ATTACHMENT 3

WRITTEN COMMENTS AND RESPONSES

ON THE DRAFT RATE-OF-PROGRESS PLAN
Mr. Greg Tholen

Associate Air Quality Planner

Sacramento Metropolitan

Air Quality Management District (SMAQMD)

Street, 3rd Floor

Sacramento, CA 95814

Subject: Comments on Sacramento Regional Nonattainmeni Area 8-hourOzone Rate-.of Progress Plan (ROt’) — Draft Report

Dear Mr. Tholen:

Thank you for the opportunity to review and. comment on.the draft Rate of Progress (ROP) plan and the new emission inventories being considered for the Sacramento area. Along with our air quahty consultant. CH2M HILL, the Sacramento County Airport System (CountyAirport System, or SCAS) has reviewed the draft Rate of Progress (ROP) plan and its emission estimates. We offer the following, comments for consideration during the ROP adoption processes that will take place in early 2006.

1. Introduction and Overview

Comment

1-1

Comment

1-2

As demonstrated below, the region’s air quality plans do not sufficiently ac ount for the current and future level of aircraft operations, and for the construction activity urgently needed to sup port those operations. Among other factors, the emergence of STow’ cost” commercial air carriers has made air travel truly affordable to the public. The growth of such service in the Sacramento

area has eliminated the need for air travelers to use distant airports such as Oakland and San Francisco. Postponing or expanding the construction period for airport improvement prcects will potentially result In even higher emissions due to airfield and ground transportation congestion.

Included in the comments below is a proposal for a two-part approach for ensuring an adequate future nitrogen oxide (NOx) emission budget for SCAS facilities:

1. Aircraft emissions budget in 1994 ozone State Implementation Plan (SIP): consider trad ing the surplus volatile organic compounds (VOC) identified in the plan for nitrogen ox ides (NOx); and

2. Under the new draft ozone SIP to. te completed in June 2007. consider transferring any NOx surplus that may be indicated in the on-road vehicle emssion budget to the aircraft budget.

In addition, as you know, SCAS has engaged in a number of voluntary effoits to reduce emis sions at SMF. including the recently completed Inherently Low Emission Airport Vehicle (ILEAV)

Sacramento County

Airport System

G. Hardy Acree, Director ofAirports County of Sacramei

October 27, 2005

Mather Airport

Executive Airport

Franklin Field

6900 Airport Boulevard • Sacramento. California 95837 • phone (916) 8740719 • fax (916) 8740636

www.saccounty.net • www.sacarports.org
2. General Comments

Implementation

It is imperative that the emission budget established for regional aircraft operations in the State

craft emission

Plan (SIP) reflect anticipated growth in all regional aviation activities. The air budget will serve as the basis for determining compliance with the General Con

formity requirements associated with future growth of all the airports in the multi-county nonat tainment

nonattainment

area. The aircraft emission budgets apply to the 17 airports located in the Sacramento

airports

area. An inadequate budget for aircraft emissions will limit the ability of thes.e to modernize and provide services to meet the continued demand for air travel.

ing

The

Sacramento

Sacramento County Airport System (SCAS) is responsible for four of these airports includ

Executive

International Airport (SMF), Mather Field (MHR), McClellan (MCC), Sacramento (SAC), and Franklin Field (F72). SAC airport is comprised of approximately 740

der

acres

an

owned

agreement

by the

with

City

the

of

City.

Sacramento (City). The facility is leased and operated by SCAS

u

mento Valley.

SAC is the primary general aviation airport serving the Sacra

ates McClellan

In

Airport

addition, the Sacramento County Department of Economic Development oper

der an agreement with (MCC). The County Airport System maintains portions of the airfield un the airportsflnancially Economic Development Sacramento County is striving to make each of viable by expanding operations and attracting new tenants.

The remaining 12 airports in the rionattainment area are operated by other entities with which Comment the County Airport System has no affiliation or involvement. Each of these airports function dif 1$

J ferently, each of to serve the needs of its tenants and users. It Is prudent to assume, however, that these airports will also experience future growth as the regional poputation increases.

Comment

1.7

The

larger

County

emissions

Airport System’s July 20. 2005 letter to SMAQMD on the draft ROP requested

a

accurate

budget for future aircraft activities because of the many uncertainties in making

variety

aviation forecasts. Aircraft emissions are driven by the aircraft fleet mix, and

a wide

by demand,

of aircraft types commonly operate at each of the regional airports. Fleet mix is driven

pled with growth

and demand is largely driven by changes in national economic environment, cou

sign aircraft

in the regional population and economy. In addition, airlines constantly reas to city pairs” based on factors such as fluctuating market demand, load factors

scheduling

(percentage ofseats filled), and aircraft availability. An example of the dynamic nature of aircraft

sponse to fuel

is the

price

recent

spikes

elimination

resulting

and rapid reinstatement of flights by several airlines in re— from the ukatrinan given time hurricane. The net result is that in any

varying age,span the same scheduled service may be served by

a wide range of aircraft types of engine vintage and emission levels. 1

I Comment

L14

Comment

1-5

3. Aircraft Emission Budget

A. Aircraft Variability

1

737-800.

For example. it can generally be assumed that a Boeing 737-300 Will have older, higher emitting engines than the newer model
reducing noise caused by commercial aircraft. The latest 

Stage 3

engines with high pressure 1-8 ratios have resulted in reduced noise, fuel use and emissions of carbon monoxide (GO) and

volatile organic compounds (VOCs) 2,but the higher operating temperatures of these engines has had the unfortunate result of causing increased nitrogen oxide (NOx) emissions. a factor

not accounted for In the 1994 SIP budget developed in the early 1990s.

C. Aircraft Characteristics

C mment I Jet-powered (turbofan) aircraft are high NOx, and low VOC emitters, while piston aircraft are °

1-9 I high VOC. low NOx emitters. Turbo-prop powered aircraft are significant emitters of both pre

J cursor pollutants. The amount of time an aircraft spends in each flight mode (take-off, dimb-out,

approach, and taxi/delay) also influences emissions. Thus, aircraft emissions at each airport

can vary greatly depending upon the activities and performance of each type of aircraft, andnumerous operational conditions at each airfield.

D. Air Travel Demand

The current and forthcoming period of rapidly changing economic conditions, particularly in the Comment commercial aviation industry, makes the activities of future aircraft operations very hard to pre 1-10 dict. High fuel costs have forced many airlines to change the aIrcraft fleet mix, and to make

constant readjustments. Air cargo activities have Increased due to congested marine ports and rail terminals, increased internet sales, and “just in time” inventory procedures. The stringent securityprocedures brought about by the 9-11 attacks have also increased the use of corporate aircraft at smaller airports.

E. Airport Master Plans

An airport operator is held responsible for airport emissions, but has no control of travel de Comment mend, the types of aircraft used, or of ongoing military activities. Regional airport operators will 1-11 not be able to modernize and expand to meet travel demand If the SIP emission budgets estab lished for aircraft are inadequate. Past experience with the delay in constructing Terminal

A at

SMF has shown that aIr travel demand continues to increase, even when airfield facilities arelimited, Inadequate airport facilities generate greater emissions due to congestion and ineffi dent operations of aircraft, ground support equipment (GSE), and ground access vehicles

(GAy). V

The SCAS recently prepared Airport Master Plans for SMF and MHR that forecast activities Comment over

a 20-year period. These plans anticipate growth in passengers, air cargo, aircraft opera- 1-12

J tions, and emissions, and identified

a number of improvements to increase the efficiency of each airfield. However, SMF is currently growing faster than anticipated. Attachment I is a ta

ble summarizing aircraft activity at SMF, MHR and SAC for the 12 months ending August 30, 2005. During that period SMF air passenger use grew by more than eight percent, air cargo

grew by more than two percent, and aircraft operations grew by almost 0.6 percent. (This growth is not related to post terrorist attach recovery, because SMF passenger traffic returned

to pre-September 2001 levels by April 2002.) Significantly, the 12-month SMF passenger count

2ema&yreferred to as hydrocarbons (HC).3Tha price to pay for veiy high bypass ratIo engines Is Increased size, weight and drag, which result in greater fuel burn. In addi tion, higher bypass ratio engines require much higher pressure ratios, which imply higher engine core temperatures and may have a

negative effect on emissions, especially oxides of nitrogen. These costs must be weighed against the noise benefits.’ Environmental Review 2004, International Air Transport AssociaBon (JATA), p.7.
anticipated

p

p

e growth impact of these airports was not in the SIP budget currently available for future aircraft emissions.

4. Conformity Concerns

cussed.

During the

The

recent ROP workshop at the SMAQMD.

a wide variety of regional sources were dis

withholding

emissions of on-road vehicles were of particular interest because of the recent

“Transportation

of federal

Conformity” funding and approvals for needed roadway Improvement projects.

A

plans lapse occurred in October 2004 because the regional transportation

tivities.

did

The

not meet the emissions budget that had been established for region-wide vehicle ac

puter model emission

1994 SIP

factors

on-road vehicle emission budgets were based on old EMFAC7F com and travel assumptions developed during the early 1990s.

Comment

The most current on-road vehicle emission estimates are based on improved EMFAC2002

1-14 have computer model emission factors and updated travel assumptions. These latest ROP estimates

plans

provided

may

a larger emissions budget for on-road vehicles. The transportation improvement

lug the latest

now lit within the revised budget and be able to move forward after reevaluation US

some are

information. There are even surplus NOx vehicle reductions anticipated, and

goals. planned to be substituted for hydrocarbons (HC), to reach the ROP HC reduction

However, aircraft emissions are regulated by the requirements of “General Conformity”, different that are from Transportation Conformity. The SMAQMD has recently become aware that

sion

(unlike

updates Transportation Conformity) USEPA guidelines do not recognize the recent ROP ernis

to establish

as an “applicable SIP”, and the latest emission aircraft estimates cannot be used an updated budget.

Thus,improvement

a very similar conformity lapse situation may occur with the regional airports if their airfield plans do not meet the old 1994 SIP budget established for aircraft. New General

budgets

Conformity budgets will be established with the “attainment SIP” scheduled for June 2007. The

which may

established in this new SIP will not become applicable until approved by the USEPA,

to continue

take six months or more. Therefore, regional airport improvement projects will have

forfuture airport

to be

growth.

approved using the outdated 1994 SIP aircraft budget, which leaves little room

pared.

Much has

At

changed since the early 1990’s when the old 1994 SIP budget for aircraft was pre

rapidly,

that time, SIP budget emission forecasts only extended to 2005. SMF was growing and MHR was in the process of being converted into

a civilian airport. The future activi ties

Regional

of MCC were uncertain because its future as an Air Force base was unknown at that time.

assumed

general aviation activities were on the decrease, and most of the small airfields were

adequately

to be stagnant. Also, the accuracy of the aircraft fleet mix operations may not have represented general aviation emissions because consistent records were not kept at the various smaller airports.

Comment Analyses of current aircraft emissions show that SMF and MHR now consume most of the NOx 1-18 budget allotted in the 1994 SIP. Recent Master Plans for SMF and MHR have estimated that

aircraft operations will increase at both airports between now and 2020. Emission calculations,

the

based

HC

on

budget

the 2010

will

forecasted aircraft fleet mix, show that 99% of the NOX budget, and 41% of be consumed by these two airports alone. This leaves little margin for error.

Comment

1.16

Comment

1-17
5. Timing of “Attainment SIP” Budget with Planned SCAS Airfield Improvements

Comment

1-21

SCAS has many airport improvement projects planned between 2006 and 2010 that are likely to make it difficult to stay within the outdated 1994 budget. The forecast growth in flight operations

may increase aircraft emissions at the SCAS airports faster than the approval schedules of thenew SIP aircraft budget The SMAQMD and the Airport System must continue to work together

to increase the aircraft budget while resoMng other General Conformity issues.

SCAS recently began preparation of environmental documents for the SMF Master Plan.

Preparation of environmental documents for the MHR Master Plan is expected to begin in mid- 2006. It is anticipated that approximately two years will be required to gain environmental ap proval for each of the Master Plans before the projects at these airports can move forward. SCAS also plans to begin a new Master Plan for SAC airport and Franklin Field in 2006, with preparation of environmental documents anticipated to begin in 2008.

The Federal Aviation Administration is the lead agency responsible for determining that the air field projects expected by 2010 meet the requirements of General Conformity. Approval of the environmental documents for the various Master Plans will require that future aircraft emissions

fit within the applicable budget, and thattotal direct and indirect emissions growth does not ex ceed the 50 tons!calèndar year de minlmus threshold established by General Conformity. Dur ing this period it will likely be hard to stay within the outdated and inadequate SIP aircraft budget, and gain environmental document approvals needed to construct the various planned airfield improvements. Anticipated major SCAS construction projects by 2010 indude:

SMF 2006—2010

Construct new FAA control tower

Extend the east runway and construct new cross field taxiway

Improve on-airport roadways

Expand the rental car facility

Construct air cargo building and apron

Overlay taxiway D

Demolish and rebuild terminal B

MHR 2006—2010

Rehabilitate runway pavement

Install instrument landing system

Construct air cargo access roadway

Upgrade roadways and vehicle parking lots

Extend runway 4L-22R, and upgrade taxiways
SAC 2006—2010

Improve aircraft ramp pavement areas

Construct airfield maintenance facility

6. Potential Solutions

A. Emission Budgets

The outdated 1994 aircraft SIP budgets currently applicable are very tight for NOx emissions, Comment but contain more than adequate amounts of hydrocarbon (MC) emissions. We request that 1-22

tion

SMAQMD

is possible,

consider allocating

a portion of the some of the surplus HG for NOX. If this substitu

low the SCAS projects

it would increase the NOx budget available for future aircraft operations and al

craft would need

to move forward in the interim.

A new larger emissions budget for air

to support

to be established in the upcoming attainment SIP budget that would continue increases in aircraft emissions.

Comment stration

Once the ROP has been approved, the region must prepare an ozone attainment plan demon1.23 that will be based upon photochemical modeling. This new plan will project the regional

I 1 2013. emissions Photochemical inventory andmodeling motor vehicle emission budgets through the attainment deadline of the region will meet will determine if the anticipated total emission reductions within

region will concentrate

the 8-hour ozone standard. If it is shown that the standard will be met, the

established

on insuring that emissions are maintained within the emission budgets in the attainment plan.

Comment ceeding

Should this

the

occur

overall

there

regional

may be ways to increase the budget for aircraft emissions without ex

124 about 25 emission quantities. The ROP inventory currently anticipates that

NOx surplus tonslday of surplus NOx reductions from on-road vehicles may be available. If this

of it can be allocated

is shown to still be available after photochemical modeling, perhaps

a small portion to the aircraft budget portion of the attainment SIP.

Comment However, if photochemical modeling shows that attainment cannot be demonstrated by 2013, 125 attainment the SMAQMDdeadline may request

a “bump up” to “severe” nonattainment status that would extend the

Improvements

to 2019. Unfortunately, this could have major implications for the airport because the “bump up” would decrease the General Conformity de minimus threshold

construction

to 25 tons/year. Given the number of construction projects included the Master Plans,

difficult equipment emissions could potentially exceed the 25-ton/year threshold, making it

the airport

to achieve

Master Plans.

the mitigation reductions needed to approve the environmental documents for

B. Emission Reduction Credits (ERCs)

r

Comment purpose

SMF was

of

one

demonstrating

of ten commercial airports that received

a matching grant from the FAA for the the efficacy of various technologies in reducing airport related emis

L

1.26

I twenty

sions. The

diesel

projects

poweredimplemented at SMF under the ILEAV program indude replacement of busses with CNG busses, an upgrade to the CNG refueling facility, re
air. SCAS anticipates submitting Emission Reduction Credit (ERC) applications for many of these projects, in anticipation of applying the credits toward construction-related emissions. Si

erra Research, a consultant to SCAS, submitted an ERC application for the recently completed jet fuel pipeline and fuel storage facilities, which WILT eliminate about 30 roundtrip diesel powered delivery trips daily. Earlier this year the FAA and USEPA developed ERC guidelines for such activities pursuant to the Voluntary Airport Low Emissions (VALE) program. Finally, as you know, SMAQMD successfully nominated the above activities for recognition as a “Clean Air Champion” by the Sacramento-Emigrant Trails chapter of the American Lung Association.

7. Conclusions

It is imperative that the emission budgets established within the applicable SIP be adequate to Comment permit the future growth of aircraft operations in the region. Currently, only the outdated 1994 SIP aircraft budgets are applicable, and they are based on outdated information.

Many future improvements are planned for the airports operated in Sacramento County by the Comment SCAS. These improvements are needed to meet the demand for air travel services that grows 1.28 With the regional population and economy. Numerous small airports iocated within the nonat tainment area may also wish to expand their activities, and the SIP does not adequately account For that posslbiflty.

The timing of SCAS airport improvement projects is out of phase with the regulatory schedule of Comment preparing and approving a new attainment SIP budget. This makes it difficult for the environ- 1-29 mental documents associated with the SMF and MHR Master Plans to be approved. Additional Master Plans and environmental documents will be prepared for the remaining SCAS airports that will eventually encounter the same difficulty in obtaining approval in a timely manner. In the interim, we recommend that the SMAQMD allocate some of the excess HC emissions (currently available in the 1994 SIP aircraft budget) to the NOx aircraft budget. This will enable the airport projects to move forward until a new attainment SIP budget Is available.

if the current ROP emissions inventory is carried forward into the attainment SIP, and proves to Comment be adequate to demonstrate attainment, there should be excess NOx emissions available within 1-30 the region. A small portion of this NOx excess could then be allocated to the aircraft budget without threatening attainment progress. An increased NOx budget for future aircraft activities will enable the planned airport projects to move forward and meet the future demands of re

gIonal air travel services.

Please contact me at 916-874-0698 if you have any questions about the above comments.

Sincerely,

‘cWQ

Senior Environmental Analyst

C: Leonard Takayama, Deputy Director — Planning and Development

George Munson, Airport Planner— Planning and Development
g

the 12 Months Ending August 30. 2005

1f!1IU rrt August August Last 12 Months Last 12 Months

2004

August2004. InAugust2005coniparedto

o=—

Passengers 932,688

—

893)985

——

10,027,321

—

9,266,821

NFreight(rcns) 6795 5,479 66,391 64)910 Aircraft operations at Executive Alrpott were q2&4% in August Akcalt Operations 16,405 15,659 163,496 164,448 2005 compared to August 2004 i4kpj

Aircraft Operations 13,206 10,521 114,372 136,493 ),.. - rEjt E’J $M!

,

Air Freight (lbns) 5,960 6,448 63,099 64,161

Aircraft Operations 8,507 8,014 82,108 78,891

Source: Airmail, October 19, 2005. Sacramento County Airport System

WPLANNING’ENVIRONMENTALWr QuaIitySIP Update_ 2004Rate of Progress Plan20D5ROP_Comments(2)4oc
g

o

attainment Area 8

Hour Ozone Rate

of

Progress Plan (Draft Report, dated September 2005). We understand your concerns regarding the proposed emissions

inventories for airports, especially for 2008 and beyond. SMAQMD staff will work

closely with Sacramento County Airport System (SCAS) staff to document and evaluate

potentially higher than anticipated growth at Sacramento International, Mather Field,

McClellan Airport, Sacramento Executive, and Franklin Field as we develop the regional airports emissions inventory for the upcoming 8-hour ozone attainment plan due in 2007. In addition, SMAQMD staff will continue to explore options available in the

General Conformity Rule for showing general conformity for near-term airport projects under the existing SIP aircraft emissions inventory.

Below are responses to your specific comments in your letter:

1. Introduction and Overview

Response to Comment 1-1:

Comments noted. The surge in current and anticipated airport activity must be

documented so that we can incorporate revised growth rates for aircraft and ground

support equipment activity in the next state implementation plan (SIP) submittal.

Response to Comment 1-2:

Comments noted. Regarding your Proposal I for ensuring an adequate future aircraft

NOx emissions inventory budget, General Conformity Rules (40 CFR §93, Subpart B)

do not allow the trading of volatile organic compound emissions budget surplus for

nitrogen oxide emissions budget shortfalls. EPA is revising the General Conformity Rule which is anticipated to be published in June 2006. To the extent this revision of

the rule allows for inter-pollutant trading, the District will work with SCAS to evaluate

incorporating surplus emissions.

Regarding your Proposal 2 for ensuring an adequate future aircraft NOx emissions

inventory budget, preliminary photochemical modeling results indicate that additional

ozone precursor emission reductions will be needed to demonstrate attainment of theozone standard by the 2013 attainment year in the Sacramento region. Because of the

need for additional NOx for the attainment demonstration, the transfer of surplus NOx

will be evaluated during that attainment demonstration planning process.
• For any criteria pollutant, the total of direct and indirect emissions from the action is specifically identified and accounted for in the applicable SIP’s attainment or maintenance demonstration (40 CFR §93.158(a)(1)); or

• For ozone or nitrogen dioxide, the total of direct and indirect emissions from the action is fully offset within the same nonattainment (or maintenance) area through a revision to the applicable SIP or a similarly enforceable measure that effects emission reductions so that there is no net increase in emissions of that pollutant (40 CFR §93.158(a)(2));or

• For ozone or nitrogen dioxide, the total of direct and indirect emissions from the action is determined and documented by the State agency primarily responsible for the applicable SIP to result in a level of emissions which, together with all other emissions in the nonattainment (or maintenance) area, would not exceed the emissions inventory specified in the applicable SIP (40 CFR §93.158(a)(5)(i)(A)); or

• For ozone or nitrogen dioxide, the total of direct and indirect emissions from the action is determined by the State agency responsible for the applicable SIP to result in a level of emissions which, together with all other emissions in the nonattainment (or maintenance) area, would exceed the emissions inventory specified in the applicable SIP and the State Governor or the Governor’s designee for SIP actions makes a written commitment to EPA for specific SIP revision measures reducing emissions to not exceed the emissions inventory (40 CFR §93.158(a)(5)Q)(B)).

Response to Comment 1-3:

Your comments are noted regarding SCAS efforts to reduce emissions at SMF. SMAQMD staff will work with SCAS staff to determine the eligibility of SMF emission reductions for emission reduction credits.

2. General Comments

Response to Comment 1-4:

Comments noted. SMAQMD staff worked very closely with SCAS contractor CH2M Hill

on the recent update to the aircraft emission inventory for the region. Together we
g

p

y 

the upcoming 8

hour ozone attainment plan due in 2007.

Response to Comment 1-5:

Comments noted.

Response to Comment 1-6:

Comments iioted. Future growth for the remaining 12 airports in the region is included in the forecast using California Air Resources Board (GARB) growth factors.

3. Aircraft Emission BudgetResponse to Comment 1-7:

Your comments are noted regarding the SCAS July 20, 2005 letter to SMAQMD requesting a larger emissions budget for future aircraft activities due to the uncertainties

in making accurate aviation forecasts. SMAQMD staff sent you a response letter (dated November 7, 2005) requesting more specific information and documentation for airport activity growth and emissions) and timing of conformity determinations for upcoming actions.

Response to Comment 1-8:

Comments noted. SMAQMD staff worked very closely with SCAS contractor CH2M Hill

on the recent update to the aircraft emission inventory for the region. This work resulted

in an update to the growth and control methodology incorporating the impacts of engine design changes and increases in passenger loading providing a more accurate

projection of aircraft emissions.

Response to Comment 1-9:

Comments noted. Updated aircraft inventory reflects the time spent in each flight mode

as provided by CH2M Hill.

Response to Comment 1-10:
Response to Comment 1-li:

See Response to Comment 1-1.

Response to Comment 1-12:

See Response to Comments 1-4 and 1-10

4. Conformity Concerns

Response to Comment 1-13:

Comments noted.

Response to Comment 1-14:

Comments noted.

Response to Comment 1-15:

Comments noted. Current federal rules (40 CFR §93.158) do not currently allow for the emissions inventory in this Rate-of-Progress Plan to be applicable for general

maintenance

conformity purposes, since the inventory must be from an applicable SIP’s attainment or demonstration. Therefore, the existing attainment demonstration SIP emissions inventory is established in the 1994 Sacramento Area Regional Ozone Attainment Plan. The next attainment demonstration SIP submittal for the Sacramento nonattainment area will be for the federal 8-hour ozone standard due in 2007.

However, EPA is revising the General Conformity Rule which is anticipated to be published in June 2006. To the extent this revision of the rule allows for general conformity emissions levels to be updated through the ROP process, the District will work diligently with State, local, and other agencies to incorporate the ROP’s 2008 aircraft emission levels.

Response to Comment 1-16:
Response to Comment 1-17:

The 2002 ROP inventory reflects improvements to more accurately represent the

current level of aircraft emissions and future emissions based on currently available data. Growth factors, aircraft fleet mix, and meteorological parameters used in

calculating aircraft emission factors were reviewed and updated in coordination with

CH2M Hill, CARB, and SMAQMD staff.

Response to Comment 1-18:

See Response to Comment 1-4.

5. Timing of “Attainment SIP” Budget with Planned SCAS Airfield Improvements

Response to Comment 1-19:

See Response to Comment 1-4 and 1-15

Response to Comment 1-20:

Current inventory uses forecasted activities from the approved Airport Master Plans, It

should be noted that the inventory documentation needed to address the issues raised

in these comments is required by July 2006 to be incorporated into the 2007 Attainment

Demonstration SIP.

Response to Comment 1-21:

See Responses to Comments 1-16, 1-15, and 1-4.

6. Potential Solutions

Response to Comment 1-22:

See Responses to Comments 1-2, 1-1, and 1-4.

Response to Comment 1-23:

Comments noted.
Responses

to Comments 1-1 and 1-4.

Response to Comment 1-25:

The region will consider this issue when the need for a “bump up” is considered.

Response to Comment 1-26:

See Response to Comment 1-3.

7. Conclusions

Response to Comment 1-27:

The Air District staff will work diligently with SCAS and other Federal, State, and local agencies to prepare an aircraft emissions inventory that addresses growth for the region’s airports and demonstrate attainment. To reach this goal, growth data, aircraft fleet mix, and operations data must be provided in time to accommodate a thorough

Attainment

review and validation prior to updating the inventory for submittal along with the 2007 Demonstration SIP.

Response to Comment 1-28:

See Responses to Comments 1-1, 1-4 and 1-6.

Response to Comments 1-29 and 1-30:

Unfortunately, the current General Conformity rules do not allow this ROP SIP to update the aircraft emission inventory. Therefore, this important issue must be addressed in the 2007 Attainment Demonstration SIP.