AAAE Expresses Airport Concerns With EPA's Deicing Rulemaking Proposal
For Immediate Release
February 26, 2010
Alexandria, Va. -- AAAE, on behalf of the 850 airports its membership represents, submitted comments to the Environmental Protection Agency (EPA) on proposed new standards for limiting deicing fluid runoff at commercial airports.
EPA's proposal would establish standards for the amount of aircraft deicing fluid (ADF) that commercial service airports must re-capture and prevent from entering wastewater runoff. AAAE is concerned that the standards would put undue financial burdens and create safety hazards at many airports.
Under the proposed regulation, airports with more than 10,000 annual aircraft departures and 1,000 annual jet departures would be required to capture fluid. The re-capture standards would vary based on the amount of ADF used each year, with heavy users required to re-capture 60 percent of all fluid. In addition, airports determined to have “new sources” of pollution, such as new or extended runways, would be required to meet the highest standards.
While AAAE and the airport community support efforts to improve the environment, we have several issues with EPA's proposals. Among them:
- ADF recovery operations that require additional vehicles around gates, such as glycol recovery vehicles (GRVs), would create operational and safety issues that are neither addressed nor considered in the rulemaking,
- Constructing deicing pads is not possible at some land-constrained airports, and the rulemaking offers no alternative for meeting the new standards,
- Many airports may meet the jet and total departure threshold but use a minimum amount of fluid because they are in warmer climates. Forcing these airports to have ADF re-capture capabilities, such as a GRV, would create unreasonable cost burdens,
- A de facto ban on using urea as an anti-icing agent will lead to greater expense for airports that rely on this cost-effective material,
- EPA's cost estimates for compliance fail to take into account necessary expenditures, ranging from infrastructure (pipeline, etc.) to maintenance, and added cost of consultants and/or other staff to help create and manage new airport deicing plans, and
- EPA's proposed 30-day timeframe for implementing the new standards following a final rule are not realistic. EPA does not account for the time necessary to retrofit existing stormwater management facilities, which are all unique. Moreover, airports will need time to develop strategies for disposal of the ADF waste.
"Safe airport deicing procedures are paramount to winter weather practices. Currently our industry must adhere to a number of FAA regulations and other guidelines for deicing, as well as meet their EPA general or individual permit limitations,” said AAAE Director of Regulatory Affairs Leslie Riegle. “Some airports already meet these proposed ELG requirements through their permits and we believe meeting these stringent regulations should be more than environmentally adequate without being economically taxing or unnecessarily laborious to the airport,” she continued.
“We also need the EPA to consider all costs involved with this proposal,” Riegle added. “EPA needs to understand the regulatory environment that these facilities operate in, as well as the complexities that exist within the operational environment at an airport."
EPA's proposed rule, Effluent Limitation Guidelines (ELG) and New Source Performance Standards (NSPS) for the Airport Deicing Category (EPA-HQ-OW-2004-0038 FRL-8948-2), was published August 28.
AAAE's comments were formulated with input from association membership regarding the draft rule's specific impacts at their airports. A copy of AAAE's comments can be viewed here (.pdf).
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ABOUT AAAE: Founded in 1928, AAAE is the world’s largest professional organization representing the men and women who work at public-use commercial and general aviation airports. AAAE’s 5,000-plus members represent some 850 airports and hundreds of companies and organizations that support the airport industry. Headquartered in Alexandria, Va., AAAE serves its membership through results-oriented representation in Washington, D.C., and delivers a wide range of industry services and professional development opportunities, including training, conferences, and a highly respected accreditation program.
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