Greenhouse Gas. Guidance for FAA NEPA Documents. Thomas Cuddy. Office of Environment and Energy (AEE-400)
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1 Greenhouse Gas Federal Aviation Guidance for FAA NEPA Documents Thomas Cuddy Office of Environment and Energy (AEE-400) Prepared for:,
2 Overview Aviation GHG emissions in context NEPA and Climate Change FAA guidance on addressing GHG emissions under NEPA Feedback? Federal 2Aviation
3 Total US GHG emissions U.S. Greenhouse Gas Emissions by End Use Economic Sector, mmt CO 2 equivalent U.S. EPA (2008). Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 to Federal 3Aviation
4 Emissions by Transportation Mode U.S. Greenhouse Gas Emissions by Transportation Mode (2006) U.S. EPA (2008). Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 to Federal 4Aviation
5 Aviation and GHGs Aviation s Impact on Climate Aviation contributes ~3% to global CO 2 emissions; may grow globally to 5% by 2050 (IPCC) Between 1978 and 2008, U.S. airlines improved fuel efficiency from 2.92 Revenue Ton Miles/gallon to 6.11 Revenue Ton Miles/gallon, a 110% improvement 2.7 billion metric tons of CO 2 savings, equivalent to taking ~19.5 million cars off the road each year From 2000 to 2008: Increased passengers and cargo by 17% Reduced absolute fuel burn and emissions by ~ 5.5% Federal 5Aviation
6 Ongoing GHG Management Efforts GHG Inventories Climate Science EU ETS CO2 Standards Sustainability Cap-and- Trade Evolving CEQ NEPA Expectations FAA Federal 6Aviation
7 National Environmental Policy Act NEPA review is done for every federal action CEQ considers climate to be included within the existing parameters of NEPA GHGs and climate change are a category of environmental impact that should be considered in the NEPA process CEQ & FAA have no explicit policies for GHGs and NEPA Federal 7Aviation
8 FAA Draft Guidance on GHGs in NEPA FAA has prepared draft guidance for considering GHGs and climate change in NEPA reviews Based on discussion with CEQ and CEQ draft guidance Provides guidance on addressing GHG emission in FAA NEPA documents Designed to supplement FAA Order E Goal is disclosure of project/action affects Working with FAA Lines of Business to refine guidance Planned release date is May-June 2010 Federal 8Aviation
9 FAA Draft Guidance on GHGs in NEPA When to include? GHG and climate change should always be an impact category considered in FAA s NEPA process. Note: It would only be discussed in detail and quantitatively when it appears to be a significant impact otherwise briefly and qualitatively mention it. Federal 9Aviation
10 FAA Draft Guidance on GHGs in NEPA What level of analysis? Qualitatively: in a paragraph if effects are low (de minimis) or data is unavailable Quantitatively: When proposed increase is 25,000 annual metric tons (per draft CEQ guidance), or if - The data is available or readily gathered (e.g., airport has inventory of GHG) It is mandated by other laws (Regional climate action plan, state/local AQ) Federal 10Aviation
11 FAA Draft Guidance on GHGs in NEPA How to consider? Just like other NEPA impact categories, look at the incremental change - or delta - and whether it makes a difference when choosing among the proposed action and alternatives Pick a baseline year Determine the incremental change in GHG among project alternatives versus no action If quantitative analysis is necessary Report fuel burn data, such as from EDMS, in CO 2 tons Federal 11Aviation
12 FAA Draft Guidance on GHGs in NEPA Geographic boundary for airport actions? LTO emissions up to the mixing height, consistent with today s approach and EPA guidance with respect to local air quality, and in consideration of current data and modeling capabilities Include all sources that would normally be considered in an air quality assessment for the same type of action Federal 12Aviation
13 FAA Draft Guidance on GHGs in NEPA Determining significance Must be determined within the context of the project There are no standards for significant impact of GHGs We don t have resolution to analyze effects at local level Therefore focus is on disclosure of emissions Federal 13Aviation
14 FAA Draft Guidance on GHGs in NEPA Cumulative impacts? CEQ has said it is not the case that any contribution to atmospheric CO 2 concentrations is a significant cumulative impact. Note: for the great majority of FAA projects the cumulative contribution of a project to atmospheric CO2 and climate change will be de minimis and will not be meaningful when making a decision among proposed alternatives. Federal 14Aviation
15 Feedback? Federal 15Aviation
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