Presented to: By: Date: Federal Aviation Administration Environmental Best Practices Air Quality Issues 2010 Hershey Conference Maria Stanco, AEA Environmental Program Manager March 3, 2010

2 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 2 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

3 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 3 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

4 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 4 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)

5 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 5 NEPA vs. General Conformity Analysis NEPAGeneral Conformity All Airports (where there’s a Federal action) Airports in nonattainment and maintenance areas All criteria pollutantsEmphasis on criteria pollutants causing violations All Reasonable AlternativesProposed action/No action De minimis thresholds Activity Level ThresholdsCAA exemptions and FAA Presumed to Conform

6 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 6 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

7 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 7 Airport Activity Threshold for “NAAQS Assessment” General Aviation & Air Taxi Operations (000) Million Annual Passengers (MAP) THRESHOLD Source: Air Quality Handbook, Figure 4, p. 20

8 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 8 Construction Emissions Considered “direct” project emissions EDMS has no built-in methodology Recommended EPA tools –NONROAD model

9 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 9 General Conformity Process - No new violations - No increase in the frequency or 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 Actions don’t interfere with SIPs Federal Action

Presented to: By: Date: Federal Aviation Administration Ozone CO PM 10 PM 2.5 AEA Commercial Service Airports Nonattainment and Maintenance Status Source: VALE website

11 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 11 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

12 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 12 1.Pavement Markings 2.Pavement Monitoring Systems 3.Non-Runway Pavement Work 4.Aircraft Gate Areas on Airside 5.Lighting Systems 6.Terminal and Concourse Upgrades 7.New HVAC Systems, Upgrades, and Expansions 8.Airport Security 9.Airport Safety 10.Airport Maintenance Facilities 11.Airport Signage 12.Commercial Vehicle Staging Areas 13.Low Emission Technology and Alternative Fuel Vehicles 14.Air Traffic Control Activities and Procedures 15.Routine Installation and Operation of NAVAIDS PTC Project Categories Items in blue have quantitative or “indexed” ranges

13 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 13 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.

14 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 14 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

15 Federal Aviation Administration 2010 Hershey Conference Maria Stanco 15 Be Aware New ozone nonattainment standards – may change classifications – lower threshold levels HAPS analysis Guidance Sept 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