Aviation and the Environment
Initial Voluntary Airport Low Emissions Program Projects Reduce Emissions, and FAA Plans to Assess the Program's Overall Performance as Participation Increases Gao ID: GAO-09-37 November 7, 2008In 2003, Congress established a program to reduce airport ground emissions at commercial service airports in areas failing to meet or maintain air quality standards. The Federal Aviation Administration (FAA) administers the Voluntary Airport Low Emissions (VALE) Program and oversees the program's two sources of funding: Airport Improvement Program (AIP) federal grants or Passenger Facility Charges (PFC), which airports can collect from passengers. Participating airports also receive credits for the emission reductions achieved through VALE projects in accordance with the law and guidance. Airports can use these credits to offset emissions resulting from development projects to comply with federal Clean Air Act requirements. GAO was asked to determine (1) how the VALE program has been implemented, including airport participation levels, types of projects, and program expenditures, and (2) the outcomes attributable to the VALE program. To do this, GAO reviewed FAA data on VALE projects for all nine participating airports; visited two of these airports; obtained information from the remaining seven participating airports and four nonparticipating airports; and interviewed officials from FAA, Environmental Protection Agency (EPA), and airport associations. FAA generally agreed with the report's findings, and FAA and EPA offered technical clarifications.
While the number of airports that have undertaken VALE projects is relatively small compared with the number of eligible airports, the number of participants in the program is increasing, as are the range and scope of projects being conducted and the amount of money spent on them. As of September 2008, 9 of the 160 airports that were eligible had or were planning to initiate a VALE project, which is up from 2 participating airports in VALE's initial year of operation in 2005. FAA expects participation in VALE to increase as more airports become familiar with the program. Although FAA may be correct in its assumption about participation, officials GAO interviewed from 4 nonparticipating airports, and others, such as representatives of airport associations, indicated various reasons for airports not wanting to participate in the program, which is funded through the same sources of funds--AIP grants or PFCs--as other airport development projects. One reason is that some airports have a misperception that VALE projects compete with other projects, such as runways or terminals, for AIP funding. According to FAA officials, this is usually not the case because VALE projects are funded through a discretionary AIP set-aside for noise and emission projects. FAA officials want to increase FAA's outreach to airports regarding VALE, but noted that the regional staff who are responsible for outreach have limited time for this purpose. VALE projects have ranged from airports' purchase of fuel-efficient vehicles to projects that help decrease aircraft ground emissions. Expenditures for the VALE program have been nearly $20 million for 20 projects through fiscal year 2008 (with 56 percent of these expenditures occurring in fiscal year 2008). All participating airports have used AIP grants to fund VALE projects for various reasons, mainly because their PFCs have already been committed for high-priority, large-scale terminal improvement projects that may not be eligible for any type of AIP grants. FAA has yet to assess the outcomes and overall performance of the VALE program. However, VALE projects are expected to reduce emissions at participating airports, and two airports have taken advantage of the program to obtain emission credits for planned construction projects. According to FAA data, the VALE projects initiated to date will reduce emissions of such pollutants as nitrogen oxide and carbon monoxide by over 5,700 tons estimated over the projects' lifetime, which range from 10 to 40 years. According to FAA, the emission reductions resulting from VALE projects, although large in some cases, such as equipping gates with electricity and air conditioning outlets for aircraft, represent a small fraction of total emissions at participating airports. FAA plans to assess the overall performance of the VALE program as participation increases. FAA officials have begun developing cost-effectiveness measures, such as the amount of emission reductions per dollar spent. FAA officials stated that based on the number and size of VALE projects funded to date, they believe more history and experience with the program is needed before the agency develops other performance measures, such as setting goals for the number of VALE projects
GAO-09-37, Aviation and the Environment: Initial Voluntary Airport Low Emissions Program Projects Reduce Emissions, and FAA Plans to Assess the Program's Overall Performance as Participation Increases
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
November 2008:
Aviation and the Environment:
Initial Voluntary Airport Low Emissions Program Projects Reduce
Emissions, and FAA Plans to Assess the Program's Overall Performance as
Participation Increases:
Aviation and the Environment:
GAO-09-37:
GAO Highlights:
Highlights of GAO-09-37, a report to congressional committees.
Why GAO Did This Study:
In 2003, Congress established a program to reduce airport ground
emissions at commercial service airports in areas failing to meet or
maintain air quality standards. The Federal Aviation Administration
(FAA) administers the Voluntary Airport Low Emissions (VALE) Program
and oversees the program‘s two sources of funding: Airport Improvement
Program (AIP) federal grants or Passenger Facility Charges (PFC), which
airports can collect from passengers. Participating airports also
receive credits for the emission reductions achieved through VALE
projects in accordance with the law and guidance.
Airports can use these credits to offset emissions resulting from
development projects to comply with federal Clean Air Act requirements.
GAO was asked to determine (1) how the VALE program has been
implemented, including airport participation levels, types of projects,
and program expenditures, and (2) the outcomes attributable to the VALE
program. To do this, GAO reviewed FAA data on VALE projects for all
nine participating airports; visited two of these airports; obtained
information from the remaining seven participating airports and four
nonparticipating airports; and interviewed officials from FAA,
Environmental Protection Agency (EPA), and airport associations.
FAA generally agreed with the report‘s findings, and FAA and EPA
offered technical clarifications.
What GAO Found:
While the number of airports that have undertaken VALE projects is
relatively small compared with the number of eligible airports, the
number of participants in the program is increasing, as are the range
and scope of projects being conducted and the amount of money spent on
them. As of September 2008, 9 of the 160 airports that were eligible
had or were planning to initiate a VALE project, which is up from 2
participating airports in VALE‘s initial year of operation in 2005.
FAA expects participation in VALE to increase as more airports become
familiar with the program. Although FAA may be correct in its
assumption about participation, officials GAO interviewed from 4
nonparticipating airports, and others, such as representatives of
airport associations, indicated various reasons for airports not
wanting to participate in the program, which is funded through the same
sources of funds”AIP grants or PFCs”as other airport development
projects. One reason is that some airports have a misperception that
VALE projects compete with other projects, such as runways or
terminals, for AIP funding. According to FAA officials, this is usually
not the case because VALE projects are funded through a discretionary
AIP set-aside for noise and emission projects. FAA officials want to
increase FAA‘s outreach to airports regarding VALE, but noted that the
regional staff who are responsible for outreach have limited time for
this purpose. VALE projects have ranged from airports‘ purchase of fuel-
efficient vehicles to projects that help decrease aircraft ground
emissions. Expenditures for the VALE program have been nearly $20
million for 20 projects through fiscal year 2008 (with 56 percent of
these expenditures occurring in fiscal year 2008). All participating
airports have used AIP grants to fund VALE projects for various
reasons, mainly because their PFCs have already been committed for high-
priority, large-scale terminal improvement projects that may not be
eligible for any type of AIP grants.
FAA has yet to assess the outcomes and overall performance of the VALE
program. However, VALE projects are expected to reduce emissions at
participating airports, and two airports have taken advantage of the
program to obtain emission credits for planned construction projects.
According to FAA data, the VALE projects initiated to date will reduce
emissions of such pollutants as nitrogen oxide and carbon monoxide by
over 5,700 tons estimated over the projects‘ lifetime, which range from
10 to 40 years. According to FAA, the emission reductions resulting
from VALE projects, although large in some cases, such as equipping
gates with electricity and air conditioning outlets for aircraft,
represent a small fraction of total emissions at participating
airports. FAA plans to assess the overall performance of the VALE
program as participation increases. FAA officials have begun developing
cost-effectiveness measures, such as the amount of emission reductions
per dollar spent. FAA officials stated that based on the number and
size of VALE projects funded to date, they believe more history and
experience with the program is needed before the agency develops other
performance measures, such as setting goals for the number of VALE
projects.
What GAO Recommends:
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-09-37]. For more
information, contact Gerald Dillingham at (202) 512-2834 or
dillinghamg@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
A Small Number of Eligible Airports Have Used VALE Funding to Help
Reduce Airport Emissions, but Participation in the Program Is
Increasing:
While VALE Projects Reduce Emissions, FAA Plans to Assess the Program's
Overall Performance as Participation Increases, and Two Airports Have
Used Emissions Credits:
Agency Comments and Our Evaluation:
Appendix I: Airports GAO Contacted with and without VALE Projects:
Appendix II: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: VALE Project Summary, Fiscal Years 2005-2008:
Table 2: VALE Project Expenditures Summary, Fiscal Years 2005-2008:
Table 3: VALE Projects' Estimated Emission Reductions Summary:
Figures:
Figure 1: Airports That Participate in the VALE Program:
Figure 2: Gate Power and Preconditioned Air Reduce Auxiliary Power Unit
(APU) Use and Emissions:
Figure 3: Examples of Alternative Fuel Vehicles:
Abbreviations:
ACI-NA: Airport Council International, North America:
AERC: Airport Emission Reduction Credit:
AIP: Airport Improvement Program:
CAA: Clean Air Act:
EPA: Environmental Protection Agency:
FAA: Federal Aviation Administration:
PFC: Passenger Facility Charges:
SIP: State Implementation Plan:
VALE: Voluntary Airport Low Emissions:
United States Government Accountability Office:
Washington, DC 20548:
November 7, 2008:
The Honorable Jerry Costello:
Chairman:
The Honorable Thomas Petri:
Ranking Member:
Subcommittee on Aviation:
Committee on Transportation and Infrastructure:
House of Representatives:
The Honorable Mark Udall:
Chairman:
The Honorable Tom Feeney:
Ranking Member:
Subcommittee on Space and Aeronautics:
Committee on Science and Technology:
House of Representatives:
Concerns about the environmental effects of aviation have increasingly
focused on emissions from airport operations--including emissions from
aircraft; the ground equipment that services aircraft; and the vehicles
that transport passengers to, from, and within airport grounds.
According to the Environmental Protection Agency (EPA), aviation
activities result in the emission of pollutants that account for less
than 1 percent[Footnote 1] of the total local air pollution in the
United States, but the contribution of these pollutants in areas
surrounding airports can be much larger. Also, aviation-related
pollutants such as nitrogen oxide, which contributes to ozone
formation, are expected to increase based on forecasted growth in the
aviation sector. Better scientific understanding of the potential
health effects of certain aviation emissions and the contribution of
aviation emissions, such as carbon dioxide, to climate change have also
intensified concerns about the overall impact of aviation emissions. As
communities have gained more awareness of the health and environmental
effects of aviation emissions, opposition to airport expansion
projects, which has thus far focused primarily on aviation noise, has
broadened to include emissions. In addition, airport expansion
projects, which can result in increased emissions, must comply with
federal Clean Air Act (CAA) requirements.[Footnote 2] Expanding airport
capacity will be necessary to accommodate both the predicted increases
in air traffic envisioned for the coming decades and the development of
the Next Generation Air Transportation System, which is intended to
handle those increases. Addressing the effects of airport ground
emissions and other types of aviation emissions is expected to be a
major challenge to aviation growth in the coming decades.
To provide financial assistance for airports seeking to reduce airport
ground emissions, Congress established a voluntary program in 2003 to
reduce such emissions at commercial service airports located in areas
failing to meet or maintain EPA ambient air quality standards. To
administer this program, the Federal Aviation Administration (FAA),
which is responsible for managing and overseeing the nation's air
transportation system, created the Voluntary Airport Low Emissions
(VALE) Program in 2004. Airports eligible for the VALE program can fund
low-emission projects through two sources of funds administered by FAA,
the Airport Improvement Program (AIP), which is a federal grant program
for the planning and development of public use airports, and Passenger
Facility Charges (PFC), which airports can collect from passengers to
use for eligible airport development projects.[Footnote 3] According to
FAA, many airport low-emission projects, including low-emission
vehicles, were formerly not eligible for AIP or PFC funding. In
addition, airports can receive credits for the emission reductions
achieved through VALE projects and can use these credits to offset
emissions that result from other airport development projects.[Footnote
4] In this way, VALE is designed to provide a method for airports to
continue expanding or improving but still comply with federal CAA
requirements.
You requested that we evaluate FAA's implementation of the VALE
program. Specifically, we addressed the following questions: (1) How
has the VALE program been implemented, including airport participation
levels, types of projects, and program expenditures? (2) What have been
the outcomes attributable to the VALE program?
To address these questions, we analyzed FAA and airport information on
VALE projects, including types of projects, expenditures, and estimated
outcomes in terms of reducing pollution. We also reviewed and
synthesized relevant literature and our body of work on airport-related
emissions. We visited two of the nine airports participating in the
VALE program (these nine airports have VALE projects that are in
operation or under development). At these two airports, we observed the
VALE projects and interviewed airport officials. We chose these two
airports because their projects are relatively large and account for
over half of the total expenditures for the VALE program. Also, we
interviewed via telephone airport officials at another three
participating airports and obtained written responses to our interview
questions from the remaining two participating airports.[Footnote 5] In
addition, we visited or interviewed via telephone airport officials at
four eligible airports that have not participated in the VALE program.
We selected these nonparticipating airports on the basis of their size,
including large and medium commercial service airports, and geographic
location. See appendix I for a list of the airports that we contacted
or visited. We also interviewed officials from FAA, EPA, and selected
airport associations representing major airports in the United States.
Lastly, we met with air quality officials from Pennsylvania to discuss
the state's role in granting airport emission reduction credits (AERCs)
under the VALE program. We conducted our work from June 2008 through
November 2008.
Results in Brief:
FAA implemented the VALE program in 2004, and while the number of
airports that have undertaken VALE projects is relatively small
compared with the number of eligible airports, the number of
participants in the program is increasing, as is the range and scope of
projects being conducted and the amount of money spent on them. As of
September 2008, 9 of the 160 eligible airports have initiated a VALE
project, which is up from 2 participating airports in VALE in fiscal
year 2005. FAA expects participation in VALE to increase as more
airports become familiar with the program. Although FAA may be correct
in its assumption about future participation, officials we interviewed
from 4 airports that do not have VALE projects and representatives of
airport associations indicated various reasons for not wanting to
participate in the program, which is funded through the same sources of
funds--AIP grants or PFCs--as other airport development projects. One
reason is that some airports have a misperception that VALE projects
compete with other projects, such as runways or terminals, for AIP
funding. According to FAA officials, this is usually not the case
because VALE projects are funded through a discretionary AIP set-aside
for noise and emission projects. FAA officials want to increase FAA's
outreach to airports in regards to VALE, but noted that the regional
staff who are responsible for outreach have limited time for this
purpose. VALE projects have ranged from airports' purchase of fuel-
efficient vehicles to projects that help decrease aircraft ground
emissions. Expenditures for the VALE program, including VALE grants and
the airports' share of project funding, have been nearly $20 million
for 20 projects through fiscal year 2008 (with 56 percent of these
expenditures occurring in fiscal year 2008). All participating airports
have used only AIP grants to fund VALE projects for various reasons,
mainly because their PFC funds have already been committed for high-
priority, large scale terminal improvement projects that may not be
eligible for any type of AIP grants.
FAA has yet to assess the overall performance of the VALE program.
However, VALE projects are helping to reduce emissions at participating
airports, and two airports have taken advantage of the program to
secure emission credits for planned construction projects. According to
FAA data, the VALE projects initiated to date will reduce emissions of
such pollutants as nitrogen oxide and carbon monoxide by over 5,700
tons estimated over the projects' lifetime, which ranges from 10 years
for vehicle projects to 40 years for some infrastructure projects.
According to FAA, the emission reductions resulting from VALE projects,
while significant in some cases, represent a small fraction of total
emissions at participating airports. Some projects, such as equipping
gates with electricity and air conditioning outlets for aircraft,
result in more reductions than other projects, such as purchasing
hybrid vehicles. FAA plans to assess the overall performance of the
VALE program in reducing emissions across airport activities as
participation in the program increases. FAA officials have begun
measuring the performance of projects in reducing emissions and are
developing cost-effectiveness measures, such as the amount of emission
reductions per dollar spent. FAA officials stated that based on the
number and size of VALE projects funded to date, they believe more
history and experience with the program is needed before the agency
develops other performance measures, such as setting goals for the
number of VALE projects implemented and the amount of reductions
achieved through these projects.
We provided copies of a draft of this report to EPA and the Department
of Transportation for review and comment. EPA and FAA both provided
several clarifying comments and technical corrections, which we have
incorporated in this report as appropriate. We also received comments
from officials in FAA's Office of Airport Planning and Programming,
including the National Resource Advisor, Noise and Air Quality, who is
responsible for managing the VALE program. FAA generally agreed with
the report's findings. The FAA representatives, however, stated that
the draft suggested that FAA was not aware of the performance of the
VALE program, and that tracking program benefits and performance is one
of VALE's strongest attributes. We modified the report to more clearly
reflect that FAA is developing a methodology to assess VALE's cost-
effectiveness and plans to develop other measurable performance
objectives, but that FAA has yet to assess the overall performance of
the VALE program. The representatives also stated that while the report
covers the various elements of the VALE program, they also wanted to
emphasize the "innovativeness" of the program. These officials provided
information on what they considered to be the innovative elements of
the program, which we have incorporated in this report as appropriate.
Background:
Although aviation-related activities produce a small amount of the
total air pollution in the United States, according to EPA, the types
of pollutants emitted by these activities are among the most prevalent
and harmful in the atmosphere and are expected to increase based on the
forecasted growth in the aviation sector. The major sources of
emissions at airports are aircraft, the ground equipment (such as
vehicles that transport baggage) that services the aircraft,[Footnote
6] and vehicles transporting passengers to and from the airport. The
emissions produced by these sources include carbon monoxide; toxic
substances (such as benzene and formaldehyde); particulate
matter;[Footnote 7] sulfur dioxide; and nitrogen oxides and volatile
organic compounds, which contribute to the formation of ozone, a major
pollutant in many metropolitan areas and a major concern to many
airport operators and to state and local air quality authorities. In
addition, the potential health effects of particulate matter are
becoming an increasing concern of these groups.
In response to concerns about emissions from airport sources, the
Vision 100--Century of Aviation Reauthorization Act (Vision 100),
signed into law in December 2003,[Footnote 8] established a voluntary
program to reduce airport ground emissions at commercial service
airports in air quality nonattainment and maintenance areas. Geographic
areas that have levels of a criteria pollutant[Footnote 9] above those
allowed by the standard are called nonattainment areas. Areas that did
not meet the standard for a criteria pollutant in the past but have
reached attainment and meet certain procedural requirements are known
as maintenance areas. The program, according to FAA, is intended to
help airports meet their obligations under the CAA, and to assist
regional efforts to meet National Ambient Air Quality Standards set by
EPA for limiting the amount of the six criteria pollutants considered
harmful to public health and the environment. States that have areas
exceeding these standards are required to develop and implement a plan,
known as a State Implementation Plan (SIP),[Footnote 10] for bringing
the areas into compliance with the standards.[Footnote 11] Under the
CAA conformity provision,[Footnote 12] no federal agency may approve or
provide financial assistance for any activity that does not conform to
an applicable SIP.
To implement the Vision 100 provisions relating to airport emission
reductions, FAA created and began implementing the VALE program in
2004. According to FAA, in the 9-month period between the passage of
the act in 2003 and the implementation of the VALE program, the agency-
-in cooperation with EPA and the Department of Energy--developed
program guidelines and application procedures; technical requirements,
such as standards for low-emission vehicles; and a system for assigning
credits to airports for emission reductions.
The FAA relied on experience with the FAA Inherently Low Emission
Airport Vehicle (ILEAV) Pilot Program to design the VALE program.
Authorized under the Wendell H. Ford Aviation Investment and Reform Act
for the 21st Century (AIR-21), the ILEAV pilot program operated from
2001 to 2005. Six airports implemented ILEAV projects with individual
grants of up to $2 million each to demonstrate the benefits and
economic feasibility of low-emission vehicles and supporting
infrastructure.[Footnote 13] According to FAA, the pilot program
projects also provided useful information about the environmental and
economic trade-offs of alternative fuels, their safe handling, and the
commercial availability of low-emission technology.
Airports eligible for the VALE program can apply for federal AIP
entitlement funds or discretionary funds under the "set-aside" for
noise and air quality projects.[Footnote 14] With FAA approval,
eligible airports may also use their PFCs to finance VALE projects.
According to FAA officials, VALE grants using discretionary set-aside
funds have no impact on the amount of entitlement funds an airport
receives through AIP, since AIP entitlements are based on a legislated
apportionment formula tied to the number of passengers an airport
enplanes. FAA officials stated that most participating airports seek
set-aside funding for VALE projects because VALE projects only compete
in this portion of the AIP budget against noise reduction projects.
According to FAA officials, the agency considers the approval and
funding of VALE projects on a case-by-case basis based on the project's
relative importance to other eligible airport activities. FAA officials
stated that prior to the establishment of VALE, the only emission-
reduction projects eligible for AIP grants and PFC use were those
intended to reduce emissions as a condition of approval of an
environmental action associated with an AIP-funded airport development
project. These officials also noted that the VALE program expands AIP
and PFC eligibility into new areas, such as airport mobile sources,
including vehicles.
VALE projects may be stand-alone projects (i.e., they do not have to be
linked to a project that could increase emissions to be eligible for
program funding); however, for a project to be approved, it must meet
specific criteria. For example, an airport must demonstrate that the
project will result in emission reductions. Although according to FAA
officials, these reductions are "surplus" in the sense that they are
not required in the SIP for meeting CAA standards. To demonstrate that
a project will lower emissions, an airport must prepare estimates
comparing the amount of emissions currently produced with the amount of
emissions that will be produced after the project is implemented. To
prepare these emission estimates, airports use FAA's Emissions and
Dispersion Modeling System (EDMS), which calculates emissions from
project-related airport sources,[Footnote 15] such as aircraft, ground
service equipment, and shuttle buses. The airport must also
demonstrate, among other things, that the VALE project will result in
permanent emission reductions.[Footnote 16] According to FAA officials,
using the EDMS air quality model ensures the reliability of emission-
reduction estimates and reduces planning costs.
VALE's authorizing legislation and implementing guidance greatly
expanded AIP and PFC eligibility for low-emission technology, including
the purchase of low-emitting hybrid vehicles and electric-powered
equipment used to service aircraft, such as baggage tugs. FAA officials
stated that VALE employs an innovative approach by converting EPA
average national fleet standards into low-emission standards for each
VALE vehicle purchase. All vehicles and engines that are eligible for
AIP or PFC funding under the VALE program must either be EPA certified
(new vehicles) or EPA verified (retrofit technology). VALE low-emission
standards for all new vehicles are based on EPA average national fleet
standards and are referenced, in some cases, to comparable California
Air Resources Board standards. The VALE program sets emission standards
at cleaner levels than presently required by EPA. According to FAA
officials, a goal of the VALE program is to encourage airports to make
investments in capital equipment to provide substantial emission-
reduction benefits over many years. The VALE program is also intended
to support U.S. energy independence by emphasizing domestically
produced alternative fuels that are substantially nonpetroleum based.
Also, the program is designed to provide airports with financial and
regulatory incentives to increase their investments in proven low-
emission technologies. FAA officials stated that FAA, EPA, and the
Department of Energy coordinate on an ongoing basis VALE program
standards, including nonattainment status for airport eligibility and
eligible alternative fuels.
The legislation authorizing the VALE program also provides a means for
airports to receive credits for the emission reductions achieved
through VALE projects and use these credits to comply with federal CAA
air quality standards. Before the VALE program was instituted, airports
could not receive credit for voluntary emission reductions. Therefore,
any voluntary reductions lowered an airport's emission baseline, which
is used to calculate the impact of future emissions, and thus airports
would need to find further emission reduction options to obtain
approval for future projects.[Footnote 17] In 2003, we reported that
because of this situation, some airport officials told us that they
waited to initiate emission-reduction efforts until these efforts were
needed to gain approval for an expansion project.[Footnote 18] The EPA
issued national guidance in September 2004 on how airports can receive
airport emission-reduction credits (AERC) for VALE projects and apply
those credits to future airport projects to meet certain CAA
requirements. AERCs can be used to mitigate future airport project
emissions, as long as they will be earned in the year for which they
will be applied. To be approved for the VALE program, an airport must
obtain a commitment from the state's air quality authority that it will
approve the use of AERCs for projects to conform to federal air quality
requirements, should the airport choose to use them for this purpose.
A Small Number of Eligible Airports Have Used VALE Funding to Help
Reduce Airport Emissions, but Participation in the Program Is
Increasing:
While the number of airports that have undertaken VALE projects since
2004 is relatively small compared with the number of eligible
commercial airports--9 of 160--the number of participants is
increasing, as are the range of projects being conducted and the amount
of money spent on them.
Few Eligible Airports Have Initiated VALE Projects, but FAA Expects
Participation to Increase:
Participation in the VALE program has been limited to date, although
the number of airports applying for the program is increasing, and FAA
expects more airports to seek VALE funding as they become more familiar
with the program. About 160 of the 524 commercial service airports are
eligible to participate in the VALE program; however, as of September
2008, 9 airports had received VALE program funding. (Fig. 1 shows the
locations of airports participating in VALE.) According to FAA
officials, all airports that have applied to participate in VALE have
been approved.
Figure 1: Airports That Participate in the VALE Program:
This figure is a map of the airports that participate in the VALE
program.
[See PDF for image]
Source: FAA data and Map Resources.
[End of figure]
Participation in the VALE program has risen in recent years. For
example, in 2005, the first year of the program, FAA approved VALE
projects for 2 airports. In fiscal year 2008, FAA approved 11 projects
at 6 airports, 4 of which were new participants in the program.
Overall, FAA reports that a total of 20 projects at 9 participating
airports are under way. In fiscal year 2009, FAA expects additional
VALE participants. For example, the Seattle-Tacoma International
Airport has proposed a multiyear project to purchase electric ground
support equipment, with a $3.1 million first phase beginning in fiscal
year 2009. FAA officials stated that FAA regional officials are
considering the airport's application to fund this project through
VALE.
FAA officials stated that as the VALE program matures, and concerns
about foreign oil, climate change, and fuel prices influence public
policy, airport participation in the VALE program is expected to grow.
These officials noted that they expect VALE applications to increase as
airports learn more about the program and about projects initiated at
other airports, and that numerous airports throughout the country have
recently expressed their interest in the program. FAA points to the
Part 150 Noise Compatibility Program as an example of an airport
environmental program that grew gradually. The Part 150 program
provides guidance to airports on the types of land use that are
incompatible with certain levels of airport noise and encourages
airports to develop a noise compatibility plan to reduce and prevent
such uses. Airports that develop such plans can receive AIP noise set-
aside funds, which, among other things, can be used to (1) soundproof
residences and public buildings, such as schools, and (2) support
relocation by acquiring homes in areas that experience significant
noise exposure. When the Part 150 program was initiated in the early
1980s, only a few of the approximately 3,000 eligible airports
completed compatibility plans and applied for AIP grants. However, the
program has grown over the years and, as of fiscal year 2007, nearly
300 airports have participated. According to FAA officials, the growth
of the VALE program in its first 4 years of existence has outpaced that
of the Part 150 program during its initial 4 years, particularly
considering that far fewer airports are eligible for VALE than for the
Part 150 program.
FAA officials responsible for the VALE program have conducted outreach
to eligible airports in a number of ways, but these officials believe
that more outreach is needed. FAA's VALE outreach efforts include
making presentations at conferences attended by airport executives and
working with airport associations--including Airport Council
International, North America (ACI-NA), and the American Association of
Airport Executives--to disseminate information about the program to
eligible airports. FAA has also provided guidance to FAA regional staff
on the program and encourages these staff to contact airports in their
region about VALE. However, FAA officials noted that few regional staff
are available to work on VALE outreach, and that more resources to
administer the program and provide technical assistance to airports
could increase participation. FAA officials noted several instances
where airports learned about VALE too late in the process of planning
expansion projects to fully take advantage of assistance offered
through the program. For example, Detroit Metropolitan Wayne County
Airport began installing its fuel hydrant system before its VALE grant
was issued to meet its project deadline; therefore, only part of the
system was covered by a VALE grant. Officials at this airport noted
that had they known about VALE earlier, they could have submitted their
application in time to use VALE funding for the entire project.
Although FAA may be correct in its assumption that VALE will follow the
Part 150 program's experience of participation levels gradually
increasing as the program matures, we found several reasons that
airports are not currently participating in VALE.
* Officials at all four of the nonparticipating airports we contacted
stated that VALE emission-reduction projects currently are not a high-
priority use of AIP funds when compared with airport expansion or
improvement efforts. For example, these officials stated that they
prefer to use AIP funds for higher-priority safety and airport
efficiency and capacity improvement efforts. However, these officials
noted that reducing emissions is important for addressing community air
quality concerns. In addition, officials at two nonparticipating
airports, as well as an official at one airport that has been approved
for a VALE project, said that it was their understanding that VALE
projects compete for AIP funds with all AIP-eligible projects.
Consequently, the two nonparticipating airports chose not to pursue
VALE projects and the participating airport has limited the scale of
its VALE project to use AIP funds for high-priority projects. FAA
officials stated that these airports have a misperception of VALE AIP
grants in that VALE projects do not compete with most other types of
AIP-eligible projects at airports, because VALE projects are funded
through a 35 percent set aside earmarked for noise-abatement and
emission-reduction projects. Therefore, VALE AIP grants have no effect
on an airport's eligibility for other types of AIP grants.
* ACI-NA officials noted that some airports may not be best positioned
to take advantage of the VALE program because they have no relevant
capital projects planned or do not need to replace ground service
equipment, which has up to a 15-year life cycle. Officials from one of
the nonparticipating airports we contacted stated that most of the
airport's facilities and equipment are relatively new and will not need
to be replaced in the near future. Also, officials at the four
nonparticipating airports we contacted stated that they already have
some of the equipment and facilities that are eligible under VALE.
* Officials from one airport noted that their airport lacked the
expertise to conduct the emissions inventory required to establish a
baseline for measuring VALE project emission reductions. FAA officials
noted that airports eligible for VALE, including smaller airports with
less planning resources, typically can be reimbursed by FAA for project
formulation costs, including hiring a contractor to assist in
conducting the emissions inventory and preparing the VALE application,
if the project is approved.
* FAA officials and airport officials noted that some airports have
been reluctant to seek approval for emission-reduction credits from
their state air quality authority, as FAA requires before it will
approve a project. According to these officials, some airports have
little experience in dealing with their state air quality authority
because airport emission reductions previously have not been necessary
as part of the CAA SIP. Officials from one airport we visited stated
that it is their impression that the state air quality authority will
not grant emission-reduction credits for any reason, and, consequently,
the airport had not pursued a VALE grant, even though it is currently
undertaking a terminal and gate expansion project. According to FAA
officials, the guidance that EPA has developed for AERCs provides
instructions to state air quality officials on the process and criteria
for issuing AERCs to airports.
Participating Airports Have Initiated a Range of VALE Projects:
The VALE projects initiated at airports have ranged from purchases of
small numbers of fuel-efficient, low-emitting vehicles[Footnote 19] to
projects that help decrease aircraft ground emissions. Table 1 shows a
summary of the projects at the airports participating in the VALE
program from fiscal years 2005 through 2008.
Table 1: VALE Project Summary, Fiscal Years 2005-2008:
Airport: Erie International/Tom Ridge Field (ERI);
Fiscal year that project was funded: 2008;
Project type: 3 preconditioned air units at 3 gates.
Airport: Westchester County (HPN);
Fiscal year that project was funded: 2008;
Project type: 25 electric ground support equipment (eGSE) and 13 dual-
port rechargers (9 baggage tugs, 5 belt loaders, 3 pushback tractors, 4
water trucks, and 4 stairs).
Airport: Philadelphia International (PHL);
Fiscal year that project was funded: 2008;
Project type: * 5 dual-port rechargers for 5 gates at Terminal D,
supporting 10 United Airlines eGSE baggage tugs;
* Preconditioned air and electrical system upgrades for 11 gates at
Terminal A East;
* 3 electric hybrid vehicles;
* 15 dual-port rechargers supporting 34 US Airways electric hybrid
vehicles.
Airport: Greater Rochester International (ROC);
Fiscal year that project was funded: 2008;
Project type: 8 compressed natural gas (CNG) shuttle buses and CNG
station.
Airport: George Bush Intercontinental Houston (IAH);
Fiscal year that project was funded: 2008;
Project type: * Expansion of automated people-mover between Terminal A
and other terminals;
* Underground fuel hydrant system for new 30-gate Terminal B;
* Gate power and preconditioned air for new 30-gate Terminal B.
Airport: George Bush Intercontinental Houston (IAH);
Fiscal year that project was funded: 2008;
Project type: 2 eGSE cargo carts;
8 electric hybrid vehicles.
Airport: George Bush Intercontinental Houston (IAH);
Fiscal year that project was funded: 2007;
Project type: 14 electric hybrid vehicles.
Airport: George Bush Intercontinental Houston (IAH);
Fiscal year that project was funded: 2005;
Project type: 9 electric hybrid vehicles.
Airport: William P. Hobby Houston (HOU);
Fiscal year that project was funded: 2008;
Project type: 3 electric hybrid vehicles.
Airport: William P. Hobby Houston (HOU);
Fiscal year that project was funded: 2007;
Project type: Airport: 1 electric hybrid vehicle.
Airport: William P. Hobby Houston (HOU);
Fiscal year that project was funded: 2006;
Project type: 2 electric hybrid vehicles.
Airport: Detroit Metropolitan Wayne County (DTW);
Fiscal year that project was funded: 2007;
Project type: Gate power and preconditioned air, underground fuel
hydrant system for 26-gate new terminal.
Airport: Stewart International (SWF), Newburgh/New Windsor, NY;
Fiscal year that project was funded: 2007;
Project type: Gate electrification and preconditioned air for 7 gates
at main terminal.
Airport: Albany International (ALB);
Fiscal year that project was funded: 2006;
Project type: 6 runway sweeper diesel retrofits using muffler
technology;
Nitrogen oxide-reducing catalysts and particulate filters (GSE pilot);
(Note: project modification is pending).
Airport: Albany International (ALB);
Fiscal year that project was funded: 2005;
Project type: 2 CNG shuttle buses and CNG refueling station upgrade.
Source: FAA data.
[End of table]
Detroit Metropolitan Wayne County Airport has used VALE funding to
install systems to supply electricity and air conditioning to aircraft
from gates at a new terminal that opened in September 2008, eliminating
the need for aircraft to run their auxiliary engines to power and cool
aircraft while loading and unloading passengers, thereby reducing
emissions (see fig. 2). The airport has also partially relied on VALE
funding to install an underground fuel hydrant system for refueling
aircraft, which reduces emissions by eliminating the need to truck fuel
to the aircraft.
Figure 2: Gate Power and Preconditioned Air Reduce Auxiliary Power Unit
(APU) Use and Emissions:
This figure is a combination of photographs showing gate power and
preconditioned air reduce auxiliary power unit (APU) use and emissions.
[See PDF for image]
Source: FAA data.
Note: An aircraft's APU is a small engine that is used to supply power
to the cabin when the aircraft's main engines are not in use.
[End of figure]
Several other airports have used the VALE program to purchase low-
emitting vehicles for use at the airport. For example, George Bush
Intercontinental Airport and William P. Hobby Airport, which are both
owned by the city of Houston, have received VALE funding to purchase 37
hybrid cars and sport utility vehicles, and Albany International
Airport has purchased natural gas-powered shuttle buses and other low-
emitting vehicles through VALE (see fig. 3). As table 1 indicates,
George Bush Intercontinental Houston Airport and Philadelphia
International Airport have also used VALE funding to purchase ground
service equipment, such as baggage tugs and power stations to recharge
this equipment.
Figure 3: Examples of Alternative Fuel Vehicles:
This figure is a combination of two pictures of alternative fuel
vehicles.
[See PDF for image]
Source: FAA.
[End of figure]
The scope of VALE projects at airports has also been increasing. For
example, in fiscal year 2008, Philadelphia International Airport
received FAA approval for a $3.4 million VALE grant for electric tugs
that transport baggage, systems for supplying electricity and air
conditioning to aircraft at gates, and hybrid vehicles. FAA officials
noted that this is the first VALE project with airline participation.
United Airlines has agreed to keep 10 of its electric baggage tugs at
the airport for their entire useful life[Footnote 20] in exchange for
the airport agreeing to purchase a recharging station for the tugs
through VALE. Similarly, US Airways agreed to purchase 34 new electric
ground support vehicles for use at Philadelphia International. For this
project, US Airways obtained a grant from Pennsylvania through the
state's Alternative Fuels Incentive Program[Footnote 21] to fund part
of the purchase of the tugs. George Bush Intercontinental Houston
Airport, which previously used VALE to purchase hybrid vehicles,
increased its participation in the VALE program to include funding the
expansion of its people-mover system and other projects.
Expenditures for the VALE Program Are Increasing:
Expenditures for the VALE program have increased significantly as the
program has matured. In fiscal years 2005 and 2006, VALE funding for
projects totaled less than $400,000, but has increased to nearly $20
million for projects funded through fiscal year 2008, including the
airports' required share for AIP-funded projects.[Footnote 22] About 56
percent of these expenditures occurred in fiscal year 2008. Table 2
indicates that most of the VALE funding came from the AIP program. To
date, no airports have applied PFC funds to VALE projects. Officials at
Philadelphia International Airport had initially intended to use PFC
funds to meet its required 25 percent share for its VALE grant, but
later decided to rely on other funding sources for this share.
According to FAA officials and officials of the seven participating
airports we contacted, because there is more flexibility in using PFC
funds for airport projects than in using AIP funds,[Footnote 23]
participating airports use AIP funds for VALE projects and apply PFCs
to other types of projects, such as terminal improvement projects, that
may not be eligible for any type of AIP grants. In addition, these
participating airport officials, as well as FAA officials, said that
VALE projects have to compete with all other priorities for PFC use,
and many PFC priority projects have been set well into the future. For
example, officials at one airport we visited said that the airport
currently collects the maximum $4.50 PFC, and that all PFCs collected
have already been dedicated to capital projects, including building a
new terminal with six additional gates.
Table 2: VALE Project Expenditures Summary, Fiscal Years 2005-2008:
Airport: Erie International/Tom Ridge Field (ERI);
Fiscal year that project was funded: 2008;
AIP expenditure: $313,500;
PFC expenditure: $0;
Airport's share of project funding: $16,500;
Total project expenditures: $330,000.
Airport: Westchester County (HPN);
Fiscal year that project was funded: 2008;
AIP expenditure: 1,032,949;
PFC expenditure: 0;
Airport's share of project funding: 54,366;
Total project expenditures: 1,087,315.
Airport: Philadelphia International (PHL);
Fiscal year that project was funded: 2008;
AIP expenditure: 3,484,301;
PFC expenditure: 0;
Airport's share of project funding: 1,161,433;
Total project expenditures: 4,645,734.
Airport: Greater Rochester International (ROC): 2008;
AIP expenditure: 451,950;
PFC expenditure: 0;
Airport's share of project funding: 150,650;
Total project expenditures: 602,600.
Airport: Greater Rochester International (ROC);
Fiscal year that project was funded: 2008;
AIP expenditure: 1,524,147;
PFC expenditure: 0;
Airport's share of project funding: 80,218;
Total project expenditures: 1,604,365.
Airport: George Bush Intercontinental Houston (IAH);
Fiscal year that project was funded: 2008;
AIP expenditure: 2,133,112;
PFC expenditure: 0;
Airport's share of project funding: 711,037;
Total project expenditures: 2,844,149.
Airport: George Bush Intercontinental Houston (IAH);
Fiscal year that project was funded: 2008;
AIP expenditure: Airport: 30,808;
PFC expenditure: Airport: 0;
Airport's share of project funding: Airport: 10,270;
Total project expenditures: 41,078.
Airport: George Bush Intercontinental Houston (IAH);
Fiscal year that project was funded: 2007;
AIP expenditure: Airport: 51,896;
PFC expenditure: Airport: 0;
Airport's share of project funding: 17,125;
Total project expenditures: 69,021.
Airport: George Bush Intercontinental Houston (IAH);
Fiscal year that project was funded: 2005;
AIP expenditure: 42,655;
PFC expenditure: 0;
Airport's share of project funding: 14,218;
Total project expenditures: 56,873.
Airport: William P. Hobby Houston (HOU);
Fiscal year that project was funded: 2008;
AIP expenditure: 10,779;
PFC expenditure: 0;
Airport's share of project funding: 3,593;
Total project expenditures: 14,372.
Airport: William P. Hobby Houston (HOU);
Fiscal year that project was funded: 2007;
AIP expenditure: 7,905;
PFC expenditure: 0;
Airport's share of project funding: 2,608;
Total project expenditures: 10,513.
Airport: William P. Hobby Houston (HOU);
Fiscal year that project was funded: 2006;
AIP expenditure: 12,557;
PFC expenditure: 0;
Airport's share of project funding: 5,186;
Total project expenditures: 7,743.
Airport: Detroit Metropolitan Wayne County (DTW);
Fiscal year that project was funded: 2007;
AIP expenditure: 5,099,971;
PFC expenditure: 0;
Airport's share of project funding: 1,699,990;
Total project expenditures: 6,799,961.
Airport: Stewart International (SWF), Newburgh/New Windsor, NY;
Fiscal year that project was funded: 2007;
AIP expenditure: 1,053,500;
PFC expenditure: 0;
Airport's share of project funding: 451,500;
Total project expenditures: 1,505,000.
Airport: Albany International (ALB);
Fiscal year that project was funded: 2006;
AIP expenditure: 128,324;
PFC expenditure: 0;
Airport's share of project funding: 6,754;
Total project expenditures: 135,078.
Airport: Albany International (ALB);
Fiscal year that project was funded: 2005;
AIP expenditure: 106,489;
PFC expenditure: 0;
Airport's share of project funding: 5,605;
Total project expenditures: 112,094.
Airport: Total;
Fiscal year that project was funded: [Empty];
AIP expenditure: $15,484,843;
PFC expenditure: $0;
Airport's share of project funding: $4,391,053;
Total project expenditures: $19,875,896.
Source: FAA data.
[End of table]
While VALE Projects Reduce Emissions, FAA Plans to Assess the Program's
Overall Performance as Participation Increases, and Two Airports Have
Used Emissions Credits:
VALE projects have reduced emissions at participating airports,
according to FAA officials, and FAA plans to assess the overall
performance of the VALE program in reducing emissions across airport
activities as participation in the program increases. Thus far, two
airports have taken advantage of emission credits available through the
program to offset emissions from planned construction projects.
VALE Projects Reduce Emissions at Participating Airports:
The estimated emissions reductions resulting from VALE projects
initiated at airports vary, depending on the type and scope of the
project. Table 3 shows the estimated reductions in tons of criteria
pollutants, including nitrogen oxides, volatile organic compounds,
carbon monoxide, and particulate matter. Airports use FAA's EDMS, which
calculates emissions produced by aircraft and equipment used at
airports. Airports determine the estimated reductions by comparing the
estimated amount of pollution produced before the project was initiated
with the estimated amount after it was implemented. For example,
officials at George Bush Intercontinental Houston Airport compared the
estimated amount of pollution produced by the airport's conventional
vehicles with the estimated amount of pollution produced by the
replacement hybrid vehicles purchased with VALE funding.
Table 3: VALE Projects' Estimated Emission Reductions Summary:
Reductions in tons.
Airport: Erie International/Tom Ridge Field (ERI);
Estimated project lifetime[A] emission reductions: Nitrogen oxide:
11.1;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 1.0;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
15.2;
Estimated project lifetime[A] emission reductions: Particulate matter:
0.0.
Airport: Westchester County (HPN);
Estimated project lifetime[A] emission reductions: Nitrogen oxide:
33.8;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 16.2;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
656.1;
Estimated project lifetime[A] emission reductions: Particulate matter:
1.7.
Airport: Philadelphia International (PHL);
Estimated project lifetime[A] emission reductions: Nitrogen oxide:
730.7;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 60.0;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
937.8;
Estimated project lifetime[A] emission reductions: Particulate matter:
18.4.
Airport: Greater Rochester International (ROC);
Estimated project lifetime[A] emission reductions: Nitrogen oxide:
248.4;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 33.1;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
835.8;
Estimated project lifetime[A] emission reductions: Particulate matter:
9.1.
Airport: George Bush Intercontinental Houston (IAH);
Estimated project lifetime[A] emission reductions: Nitrogen oxide:
426.5;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 54.2;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
898.2;
Estimated project lifetime[A] emission reductions: Particulate matter:
0.9.
Airport: George Bush Intercontinental Houston (IAH);
Estimated project lifetime[A] emission reductions: Nitrogen oxide: 0.1;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 0.0;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
0.6;
Estimated project lifetime[A] emission reductions: Particulate matter:
0.0.
Airport: George Bush Intercontinental Houston (IAH);
Estimated project lifetime[A] emission reductions: Nitrogen oxide: 1.0;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 0.3;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
5.2;
Estimated project lifetime[A] emission reductions: Particulate matter:
: 0.0.
Airport: George Bush Intercontinental Houston (IAH);
Estimated project lifetime[A] emission reductions: Nitrogen oxide:
William P. Hobby Houston (HOU): 0.4;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: William P. Hobby Houston (HOU): 0.1;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
William P. Hobby Houston (HOU): 1.6;
Estimated project lifetime[A] emission reductions: Particulate matter:
William P. Hobby Houston (HOU): 0.1.
Airport: William P. Hobby Houston (HOU);
Estimated project lifetime[A] emission reductions: Nitrogen oxide: 0.0;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 0.0;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
0.2;
Estimated project lifetime[A] emission reductions: Particulate matter:
0.0.
Airport: William P. Hobby Houston (HOU);
Estimated project lifetime[A] emission reductions: Nitrogen oxide: 0.0;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 0.0;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
0.1;
Estimated project lifetime[A] emission reductions: Particulate matter:
0.0.
Airport: William P. Hobby Houston (HOU);
Estimated project lifetime[A] emission reductions: Nitrogen oxide:
Detroit Metropolitan Wayne County (DTW): 0.0;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: Detroit Metropolitan Wayne County (DTW): 0.0;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
Detroit Metropolitan Wayne County (DTW): 0.1;
Estimated project lifetime[A] emission reductions: Particulate matter:
Detroit Metropolitan Wayne County (DTW): 0.0.
Airport: Detroit Metropolitan Wayne County (DTW);
Estimated project lifetime[A] emission reductions: Nitrogen oxide:
396.6;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 46.5;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
453.5;
Estimated project lifetime[A] emission reductions: Particulate matter:
50.6.
Airport: Stewart International (SWF) Newburgh/New Windsor, NY;
Estimated project lifetime[A] emission reductions: Nitrogen oxide:
38.6;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 3.7;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
40.9;
Estimated project lifetime[A] emission reductions: Particulate matter:
0.9.
Airport: Albany International (ALB);
Estimated project lifetime[A] emission reductions: Nitrogen oxide: 8.4;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 1.2;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
8.2;
Estimated project lifetime[A] emission reductions: Particulate matter:
1.4.
Airport: Albany International (ALB);
Estimated project lifetime[A] emission reductions: Nitrogen oxide:
Total: 3.3;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: Total: 9.5;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
Total: 0.0;
Estimated project lifetime[A] emission reductions: Particulate matter:
Total: 0.0.
Airport: Total;
Estimated project lifetime[A] emission reductions: Nitrogen oxide:
1,898.0;
Estimated project lifetime[A] emission reductions: Volatile organic
compounds: 226.0;
Estimated project lifetime[A] emission reductions: Carbon monoxide:
3,854.0;
Estimated project lifetime[A] emission reductions: Particulate matter:
83.1.
Source: FAA data.
Note: The emission reductions data represent emission reductions from
all VALE projects at each of the airports.
[A] According to FAA, the lifetime duration of projects varies and
ranges from 10 years for some vehicle projects to 40 years for some
infrastructure projects. For these initial VALE projects, the estimated
emission reductions for such pollutants as nitrogen oxide and carbon
monoxide is over 5,700 tons.
[End of table]
According to FAA officials, the emission reductions resulting from VALE
projects, although relatively large in the case of some projects,
represent a small portion of total emissions at the participating
airports. For example, the VALE project at Philadelphia International
Airport is projected to reduce nitrogen oxide emissions by about 1
percent. In addition, some of the VALE projects would have been
undertaken even without VALE funding. For example, according to Detroit
Metropolitan Wayne County Airport officials, the airport would have
used other funding sources to install systems to supply electricity and
air conditioning to aircraft at the gates of its new terminal even if
it had not received an AIP grant through the VALE program for this
purpose. However, airport projects that are not part of the VALE
program may not receive emission credits from their state air quality
agency.
According to FAA officials, the agency has taken steps to ensure that
estimates of emission-reductions from VALE projects are quantified
accurately. These steps include developing and updating emission
standards for airport vehicles eligible for VALE in cooperation with
EPA. FAA also publishes a technical report that contains vehicle
emission standards as well as guidance on how to do the required
emission inventories for proposed VALE projects. In addition, emission
reduction estimates that airports are required to provide are verified
by FAA regions using a formal checklist. The estimates are also checked
by FAA headquarters and by the airport's EPA region and state air
quality agency.
FAA officials are developing a methodology to assess the cost-
effectiveness of VALE projects in reducing emissions and plan to
develop other measurable performance objectives. As part of its
oversight of the VALE program, FAA evaluates the cost-effectiveness of
VALE projects based on a comparison of emission reductions over the
useful life of the project and the total project costs. FAA recognizes
that cost-effectiveness may vary by project type, the way the project
is implemented, and airport size. For example, according to FAA, gate
electrification projects tend to provide the largest emission
reductions and are the most cost-effective, while a project involving a
refueling station tends to yield lower cost-effectiveness. FAA has
developed specific cost-effectiveness measures for gate electrification
projects initiated under VALE based on actual program experience to
date. According to FAA, these projects have reduced ozone and carbon
monoxide at a cost of $7,000 and $6,000 per ton, respectively.[Footnote
24] To further develop its cost-effectiveness methodology, FAA plans to
expand its cost-effectiveness ranges to include other types of VALE
projects. FAA officials stated that based on the number and size of
VALE projects funded to date, they believe more history and experience
with the VALE program is needed before they can develop other
performance measures, such as setting goals for the number of projects
implemented and the amount of reductions achieved through these
projects. Nevertheless, FAA program officials noted that they have set
an informal goal for each of FAA's nine regions to approve at least one
VALE project in fiscal year 2009. An EPA official involved in the
development of the VALE program noted that a future requirement should
be the development of the cost-effectiveness and efficiency measures
for the VALE program to hold airports and the federal government
accountable for results.
As we have previously noted, airports that participate in the VALE
program can apply to their state or local air quality authority to
receive AERCs for emission reductions achieved through the program. To
date, two airports have obtained these credits to help mitigate the
increases in emissions resulting from airport development projects. FAA
officials stated that while most airports that participate in VALE are
mainly interested in receiving VALE funding, some airports also plan to
use emission credits to meet CAA conformity requirements.[Footnote 25]
As of June 2008, William P. Hobby Houston Airport and George Bush
Intercontinental Houston Airport have applied for and received a formal
AERC statement from the Texas Commission on Environmental Quality,
which allows the airports to use their AERCs to mitigate emissions from
airport development projects. For example, Houston Intercontinental
will use AERCs in its environmental impact statement for a terminal
expansion project to help satisfy CAA conformity requirements.
According to FAA, other airports, including Philadelphia International,
are planning to use emission credits to offset emissions from
development projects currently under way. For example, Philadelphia
International Airport plans to use AERCs to satisfy CAA conformity
requirements to offset the emissions produced in the construction of
its ongoing capacity enhancement project, which includes a new airport
runway. Airport officials at Philadelphia International expect that the
state will approve these credits. Officials with whom we spoke from two
airports that have initiated VALE projects but that have not applied
for earned AERCs stated that they currently have no ongoing development
projects, or have not needed the credits for ongoing projects because
the resulting emissions fall within federal standards. In addition, FAA
officials indicated that some airports do not need AERCs for expansion
projects, but are expressing interest in participating in the VALE
program to buy low-emitting equipment partly because such equipment
uses less fuel, and rising fuel prices have put a strain on airport
finances.
Agency Comments and Our Evaluation:
We provided copies of a draft of this report to EPA and the Department
of Transportation for review and comment. EPA and FAA both provided
several clarifying comments and technical corrections, which we have
incorporated in this report as appropriate. We also received comments
from officials in FAA's Office of Airport Planning and Programming,
including the National Resource Advisor, Noise and Air Quality who is
responsible for managing the VALE program. FAA generally agreed with
the report's findings. The FAA representatives, however, stated that
the draft suggested that FAA was not aware of the performance of the
VALE program, and that tracking program benefits and performance is one
of VALE's strongest attributes. We modified the report to more clearly
reflect that FAA is developing a methodology to assess VALE's cost-
effectiveness and plans to develop other measurable performance
objectives, but that FAA has yet to assess the overall performance of
the VALE program. The representatives also stated that while the report
covers the various elements of the VALE program, they also wanted to
emphasize the "innovativeness" of the program. In this regard, they
noted that VALE represents a new model for government efforts to
promote clean fuels and technology. For this reason, they state and we
point out in the report, EPA is recommending in current proposed
revisions to its General Conformity Regulations that the VALE system
for granting emissions credits be expanded to all actions subject to
General Conformity Regulations. The FAA representatives also provided
information on what they regarded as other innovative elements of the
VALE program, which we have incorporated in this report as appropriate.
We are sending copies of this report to interested congressional
committees, the Secretary of Transportation, the FAA Administrator and
the EPA Administrator. We will also make copies available to others on
request. In addition, this report will be available at no charge on the
GAO Web site at [hyperlink, http://www.gao.gov].
If you or your staffs have any questions about this report, please
contact me at (202) 512-2834 or dillinghamg@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. GAO staff who made major contributions
to this report are listed in appendix II.
Signed by:
Gerald L. Dillingham, Ph.D.:
Director, Physical Infrastructure Issues:
[End of section]
Appendix I: Airports GAO Contacted with and without VALE Projects:
Airports with VALE Projects:
Albany International (ALB):
Detroit Metropolitan Wayne County (DTW)[Footnote 26]
George Bush Intercontinental Houston (IAH):
Greater Rochester International (ROC):
Philadelphia International (PHL):
Stewart International (SWF), Newburgh/New Windsor, New York:
William P. Hobby Houston (HOU):
Eligible Airports without VALE Projects:
Chicago O'Hare International (ORD):
Denver International (DEN):
John Wayne Airport-Orange County, California (SNA):
Los Angeles International (LAX):
[End of section]
Appendix II: GAO Contact and Staff Acknowledgments:
GAO Contact:
Gerald L. Dillingham, Ph.D., (202) 512-2834 or dillinghamg@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, individuals making key
contributions to this report include Edward Laughlin (Assistant
Director), Lauren Calhoun, James Geibel, Delwen Jones, Rosa Leung, Josh
Ormond, Stan Stenersen, and Larry Thomas.
[End of section]
Footnotes:
[1] This estimate pertains to aircraft emissions, and it does not
include emissions from other sources at airports, such as vehicles and
equipment that service aircraft. According to EPA, in areas that do not
meet federal Clean Air Act requirements for ozone (which is formed from
nitrogen oxides and volatile organic compounds), aircraft emissions are
estimated to contribute as much as 3 percent of this pollutant.
[2] The Clean Air Act, codified at 42 U.S.C. § 7401 et seq, is a
comprehensive federal response to address air pollution.
[3] Airports can collect PFCs of up to $4.50 for every enplaned
passenger and can use these PFCs to fund FAA-approved projects for
various purposes, such as enhancing safety and security, increasing
capacity and air carrier competition, or decreasing noise or emissions.
PFCs are considered local funds.
[4] EPA, Guidance on Airport Emission Reduction Credits for Early
Measures Through Voluntary Airport Low Emission Programs (Washington,
D.C.: 2004).
[5] For two of the nine airports, FAA provided us with information on
these participating VALE airports.
[6] Such equipment is known generally as ground service equipment.
[7] Particulate matter, also known as particle pollution, is a complex
mixture of extremely small particles and liquid droplets. Particulate
matter is made up of a number of components, including acids (such as
nitrates and sulfates), organic chemicals, metals, and soil or dust
particles.
[8] Pub. L. No. 108-176, 177 Stat. 2490, Sections 121, 151, 158 and
159, December 12, 2003.
[9] The criteria pollutants are carbon monoxide, lead, nitrogen oxide,
sulfur oxides, ozone, and particulate matter. Ozone is formed in the
atmosphere when nitrogen oxides and volatile organic compounds combine
in the atmosphere and are heated by sunlight.
[10] SIPs specify the programs that states will develop to achieve and
maintain compliance with the CAA standard.
[11] States are preempted from adopting or enforcing any standard
respecting aircraft engine emissions unless such a standard is
identical to EPA's standards (see 42 U.S.C. § 7573). This provision
does not preclude all state regulation of the field of aircraft
engines. People of the State of California v. Department of the Navy,
624 F.2d 885, 888 (9TH Cir. 1980). If state pollution measures can be
met without affecting the design, structure, operation, or performance
of the aircraft engine, then the regulations are not preempted. Id.
[12] 42 U.S.C. § 7506(c)(1).
[13] Baltimore-Washington, Baton Rouge, Dallas/Fort Worth, Denver,
Sacramento, and San Francisco airports had active ILEAV projects. Four
airports (Atlanta, Chicago O'Hare, and New York's Kennedy and
LaGuardia) had to ask FAA to terminate their ILEAV grants and to
redistribute the funding to other eligible AIP projects due to economic
considerations after September 11, 2001.
[14] FAA reserves 35 percent of the AIP discretionary budget, which in
fiscal year 2009 will be about $337 million, as a set-aside for airport
noise and air quality improvement efforts.
[15] Project-related airport sources are sources that are directly
related to the airport's VALE project and do not include other or all
airport emission sources.
[16] Emission reductions must be permanent for the life of the project.
Additionally, to be eligible for emission-reduction credits, emission
reductions must be quantifiable, adequately supported, and enforceable.
[17] For example, if an airport were to produce 100 tons of nitrogen
oxides per year and then voluntarily initiated a project that reduced
that amount by 10 tons, the airport's emission baseline would become 90
tons. If an expansion project then resulted in a 10-ton yearly increase
in nitrogen oxides, the airport might have to initiate new mitigation
measures that would compensate for the increase.
[18] GAO, Aviation and the Environment: Strategic Framework Needed to
Address Challenges Posed by Aircraft Emissions, GAO-03-252 (Washington,
D.C.: Feb. 28, 2003).
[19] Low-emitting vehicles purchased primarily use alternative fuel,
such as electric hybrid or natural gas.
[20] Airlines often move the ground support equipment between airports.
[21] The state of Pennsylvania grant program was established in 1992
and is administered by the Department of Environmental Protection's
Office of Pollution Prevention and Compliance Assistance. The program
is intended to help improve the Commonwealth's air quality and reduce
the use of imported oil through the use of alternative fuels.
[22] The federal government's share of AIP grants is 95 percent for
smaller airports and 75 percent for large and medium hub airports.
[23] AIP funding is usually limited to construction or improvements
related to aircraft operations, such as runways or taxiways, whereas
PFCs are considered local revenues; therefore, airports generally have
more flexibility in the use of PFCs than AIP grants. PFCs can be used
in furthering airport development, including preserving or enhancing
airports' safety, security, or capacity; reducing noise; or enhancing
airline competition.
[24] FAA has also developed cost-effectiveness ranges for other
pollutant reductions, including particulate matter ($30,000 per ton)
and sulfur dioxide ($35,000 per ton). The calculations of all these
ranges do not include the costs for upgrading the electrical
infrastructure at the terminal or in main electric lines or subsystems.
In addition, these ranges assume minimum aircraft gate occupancy of 4
hours per day.
[25] EPA is proposing to extend the types of emissions available under
VALE to all federal actions subject to General Conformity Regulations.
See "Revisions to the General Conformity Regulations," Early Emission
Reduction Credit Program, 73 Fed. Reg. 1402 (Jan. 8, 2008).
[26] GAO also visited this airport and Philadelphia International
Airport.
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