group;
  • Federal and State legislative/regulatory review and communication of applicability and potential impacts on airports;
  • Potential liabilities facing airports;
  • Remediation and disposal methods/options;
  • Fluorine-free foam alternatives (Canadian airport experiences, FAA progress);
  • Equipment and hangar cleaning technologies and collection/disposal options for AFFF inventories;
  • Airport tenant-related PFAS issues (hangars, fuel farms, etc.);
  • Laboratory and sampling developments and approved analytical methods;
  • Coordination with ACI-NA’s PFAS “Experts” Group;
  • Continued collaboration with other workgroups also affected by PFAS. The Water Quality Working Group has taken leadership on PFAS issues for the Environmental Committee, but we encourage other Working Groups to contribute to the PFAS discussions to provide their particular expertise/insight into possible impacts on ACI members. We welcome other Working Group involvement and coordination/collaboration.

2. Clean Water Jurisdiction/Waters of the US (WOTUS) Issues: The Trump Administration finalized a new definition of WOTUS in 2020. The Trump Rule has been stayed in federal court. The Biden Administration has proposed a new definition, returning to a more expansive definition for WOTUS (similar to the original Obama Administration definition).  Meanwhile, the Supreme Court is considering whether to take up a case that would allow the Court to clarify its earlier opinions (including Rapanos) regarding Clean Water Act jurisdiction.  The WQWG will follow and report on any changes to the federal and state Clean Water Act jurisdictional definitions or limitations.  In addition, the Supreme Court has found that discharges into groundwater that are the “functional equivalent” of surface water discharges also require NPDES permits.  The WQWG will continue to follow these issues and inform airports of any final determinations that would impact airport CWA permitting or liability.
3. NPDES Permit Issues: The WQWG will continue to track NPDES Permitting issues that may impact airports. This includes the EPA’s revised Multi-Sector General Permit (MSGP) issued in January 2021. This permit serves as the model industrial stormwater permit for most state programs.  The WQWG will provide insight to the membership on implications to airports and monitor how state regulatory agencies respond to new elements in the MSGP within their own NPDES programs. Stormwater Pollution Prevention Plans (SWPPPs) are required elements of airport NPDES permits and can be complicated due to the tenant operations. The WQWG will continue to discuss best practices and challenges regarding SWPPP development and implementation at airports. The WQWG will also monitor how NPDES permitting programs could impact airports, including the Construction General Permit reissuance and the Municipal Separate Storm Sewer System (MS4) permit program.

4. Aircraft and Pavement Deicing Issues: On January 8, 2021, EPA released its final “304(m) Plan” that outlines the status of its Effluent Limitations Guidelines (ELGs) program, assesses the current benefits from its various ELGs, and its future ELG efforts.  EPA concluded that the current Aircraft Deicing ELGs are appropriate and do not need review or revision.  However, it identified airports as an industry to continue to study in its Multi-Industry PFAS ELG study.  The WQWG will monitor EPA’s progress on the PFAS ELG issue and also will focus on sharing information and best management practices related to pavement deicing approaches (an issue raised at several WQWG sessions).
5. Drinking Water Issues: On December 16, 2021, EPA announced the development of a new regulation, Lead and Copper Rule Improvements (LCRI), to better protect communities from exposure to lead in drinking water. In addition, various drinking water and water efficiency issues have been raised during prior WQWG sessions. The WQWG will monitor and provide updates on the lead and copper rule, as available, and continue to solicit specific issues and concerns for future efforts on behalf of airport members.
6. SPCC: The WQWG will address, as needed, various issues regarding Spill Prevention Control and Countermeasures Plans and implementation including secondary containment and large spill management planning.