MEMORANDUM 

TO: Record 

FROM: Mr. Brian D’Amico, USEPA/EAD 

DATE: February 8, 2012 

SUBJECT: Final Rule Barrier to Entry Analysis for New Source Performance Standards 

for Airport Deicing 

Introduction 

Under section 306(b) of the Clean Water Act, EPA sets New Source Performance Standards 

(NSPS). NSPS reflect effluent reductions that are achievable based on the “best available 

demonstrated control technology.” New facilities have the opportunity to install the best and 

most efficient processes and wastewater treatment technologies. As a result, NSPS should 

represent the controls attainable through the application of the best available demonstrated 

control technology. 

In setting NSPS, EPA does an economic analysis to ensure that these standards do not create a 

“barrier to entry.” A barrier to entry prevents or discourages the entry of new firms into a 

market, in this case, the construction of new airports. Barriers to entry might allow existing 

airports to constrain competition. It should be noted that some barriers to entry naturally exist in 

air transportation services; in densely populated regions such as the New York metropolitan area, 

for example, it would be cost prohibitive to purchase sufficient land to build a major new airport 

that could compete with New York’s existing airports. Thus, in this case, the goal of EPA is to 

ensure that it does not create new or additional barriers to entry through NSPS. EPA examines 

potential barriers to entry by determining if the NSPS requirements significantly increase the 

costs of constructing a new facility. This memorandum summarizes EPA’s assessment that the 

NSPS requirements of the final rule for airport deicing do not create a “barrier to entry” for new 

sources subject to these requirements. 

The final ELGs for the airport deicing category establish NSPS. All new in scope airports must 

comply with requirements based on substitution of less toxic pavement deicers that do not 

contain urea. The rule also establishes NSPS for wastewater discharges associated with aircraft 

deicing for a subset of new airports.1

 New source airports within the scope of this rule are 

required to collect spent aircraft deicing fluid (ADF) and, if they direct discharge collected ADF 

wastewaters, to meet numerical discharge limits. The technology basis for the collection 

requirement is centralized deicing pads (CDPs) and the technology basis for the Chemical 

Oxygen Demand (COD) standards is an anaerobic fluidized bed (AFB) treatment system. 

 

1

 EPA is making NSPS collection requirements for ADF applicable based on whether the new airport is located 

within specific colder climatic zones (called a “heating degree day [HDD] category”) as documented by the National 

Oceanic and Atmospheric Administration (NOAA). Airports in scope of the final rule for NSPS are located in areas 

with a HDD category of 3,000 HDD or higher. These climate zones are associated with the use of larger volumes of 

ADF. 
Memorandum 

8 February 2012 

Page 2 

CDP and Treatment Costs Relative to New Airport Construction Costs 

Our information is that Denver International (DIA), the only new airport to open in the last 25 

years that meets the applicability of the ELG, installed and uses deicing pads for all of their 

flights2

. Denver’s deicing handling system also includes a glycol recycling plant for treatment of 

collected ADF wastewaters. The plant storage tanks feed five mechanical vapor recompression 

units (MVRs). The MVRs concentrate the storage tank influent, which ranges from 1 to 12 

percent propylene glycol (PG), to a final concentration of 50 to 55 percent. The effluent from the 

MVRs goes to a storage tank until 150,000 gallons is stockpiled. The stockpiled effluent is sent 

to a distillation system, which increases the glycol concentration to 98 to 99 percent PG. The 

distillation system runs 24 hours a day for a three-week cycle and processes about 225,000 

gallons of PG before the system is halted for cleaning and maintenance. The distillate from both 

the MVRs and the distillation column are discharged to the airport’s WADS storage ponds and is 

then indirectly discharged to a POTW. The distillate is monitored for biological oxygen demand 

prior to discharging to the storage ponds. The distillation column bottoms are classified as 

specialized non-hazardous waste and are sent to a landfill (operated by BFI Waste Systems). The 

98 to 99 percent PG from the distillation column is pumped to a polisher where it is concentrated 

to greater than 99.3 percent PG. The WADS pond has three cells, where two cells receive and 

hold stormwater and the third cell is mixed and provides an equalized flow for metering and 

discharge to the POTW. Denver’s current POTW discharge permit requires it to comply with 

monthly COD discharge load limits. (See DCN AD00779) 

The estimated costs for the design and construction of DIA are publicly available and are $4.82 

billion (GAO, 1995). EPA also received CDP and recycling plant cost information for DIA 

during its site visit to Denver. (See DCN AD00779) Deicing infrastructure construction costs 

accounted for $126 million (in 1995$) at the time the airport was completed, approximately 2.6 

percent of the total cost of constructing the airport. (USEPA, 2011) The deicing infrastructure 

costs included four pads (with 22 slots), and all necessary piping and other related infrastructure. 

The airport also spent $14 million (in 1995$) constructing the recycling plant described above, 

representing 0.3 percent of the total cost of constructing the airport. (ERG, 2007; USEPA, 2011) 

In 2005, DIA added the “Whiskey Alpha” deicing pad covering 18 acres and providing 6 

additional aircraft deicing slots at a cost of $43 million (in 2005$). These costs include 4 type I 

ADF load stations, one 10,000 gallon type IV ADF tank and load station, a control building, 

piping, and an 800,000 gallon storage tank for collected ADF. 

Using the ENR Construction Cost Index to value all construction costs in the same year’s dollars 

(2006)3

, DIA has spent: 

 

2

 DIA is operated by the City and County of Denver Department of Aviation and is a municipal airport facility 

serving the Denver, Colorado metropolitan area. The airport opened on February 28, 1995 and includes 4 northsouth and 2 east-west runways, for a total of 6 runways. The airport has 89 gates and associated taxiways, aircraft 

parking aprons; three airside concourses; and passenger and cargo terminals. The airport was designed with a 

centralized deicing system comprised of four CDPs that are used for passenger aircraft, and the airport has since 

added a fifth pad. The airport also has general aviation and cargo ramps and a CDP which is occasionally used by 

cargo aircraft. Each of the passenger aircraft CDPs feed high concentration ADF stormwater (greater than 1 percent 

glycol) to on-site storage tanks located at the airport’s glycol recycling plant. (See DCN AD00779) 3

 ENR Construction Cost Index (CCI) for 1995 = 5471, for 2005 = 7446 , and for 2006 = 7751; 

CCI_2006/CCI_1995 = 7751/5471 = 1.41674 ; CCI_2006/CCI_2005 = 7751/7446 = 1.04096
Memorandum 

8 February 2012 

Page 3 

 $180.6 million on the original 4 CDPs and associated infrastructure; 

 $20.1 million on the ADF treatment facility; and 

 $44.8 million on the Whiskey Alpha pad and associated infrastructure. 

Therefore, the total amount spent for deicing controls at Denver was $245.5 million. CDPs and 

associated costs represent 92 percent of these costs while the recycle plant represents 8 percent 

of these costs. 

In addition, when original airport construction capital costs are inflated to 2006 dollars: 

 DIA initial capital cost totaled $6.91 billion. 

Thus, about 3.6 percent of the cost of constructing DIA is attributable to deicing infrastructure, 

including 5 CDPs and collected ADF recycle facilities.4 DIA chose to construct CDPs as an 

integral component of the airport’s initial layout. Furthermore, DIA chose to build additional 

CDPs to increase ADF wastewater collection capacity about 10 years after the airport was 

completed. Thus, as exhibited by its decision-making, DIA’s management considers CDPs to be 

economically viable. EPA therefore does not consider this percentage of airport construction 

cost to be a barrier to entry. 

AFB Treatment Costs Compared to DIA’s Recycle Plant Costs 

The NSPS effluent limits on COD would apply to new in-scope airports that directly discharge 

collected and treated ADF wastewater to waters of the U.S. As explained above, the technology 

basis for the NSPS COD standard is AFB. Since DIA is the only new airport to open within the 

past 25 years that would be subject to the final rule and since Denver did not install an AFB, 

EPA does not have cost information on installing AFB at a new airport. Since DIA is not a 

direct discharger and employs glycol recycling technology rather than on-site AFB, EPA 

evaluated the impact of ALB treatment costs on the barrier to entry analysis. EPA looked to 

costs of installing AFB at existing airports. EPA collected AFB capital treatment system costs 

during the proposed rule for the system retrofitted at Albany International Airport (ALB), the 

model facility for the COD standards. ALB reported AFB construction costs of $3.2 million 

(1998$). (Albany Airport, 2005; Albany airport, 2007) Using the ENR Construction Cost Index 

to value the AFB construction costs to 2006$, ALB spent $4.2 million on the AFB treatment 

facility.5

 

To compare DIA’s new construction recycle plant costs to ALB’s AFB retrofit treatment facility 

costs, EPA developed a normalized scaling factor based on the number of jet departures6

 at each 

airport. This scaling factor is then used to estimate what treatment facility costs might have been 

at DIA had it also built an AFB treatment system. EPA selected jet departures as the normalizing 

 

4

 This percentage should be an overestimate because EPA did not add the cost of additional capital investment to the 

original total airport capital costs. 

5

 ENR Construction Cost Index (CCI) for 1998 = 5920 and for 2006 = 7751; CCI_2006/CCI_1998 = 7751/5920 = 

1.30929 

6

 Based on Bureau of Transportation Statistics (BTS) 
Memorandum 

8 February 2012 

Page 4 

factor since both ALB and DIA are located in cold weather climates and would be expected to 

deice jet aircraft on a regular basis during the winter months. EPA calculated normalized costs 

using: 2006 jet departures, a three-year average of jet departures (2005 through 2007), and a 

five-year average of jet departures (2004 through 2008). The calculation of the normalized 

scaling factor and DIA’s projected treatment system costs are presented in Table 1. 

Table 1. Calculation of Normalized Treatment System Costs and Projected DIA Treatment 

System Cost (2006 $) 

Calculation Component 

Basis for Estimate [a] 

2006 3-Year Average 5-Year Average 

DIA 

Treatment System Costs $20,100,000 

Jet Departures 243,697 241,943 240,767 

Cost per Jet Departure $82.34 $82.93 $83.34 

ALB 

Treatment System Costs $4,200,000 

Jet Departures 22,447 22,884 22,361 

Cost per Jet Departure $186.65 $183.09 $187.37 

Ratio of ALB to DIA Cost per Jet Departure 2.3 2.2 2.2 

Projected DIA Treatment Cost $45,500,000 $44,300,000 $45,100,000 

[a] The three year average consists of the years 2005 through 2007, while the five year average includes the 2004 

through 2008 period. 

Thus, Albany’s AFB treatment system cost 2.2 to 2.3 times more than Denver’s treatment system 

when costs are normalized using jet departures. EPA then re-evaluated the percentage of airport 

construction costs for DIA assuming its treatment system costs were 2.2 to 2.3 times larger than 

its actual treatment system costs, about $44.3 to 45.6 million (in 2006$), and used these revised 

cost values to recalculate collection and treatment costs as a percent of initial airport costs. 

Adding the scaled treatment costs to the cost of constructing the CDPs and related infrastructure, 

DIA’s adjusted collection and treatment system would represent approximately 3.9 percent of 

the total DIA airport construction costs and would not present a barrier to entry. Further, the 

AFB treatment system costs for ALB represent a retrofitted system into an existing airport. EPA 

would not expect a new treatment system cost to exceed a retrofitted treatment system cost when 

applied to systems of similar size. 

CDP and Treatment Costs Extrapolated to Smaller New Airports

The construction of a major new airport, however, is a relatively rare event. It seems much more 

probable that any construction of a new airport in the foreseeable future will be a smaller airport. 

To determine likely airport construction scenarios, EPA examined FAA’s National Plan of 

Integrated Airport Systems (NPIAS) reports published between 2002 and 2010 and found: 
Memorandum 

8 February 2012 

Page 5 

 In 2002, FAA expected 125 airports to open within the next five years, none of which 

were commercial service airports7 (therefore these airports would all be out of scope of 

the final rule). 

 In May 2010, a new primary commercial service airport8 opened in Panama City, FL. 

 In January 2011, a new primary commercial service airport opened in St. George, UT. 

The NPIAS also reported at least four other communities have examined the possibility of 

developing new commercial service airports since 2008, including Peotone, IL, Bowling Green, 

KY, Hazleton, PA, and Las Vegas, NV. Some of these communities have been undertaking 

needs assessment and feasibility studies since before 2002, but as of 2010 no solid plans have 

emerged. No other potential commercial service airports were under consideration during this 

period. Therefore, based on data presented in NPIAS that reviewed more than a decade’s worth 

of airport planning and construction activity, EPA concludes that a new airport is much more 

likely to be a smaller commercial service airport than a major airport. 

Although a primary commercial service airport, EPA determined that the new Panama City 

airport is not in-scope of NSPS due to its geographic location. The St. George airport averaged 

more than 3,000 annual heating degree days from 1961 through 1990, and thus is potentially 

subject to NSPS. However, because these two airports provide the only source of recent data 

available on the cost of constructing a small primary commercial service airport, EPA will 

consider them to be representative of airports that will be subject to NSPS and use their 

construction cost data as the basis for this analysis. 

The NPIAS indicates that the Panama City airport had a planned service level of 225,000 annual 

enplanements and cost $318 million (Airport Technology, 2011; approximately $297 million in 

2006 dollars). The St. George airport had a planned service level of 55,000 annual enplanements 

and cost about $159 million (Airport Improvement Magazine, 2011; approximately $148 million 

in 2006 dollars). 

The NPIAS only provides data on planned enplanements, not expected operations. Therefore, 

EPA estimated the number of departures that might be expected at the Panama City airport to 

support the planned 225,000 annual enplanements. EPA used BTS data to estimate average 

annual enplanements per departure at existing commercial service airports with annual 

enplanements between 200,000 and 300,000 to represent Panama City airport, and annual 

enplanements between 30,000 and 100,000 for St. George. Average passengers per departure 

were then multiplied by the expected annual enplanements at each airport to estimate annual 

commercial airliner departures. EPA estimates that the new Panama City airport might average 

7,600 to 7,900 annual departures, while St. George might average 7,500 to 6,600 annual 

departures (see Table 2).9

 

 

7

 Commercial service airports are publicly owned airports that have at least 2,500 passenger boardings each calendar 

year and receive scheduled passenger service. 

8

 Primary commercial service airports have more than 10,000 passenger boardings each year. 9

 EPA excluded airports from Alaska’s Rural Airport System from the calculation because operating patterns at 

these airports differ significantly from operations at airports in the 48 contiguous states. 
Memorandum 

8 February 2012 

Page 6 

Table 2. Estimated Average Annual Departures at New St. George, UT and Panama City, 

FL Airports

Calculation Component

Basis for Estimate [a]

2006 3-Year Average 5-Year Average

Panama City, FL Airport 

Average Passengers per Departure at Existing 

Airports 28.44 29.37 29.45 

Expected average enplanements [b] 225,000 

Estimated departures 7,912 7,661 7,641 

St George, UT Airport 

Average Passengers per Departure 

at Existing Airports 8.51 9.60 10.39 

Expected average enplanements [b] 55,000 

Estimated departures 6,462 5,728 5,295 

[a] The three year average consists of the years 2005 through 2007, while the five year average includes the 2004 

through 2008 period. 

[b] NPIAS.

To estimate potential costs associated with the ADF collection and treatment requirements at 

new airports, EPA estimated that the average cost of constructing CDPs and treatment at DIA is 

in the $949 to $954 per departure range (2006 dollars; see Table 3). 

Table 3. Estimated Cost of Centralized Deicing Pads and Treatment System, per 

Departure, Denver International Airport (2006 $) 

Calculation Component

Basis for Estimate [a]

2006 3-Year Average 5-Year Average

Original deicing infrastructure ($ mil.) $180.6 $180.6 $180.6 

Projected treatment system($ mil.) $45.5 $44.3 $45.1 

Whiskey Alpha pad ($ mil.) $44.8 $44.8 $44.8 

Total ($ mil.) $270.8 $269.6 $270.5 

Annual Departures 285,399 283,340 283,454 

CDP and Treatment Cost per Departure $948.97 $951.67 $954.17 

[a] The three year average consists of the years 2005 through 2007, while the five year average includes the 2004 

through 2008 period. 

Using estimated departures to scale the costs of the CDP and treatment system to these smaller 

airports, EPA estimates that should an airport the size of Panama City build a CDP and ADF 

treatment system, then the capital cost will be about $7.3 to $7.5 million, or about 2.5 percent of 

the initial cost of the airport. An airport the size of St. George might incur capital costs of $5.1 

to $6.1 million for a CDP and ADF treatment system, or about 3.4 to 4.1 percent of the initial 

construction cost of the airport. These calculations are presented in Table 4. 
Memorandum 

8 February 2012 

Page 7 

Table 4. Estimated Cost of Centralized Deicing Pads and Treatment System as Percent of 

Total Airport Construction Costs at New St. George, UT and Panama City, FL Airports 

(2006 $)

Component

Basis for Estimate [a]

2006 3-Year Average 5-Year Average

Panama City, FL Airport 

Estimated departures 7,912 7,661 7,641 

CDP & treatment cost per departure (DIA) $948.97 $951.67 $954.17 

Estimated CDP & treatment cost ($ mil.) $7.51 $7.29 $7.29 

Airport construction cost ($ mil.) $296.6 

CPD & treatment cost / Airport cost 2.5% 2.5% 2.5% 

St George, UT Airport 

Estimated departures 6,462 5,728 5,295 

CDP & treatment cost per departure (DIA) $949 $952 $954 

Estimated CDP & treatment cost ($ mil.) $6.13 $5.45 $5.05 

Airport construction cost ($ mil.) $148.3 

CPD & treatment cost / Airport cost 4.1% 3.7% 3.4% 

[a] The three year average consists of the years 2005 through 2007, while the five year average includes the 2004 

through 2008 period. 

DIA’s management found CDPs and ADF wastewater treatment to be economically viable. The 

projected cost of constructing CDPs and ADF wastewater treatment at the Panama City and St. 

George airports composes a similar or smaller percentage of initial capital costs than was 

incurred by DIA. EPA therefore concludes that requiring smaller, new primary commercial 

service airports to build CDPs and ADF wastewater treatment systems would not create a barrier 

to entry for new airport construction. 

Product Substitution Costs 

New airports subject to NSPS will also be required to use pavement deicers that do not contain 

urea. Alternatively, the airport can collect and treat airfield pavement stormwaters to meet NSPS 

ammonia as nitrogen limits. EPA identified ammonia as the primary pollutant of concern from 

airfield deicing since ammonia discharges result from using pavement deicers containing urea. 

EPA identified product substitution (i.e., discontinuing the use of pavement deicers containing 

urea) as one means of eliminating pollutant discharges from these deicers. Currently only about 

10 percent of chemical pavement deicers applied nationwide contain urea. The NSPS do not 

require an airport to use a specific alternate pavement deicer, however, for the purposes of 

estimating costs to the industry, EPA assumed that airports would use potassium acetate, the 

most widely used pavement deicer in the industry. 

EPA has determined that the need to do product substitution at a new airport to meet NSPS 

requirements will not create a barrier to entry. First, only a small minority of airports, 37 of 198 

in-scope airports (18.7 percent) used a pavement deicer containing urea based on the airport 

questionnaire. Thus, it cannot be assumed that a new airport would have used urea in the absence 
Memorandum 

8 February 2012 

Page 8 

of the effluent guideline. If the management of a new airport intended to follow industry trends 

and use a pavement deicer that does not contain urea, then this effluent guideline adds nothing to 

the cost of constructing a new airport and cannot create a barrier to entry. 

Second, if EPA assumes the airport would have used a deicer containing urea in the absence of 

this effluent guideline, the incremental capital costs associated with product substitution are 

likely to be small. Pavement deicing requires capital costs to store, handle and spread the deicing 

product. During airport construction, management would be required to purchase equipment for 

the storage, handling, and spreading of the substitute product instead of the product containing 

urea. Therefore the incremental capital cost attributable to the effluent guideline is the difference 

between what the airport would have spent on this equipment for the product containing urea and 

what it does spend on the equipment for the urea-free product. When compared to the costs of a 

new airport, such costs are negligible. 

To test the above assumption, using information for existing airports of similar size, EPA 

estimated costs for the two smaller airports discussed above, Panama City and St. George, to use 

a non-urea pavement deicer. EPA’s record contains information on 6 existing airports with 

140,000 to 300,000 annual enplanements that will incur capital costs as a result of the product 

substitution requirement. On average, these airports are projected to incur $224,000 in initial 

capital costs (2006 dollars), with a net present value (NPV) of $328,000 (7 percent real rate) 

when accounting for equipment replacement over the 20-year analytic period. If these capital 

costs are entirely incremental, that is if they represent additional capital costs resulting from the 

effluent guideline, then the capital cost of the Panama City airport would increase by about 0.11 

percent , while the cost of the St. George airport described above would increase by 0.23 

percent.10 However, the capital costs evaluated here are an overestimate of the true incremental 

capital costs because they make no account for the storage, handling, and spreading equipment 

associated with the product containing urea that the airport does not purchase. After subtracting 

those capital costs from the estimated $328,000 in average NPV of capital costs, the Agency 

believes the net capital costs will be substantially smaller, perhaps even zero, and the percent 

increase in the capital cost of constructing a new airport will also be substantially smaller. 

Summary 

EPA has conducted an analysis of the costs of CDPs and ADF wastewater treatment in relation 

to airport design and construction costs showing that the NSPS technologies represent a small 

percentage of total airport construction costs and should not present a barrier to entry for new 

airports. The projected costs estimated for two small, recently built, primary commercial service 

airports compose a similar (or smaller) proportion of initial construction costs than those 

incurred at DIA. 

EPA also found that if capital costs projected for existing airports for pavement deicer 

substitution are applied to the new smaller airports evaluated in this memorandum, it would have 

a negligible increase on total airport construction costs. Furthermore, the true incremental 

 

10 Combined with the CDP and ADF wastewater treatment costs, Panama City airport costs would increase by 2.3 

percent and St. George airport costs would increase by 3.5 percent. 
Memorandum 

8 February 2012 

Page 9 

capital costs incurred by a new airport resulting from product substitution should be significantly 

smaller and less burdensome than those projected for existing airports. 

Therefore, EPA finds there is no barrier to entry for new airports to install the technology basis 

for the NSPS aircraft deicing requirements, airfield deicing requirements, or both. 

References

Airport Improvement Magazine. 2011. New Replacement Airport Opens in St. George, UT. 

http://www.airportimprovement.com/content/story.php?article=00263. Accessed January 6, 

2012. 

Airport Technology. 2011. Panama City-Bay County International Airport, United States of 

America. http://www.airport-technology.com/projects/panama_city_bay/. Accessed January 6, 

2012. 

Albany Airport. 2007. Albany Cost Data Submittal. (June 27). DCN AD00866. 

Albany Airport. 2005. Presentation: Award Winning Water Quality Management at Albany 

International Airport Regulatory Challenge and Biological Solutions. (February 10). DCN 

AD00256. 

ERG. 2007. Personnel Communication (email) between Keith Pass (DIA) and Mary Willett 

(ERG). (July 12). DCN AD00868. 

GAO. 1995. Denver International Airport: Information on Selected Financial Issues. General 

Accounting Office. (Letter Report, 09/18/95, GAO/AIMD-95-230). DCN AD00802. 

www.colorado.edu/libraries/govpub/dia.htm

USEPA. 2011. Personnel Communication (telephone contact) between Keith Pass (DIA) and 

Brian D’Amico (USEPA). (September 29). 

USEPA. 2008a. Airline Detailed Questionnaire Database. U.S. Environmental Protection 

Agency/Office of Water. Washington, D.C. DCN AD00938. 

USEPA. 2008b. Airport Questionnaire Database. U.S. Environmental Protection Agency/Office 

of Water. Washington, D.C. DCN AD00927. 

USEPA. 2007. Final Engineering Site Visit Report for Denver International Airport. U.S. 

Environmental Protection Agency/Office of Water. Washington, D.C. (November 4). DCN 

AD00779.