It is well documented that air pollutants can cause health-related problems. In fact, pollutants, such as ozone and particulate matter (PM), can cause serious and even permanent lung damage. As such, the ongoing federal-state effort to improve the nation's air quality is imperative to making the air healthier to breathe.
Recently, the U.S. Environmental Protection Agency (EPA) revisited the rules for ozone and PM. Although these new standards move toward a common goal of improving air quality, it is important to keep in mind the direct impact they will have on U.S. airports.
Changes in Regulations
Ozone and PM are often grouped together because of how they are formed—via a photochemical reaction between nitrogen oxide and volatile compounds, of which industrial emissions, vehicle exhaust, and aviation activities are all sources.
Since 1987, PM has been regulated only as PM10, because PM measuring 10 micrometers can become lodged in the lungs causing deleterious health effects, while the nose successfully filters PM larger than 10 micrometers. However, researchers have discovered that PM measuring 2.5 micrometers, particulate formed primarily in the air from chemical reactions, also contributes to serious lung ailments, leading to the addition of regulations for PM2.5.
The previous standard for ozone was established by taking 1-hour measurements. The EPA has recently changed this methodology and is now measuring ozone over 8-hour increments. As a result of this new approach, many areas of the country previously in compliance with the ozone standard are no longer in compliance. Areas EPA has found that do not meet ozone standards are classified as nonattainment areas. Depending upon the severity of the nonattainment, areas are designated as moderate, serious, or severe nonattainment.
States with 8-hour ozone nonattainment areas must develop or revise a state implementation plan (SIP) for ozone by June 15, 2007; while those with PM2.5 nonattainment areas must develop a PM2.5 SIP in April 2008. SIPs need to demonstrate how an area will reduce the ozone and PM2.5 in the air and the chemicals that contribute to ozone and PM2.5 development. Compliance for moderate, serious, and severe ozone levels must be met by June 2010, June 2013, and June 2021, respectively. PM2.5 standards must be attained by April 2010 (or by April 2015 with an EPA approved extension).
Actions for U.S. Airports
The revised standards may create new obligations for airports, including permitting and emission control equipment. In addition, when seeking Federal Aviation Administration (FAA) approval and/or funding for many projects, airports in nonattainment areas are required to demonstrate that these actions will conform with the Clean Air Act. There are only a few approved approaches to demonstrating conformity for an airport project:
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Show the project is identified in the SIP
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Show emission increases are included in the SIP
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Obtain emissions offsets and implement mitigation measures
To take advantage of cost-effective approaches and airport safeguards, it is important to act now to meet the new standards.
This is an opportunity for airports to make sure their state's SIP includes accurate emissions forecasts for the airport. Airports should conduct a complete emissions inventory, analyze the inventory, and prepare compliance assessments and plan for the compliance deadlines.
Most importantly, airports should become actively involved in their state's SIP process. Airport officials should consider participating in all workshops and hearings on new rules, which will provide the chance to evaluate proposals and recommend improvements, and work with state regulators to have current and forecasted airport emissions inventories included in the SIP. Airports should take advantage of grants and incentive programs to develop facilities, obtain equipment, and implement strategies that reduce air emissions. Where possible, airports should work with local regulators to develop a program allowing the banking of emission reduction credits to offset future development; and make community and regulators aware of these reductions.
John R. Pehrson, P.E., CDM principal air quality engineer, specializes in dispersion modeling for air quality, regulatory compliance, acquisitions, and permitting.