How are aviation emissions regulated?


How Are Aviation Emissions Regulated?


There is some misperception that aviation in general and airlines in particular are the “only unregulated industry in the country,” or “are getting a free ride on air quality,” and “cars have reduced their emissions by over 98% while aircraft have done nothing.” In fact, there are many, varied regulations that constrain aviation emissions. For example, both cars and aircraft have improved their energy intensity over time using new technologies, advanced materials, and improved designs for energy conservation to reduce fuel consumption. Practically all aviation emission sources are independently regulated through equipment specific regulations, standards and recommended practices, and operational guidelines, which are established by a variety of organizations. For example, on-road vehicles, which take passengers to and from the airport, meet stringent Federal tailpipe standards set by EPA. Stationary sources on the airport, like power boilers and refrigeration chillers, must meet independent state regulations. And FAA certification is required for essentially all aviation equipment and processes. For example there are more than 60 standards that apply to aircraft engine design, materials of construction, durability, instrumentation and control, and safety, among others. These are in addition to the Fuel Venting and Exhaust Emission Requirements for Turbine Engine Powered Airplanes (FAR Part 34), which guide compliance with EPA’s aircraft exhaust emission standards. This comprehensive and complex regulatory framework has enabled our safe and efficient national air transport network. The International Civil Aviation Organization (ICAO) is a United Nations intergovernmental body responsible for worldwide planning, implementation, and coordination of civil aviation. ICAO sets emission standards for jet engines. These are the basis of FAA’s aircraft engine performance certification standards, established through EPA regulations. ICAO has long been the forum for evaluating the environmental performance of aircraft engines. ICAO has taken a “technology progressing” approach, raising standards within the capabilities of proven technologies and certified products (engines and aircraft) rather than a “technology forcing” approach, which sets standards based on technology that is not certified or may not even exist. The reason for ICAO’s approach is quite simple - the very high premium placed on the safety of aircraft operation restricts the use of unproven new technologies. Current NOx standards were established in 1996. New standards go into effect for engines entering service beginning in 2004, which reflect a 16 percent NOx reduction over the 1996 standards and a 33 percent reduction over the original standards agreed to in 1981. Earlier this year, ICAO’s Committee on Aviation Environmental Protection recommended new certification standards that represent a further 12 percent NOx reduction, with an effective date of 2008. Airport air emissions from all sources also are constrained by the General Conformity regulations of the Clean Air Act Amendments of 1990. General Conformity requires Federal agencies to assure that actions that would increase emissions in non attainment areas “conform” to the appropriate State Implementation Plan. These plans define the steps states are committed to taking to ensure their cities enjoy healthy air. Each year the environmental impacts of several hundred projects at airports throughout the country are analyzed in detail, including general conformity evaluations and analyses, using the best data and most advanced analytical models available.

Emissions from the vast majority of these projects are well below the thresholds that trigger a “conformity determination.” The two or three projects a year that do require further analysis essentially are able to meet the needs of state air quality plans through minor project modification. EPA recently proposed new exhaust emission standards for non-road diesel engines. These standards, to be phased in between 2008 and 2014, will require engine manufacturers to produce new engines with advanced emission control technologies. New ground support equipment with diesel engines, which are used only on airport property, will be required to meet these standards. This new equipment will achieve emission performance comparable to today’s automobiles.

While there are no national or international regulations for greenhouse gas emissions that apply to aircraft or other airport sources, the aviation industry has made significant strides here as well. Aircraft have a long history of continuously improved fuel economy, which reduces all greenhouse gas emissions. For example, according to Boeing, the B-777 is 300 percent more efficient than its early jets. Fuel economy and energy conservation are also priorities at many airports. Dallas/Fort Worth International Airport for example looks at business practices at all of their facilities to minimize energy consumption. They realize that this benefits local air quality through reduced emissions as well as regional air quality as a result of reduced power purchases from electric utilities and an overall reduction in greenhouse gas emissions.

Looking to the future, FAA is working through ICAO to evaluate policy options to limit or reduce greenhouse gas emissions from aviation. Various market-based options, such as voluntary agreements, open emissions trading, and emission related levies are being analyzed. Preliminary results from analyses of market based options show that emission related levies are not cost-beneficial, but voluntary arrangements and emissions trading may be cost effective in limiting or reducing greenhouse gas emissions. Additional analyses are underway at ICAO to evaluate further emissions trading and voluntary agreements as approaches to limit aviation emissions growth while allowing continued expansion of air travel.

Under this multidimensional regulatory and voluntary structure, aviation has made significant environmental progress. Given the complexity of the industry and the need for different strategies and technological approaches for different types of vehicles and equipment, a coordinated effort between the aviation industry and the many regulatory agencies that share environmental responsibility will continue.

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