Recent Developments in GHG and Climate Change Management. April 15, 2010

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1 Recent Developments in GHG and Climate Change Management April 15, 2010

2 Greenhouse Gas Updates and Facilitated Discussion Greenhouse Gas Updates: CEQ NEPA Climate Change Guidance EPA Clean Air Act Programs: Mandatory GHG Reporting Rule, PSD/Title V GHG Tailoring Rule, CO 2 as a Regulated Pollutant SEC Interpretive Guidance Insurer Climate Risk Disclosure Executive Order - Federal Leadership in Environmental, Energy, and Economic Performance U.S. Congressional Activity Canada

3 Greenhouse Gas Updates and Facilitated Discussion Facilitated Discussion: Airport Plans and Programs GHG Inventories and Reporting Moderators: Sam Mehta, Environmental Services Manager, San Francisco Int l Airport Pamela Vanderbilt, Principal Scientist, Air Quality Services, CH2M HILL Excerpt from ACI-NA Board Adopted Environmental Goals (February 2009): "Half of ACI-NA member airports will strive to conduct greenhouse gas emissions inventories by 2015."

4 CEQ NEPA Climate Change Guidance Consideration of the Effects of Climate Change and Greenhouse Gas Emissions (18 Feb 2010) Explains when and how Federal agencies should consider: the impacts of proposed Federal actions on GHG emissions and global climate change, and the expected environmental effects from climate change that may be relevant to the design of the proposed Federal action. Threshold of 25,000 metric tons of CO 2 e from the proposed action may trigger quantitative analysis.

5 NEPA Climate Change Guidance (cont.) When a proposed federal action meets an applicable threshold for quantification and reporting, CEQ proposes that the agency should also consider mitigation measures and reasonable alternatives to reduce action-related GHG emissions. Options that may be considered: enhanced energy efficiency, lower GHG-emitting technology, renewable energy, planning for carbon capture and sequestration, and capturing or beneficially using fugitive methane emissions.

6 EPA Clean Air Act Programs: Mandatory GHG Reporting Rule PSD/Title V GHG Tailoring Rule CO 2 as a Regulated Pollutant

7 SUBJECT TO RULE U.S. EPA Mandatory GHG Reporting Rule Applicability Test for Airports with Stationary Fuel Combustion Units Does the facility have Boilers, Stationary Internal Combustion Engines, Process Heaters, Combustion Turbines, Incinerators, or Other Units? 1 YES NO Is the aggregate maximum 2 rated heat input capacity 30 million Btu per hour (mmbtu/hr)? YES Does the Facility Emit 25,000 metric tons/year of CO 2 equivalent (CO 2 e)? YES NO NO NOT SUBJECT TO RULE

8 U.S. EPA Mandatory GHG Reporting Rule (cont.) March 16, revisions to the GHG Mandatory Reporting Rule. Extends coverage to the eleven deferred source categories: electronics manufacturing, ethanol production, fluorinated GHG production, food processing, magnesium production, oil and natural gas systems, SF6 from electrical equipment, underground coal mines, industrial landfills, wastewater treatment, and suppliers of coal.

9 U.S. EPA PSD/Title V GHG Tailoring Rule Provides legal basis for changes to current major source permitting thresholds, specifically for GHG emissions. Rule design to tailor the applicability of requirements for Federal prevention of significant deterioration (PSD) and Title V permitting programs to limit the number of regulated facilities (more manageable and practical for EPA).

10 U.S. EPA Tailoring Rule (cont.) Rationale: GHGs, considered as CO 2 e, are emitted in much greater quantities than traditional criteria pollutants. Even small emitters would exceed current 100/250 tons per year (tpy) thresholds for a major source. GHGs will likely become a regulated pollutant in If GHGs become regulated pollutants, PSD and Title V permitting programs and requirements will automatically apply to major sources that emit over the thresholds.

11 U.S. EPA Tailoring Rule (cont.) Proposed changes: revised GHG major source thresholds and significance levels : PSD and Title V: major source defined to emit >25,000 tpy CO 2 e PSD significance level: >10,000-25,000 tpy CO 2 e Rule would reduce number of PSD and Title V permits from thousands and millions to ~100 new PSD and ~3,000 new Title V permits, due to higher thresholds.

12 U.S. EPA CO 2 as a Regulated Pollutant On April 1, 2010, EPA issued GHG emission standards for new car and truck engines effective in 2012 (requiring improved fuel economy over time). CO 2 thereby becomes a regulated pollutant under the Clean Air Act. Rules for permitting of stationary sources will take effect January 2011, which is the earliest that GHGcompliant, model year 2012 vehicles can be sold.

13 Securities and Exchange Commission (SEC) Guidance Regarding Climate Change Disclosure On March 17, 2009, the National Association of Insurance Commissioners (NAIC) adopted a mandatory requirement that insurance companies disclose to regulators the financial risks they face from climate change, as well as actions the companies are taking to respond to those risks. All insurance companies with annual premiums of $500 million or more were to be required to complete an Insurer Climate Risk Disclosure Survey every year, with an initial reporting deadline of May 1, On March 28, 2010, NAIC made surveys voluntary, discretional, and confidential.

14 Executive Order (EO) No Federal Leadership in Environmental, Energy, and Economic Performance Signed 5 October 2009 by President Obama Includes new goals and updates some requirements from Bush s 2007 EO 13423

15 EO (cont.) EO Metrics/Goals Included in EO 13423? (Existing EO) Included in EO 13514? (New EO) Updated or New Requirements in EO 13514? Greenhouse Gases (GHG) N Y Y Regional and local integrated planning N Y Y Water conservation Y Y Y Green purchasing Y Y Y Petroleum conservation Y Y Y Sustainable buildings Y Y Y Pollution prevention and recycling Y Y Y Electronics management Y Y Y Environmental Management Systems Y Y N (EMS) Reduction or elimination of toxics and Y Y N hazardous chemicals Energy efficiency Y Y N Renewable energy Y Y N Alternative fuel use Y Y N

16 United States Congressional Activity Any changes that may have occurred since Jane Calderwood s Legislative Update (Wednesday, April 14 at 10:30 am)

17 Canadian GHG Regulatory Programs Canadian Federal Government to harmonize GHG legislation with the U.S. Federal GHG reporting now has a threshold of 50,000 metric tonnes (reduced from 100,000 in prior years). The Federal Government has committed to a 17% reduction in GHGs below a 2005 baseline by Transport Canada Excel tool being tested by Canadian airports to calculate GHGs. Stakeholders developing MOU to work on aviation emissions (airlines, airports, Transport Canada, etc.). Any changes that may have occurred since Canadian update (Wednesday, April 14 at 11:00 am).

18 Facilitated Discussion: Airport Programs and Plans Excerpt from ACI-NA Board Adopted Environmental Goals (February 2009): "Half of ACI-NA member airports will strive to conduct GHG emissions inventories by 2015." And what else is going on at your airport???