{A0137730.1 } 

Draft 

Site Visit Report for 

Logan International Airport 

Boston, MA 

Prepared for: 

U.S. Environmental Protection Agency

Engineering and Analysis Division 

Office of Water 

1200 Pennsylvania Avenue, NW 

Washington, D.C. 20460 

Prepared by: 

Eastern Research Group, Inc.

14555 Avion Parkway 

Suite 200 

Chantilly, VA 20151 

August 2011 

EPA Contract No. 68-CO2-095 

Work Assignment 8-15 
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Draft 

Site Visit Report for 

Logan International Airport 

Boston, MA 

1.0 PLACE AND DATE

Massachusetts Port Authority 

One Harborside Drive 

East Boston, MA 02128 

March 21, 2011 

2.0 ATTENDEES

Logan International Airport

Catherine Wetherell, Deputy Director, Capital Programs 

 and Environmental Affairs (617) 568-3501 

Vincent Cardillo, Deputy Director of Aviation Operations (617) 561-1936 

Patricia Haederle, Assistant Director, Capital Programs 

 and Environmental Affairs 

Ira Wallach, Chief Aviation Counsel (617) 568-3151 

Flavio Leo, Manager of Aviation Planning (617) 568-3528 

Anderson & Kreiger LLP

William Lahey, Attorney (617) 621-6550 

Elizabeth Mason, Attorney (617) 621-6534 

U.S. Environmental Protection Agency

Brian D’Amico, Project Engineer (202) 566-1069 

Newton Tedder, EPA Region 1 NPDES Permitting (617) 918-1038 

Eastern Research Group, Inc. (technical contractor to U.S. EPA)

Calvin Franz, ERG Economic Task Assignment Manager (781) 674-7383 

3.0 BACKGROUND AND OBJECTIVES

The U.S. Environmental Protection Agency (EPA) conducted a site visit at Logan International 

Airport (BOS), Boston, MA (Logan) on March 21, 2011. EPA conducted this site visit to collect 

information to inform the Effluent Limitation Guidelines rulemaking for discharges from airport 

deicing operations. EPA visited Logan to better understand its operations and constraints, 

including the significant land constraints described by Massachusetts Port Authority (Massport) 

in its February 26, 2010 comments on the proposed Effluent Limitation Guidelines and New 

Source Performance Standards for the Airport Deicing Category published in the Federal 

Register on August 28, 2009 (Proposed Rule). 
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4.0 OVERVIEW

Logan is owned and operated by Massport, an independent state authority that is also responsible 

for the Hanscom Field and Worcester Regional airports, the Port of Boston, and additional real 

estate holdings. It is the largest and busiest commercial airport in New England and one of the 

busiest (top 25) airports in the United States. 

In 2010, Logan had approximately 353,000 aircraft operations (takeoffs and landings) and 

handled approximately 27.4 million passengers, roughly 3.7 million of whom were on 

international flights. Its carriers include major airlines, regional and commuter airlines, foreignflagged air carriers and cargo carriers. Airlines operating from Logan include: 

 Major airlines: AirTran Airways, American Airlines, Continental, Delta, JetBlue 

Airways, Southwest Airlines, United Airlines, and US Airways, which account for 85 

percent of passenger enplanements. (Alaska Airlines and Frontier Airlines also operate 

from Logan, but account for a very small percentage of passenger enplanements.) 

 Regional/commuter airlines: American Eagle, Cape Air, Porter Airlines, Spirit Airlines, 

Sun Country, United Express, US Airways Express/Shuttle, Virgin America. 

 Foreign air carriers: Aer Lingus, Air Canada, Air France, Alitalia, British Airways, 

Iberia, Icelandair, Lufthansa, SATA (Azores Express), Swiss International Air Lines, 

TACV (Cabo Verde Airlines), Virgin Atlantic Airways. 

 Cargo carriers: ABX Air, Astar Air Cargo, Air Transport International, DHL Airways, 

Federal Express, and UPS Airlines. 

There is no single dominant carrier at Logan; American, US Airways, Delta and JetBlue account 

for approximately 14 percent to 18 percent of enplanements each. 

As a major airport in the national airspace system, Logan can experience significant delays and 

in fact is ranked as among the most congested airports in the United States (18th in 2009). 

Logan experiences minimal delays in good weather – when it can utilize three runways – but in 

poor weather (including low visibility, strong winds and/or heavy rain, snow or other 

precipitation), it typically loses the use of at least one runway, with the result that capacity drops 

and delays increase. Another source of delay is Logan’s location in the Northeast next to the 

heavily congested airspace of New York/New Jersey/Pennsylvania and Washington DC. 

Aircraft travelling to and from Logan need to be metered through this airspace. Moreover, 

because Logan is primarily an “origin and destination” airport (meaning that most passengers 

either begin or end their air travel itinerary at Boston, as opposed to “hub” airports at which 

passengers connect with other flights to reach their ultimate destination), aircraft serving Logan 

are more susceptible to air carrier network-related delays. 
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5.0 FACILITY DESCRIPTION

Logan occupies approximately 1,750 acres of land in East Boston and Winthrop, immediately to 

the east of the densely populated urban neighborhood of East Boston, and is surrounded on its 

other three sides by, respectively, Boston Harbor, Boston Inner Harbor and Winthrop Bay. 

Moreover, almost all of the available space at Logan is already occupied by existing airfield or 

landside activities. Approximately 80 percent of the site is used for runways, taxiways and 

related safety areas, aprons, and other aircraft operational purposes; the remainder is occupied by 

passenger and cargo terminals, access roads, and support infrastructure. A map of the airport 

showing these constraints is presented as Figure 1. 

Logan has six runways, although one of these (15L/33R) is less than 2,560 feet long and 

accounts for a minimal percentage of total runway usage (it is used primarily by general aviation 

(GA) aircraft). Of the remaining runways: 

 Runway 4L/22R is 7,861 feet long and accounts for 5.4 percent of arrivals and 31.5 

percent of departures; 

 Runway 4R/22L is 10,005 feet long and accounts for 45.6 percent of arrivals and 6.1 

percent of departures. 

 Runway 9/27 is 7,000 feet long and accounts for 31.9 percent of arrivals and 38.8 percent 

of departures. 

 Runway 15R/33L is a 10,083 foot runway that accounts for 15.7 percent of arrivals and 

23.7 percent of departures. 

 Runway 14/32 is 5,000 feet long and accounts for 1.4 percent of arrivals and 0.0 percent 

of departures. 

6.0 FLIGHT OPERATIONS AT LOGAN AIRPORT

According to Massport, a combination of weather patterns and space constraints at Logan make 

operations challenging, even during good weather. Due to the airport’s coastal location, wind 

direction is highly variable: 

 Winds most frequently blow from the northwest, about 37 percent of the time; 

 Winds from the southwest occur 28 percent of the time; 

 Winds from the northeast occur 18 percent of the time 

 Winds blow least frequently from the southeast, about 17 percent of the time. 

This necessitates a more complex airfield layout at Logan than at airports with less variable 

winds, because the runways at Logan cannot be constructed to operate primarily in a single 
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prevailing wind pattern; they must be oriented to provide significant capacity in essentially every 

direction. 

The fact that Logan’s land area is relatively small and limited to a peninsula, in combination with 

this weather-driven requirement to build runways that can operate in multiple wind patterns, has 

resulted in runways and taxiways that cross each other in many locations, as depicted in the 

Airport Diagram (Figure 2): 

 With the wind from the northwest, Logan uses Runways 27 and 33L for both departures 

and arrivals, and Runway 32 for arrivals. Runways 27 and 33L cross each other, and 

Runway 32 crosses through the safety zone for Runway 27. 

 With the wind from the southeast, Logan uses Runway 15R for both departures and 

arrivals, and Runways 9 and 14 for departures. Runways 15R and 9 cross each other. 

 With the wind from the southwest, Logan uses Runways 22R and 22L for departures, and 

Runways 22L and 27 for arrivals. Runways 22L and R 27 cross each other, and aircraft 

using those runways must cross Runway 22R (or its safety zone) going to or from 

terminals. 

 With the wind from the northeast, Logan uses Runways 4L and 4R for both departures 

and arrivals, and Runway 9 for departures. Again, Runways 4R and 9 cross, and aircraft 

using these runways must cross Runway 22R going to or from terminals. This operational 

pattern is particularly relevant to deicing operations since the wind comes from the 

northeast for many New England winter storms. 

Thus, even in the best conditions, runway operations at Logan are highly complex with varying 

traffic patterns depending on weather conditions. 

Furthermore, Logan is considered is delay prone when weather conditions deteriorate and result 

in loss of available runways due to visibility or winds. When the weather is good and three 

runways can be used for operations, capacity is adequate and airlines will experience minimal 

delays. However, when weather deteriorates Logan generally loses the use of one runway; 

capacity decreases and delays increase rapidly if this occurs. 

7.0 CURRENT AIRCRAFT DEICING/ANTI-ICING OPERATIONS

Two types of deicing operations are conducted at Logan from October or November through 

March or April: deicing of aircraft, and deicing of paved areas, including the runways, taxiways 

and ramp areas. Aircraft deicing occurs approximately 112 days per year during the typical 

deicing season, and weather conditions requiring deicing are not limited to snow, sleet and 

freezing rain events – deicing is very often required on cold, clear mornings to remove frost that 

has built up on aircraft overnight, in the absence of any precipitation. Deicing may be required if 

the air temperature is below approximately 38 to 40 degrees Fahrenheit, and might continue for 

several hours after a storm ends. 
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Aircraft deicing is the responsibility of the individual airlines and is conducted by the airline (or 

its contractors) or Logan’s sole fixed-base operator. The majority of aircraft deicing operations 

at Logan are performed at the gate by the airlines. In general, operations in the gate area require 

four to six vehicles per aircraft, including catering, baggage, fuel and lavatory services vehicles. 

Airlines performing gate deicing typically use two deicing trucks per aircraft (one on each side 

of the aircraft). As a result, deicing weather usually adds two more large vehicles to an already 

constrained work area. 

One airline, American Airlines, uses a glycol collection vehicle (GCV) during frost deicing 

events to collect ADF-containing stormwater, but does not typically use it during storm events. 

Massport itself does not own or operate GCVs. The airlines use Best Management Practices 

(BMPs) to reduce the amount of ADF sprayed on aircraft. Delta, for example, uses steam mixed 

with ADF. 

Some aircraft deicing is performed at an off-gate location, Juliet “Pad.” Juliet Pad is a paved 

area, adjacent to taxiway J at the western end of R 14/32, designed to be used for aircraft parking 

when Runway 14/32 is not in use. Development of Juliet Pad was initiated by US Airways to 

avoid gate constraints during poor weather/deicing conditions.. The area that is now Juliet Pad 

was paved when Massport built Runway 14/32; Massport anticipated that the area might be used 

for parking aircraft and therefore increased its pavement thickness. Two airlines use Juliet Pad 

for deicing, US Airways and Jet Blue. When possible, 100 percent of JetBlue’s deicing is done 

at Juliet Pad, although the wind direction in some storms precludes use of the pad for deicing. 

US Airways performs a variable percentage of deicing at Juliet Pad; in some storms, up to 80 

percent of its deicing may be performed at the pad. There is no collection in place at Juliet Pad 

and deicing runoff from the pad drains directly in to Boston Harbor. Juliet Pad cannot be used 

when Runway 14/32 is in use. 

Logan currently discharges stormwater – including stormwater containing deicing runoff – to 

Boston Harbor pursuant to a 2007 NPDES permit issued by EPA Region 1 to Massport and 

certain airlines as co-permittees. This permit required the development of a Storm Water 

Pollution Prevention Plan, including the design and implementation of BMPs aimed at the 

reduction of deicer use and deicing runoff discharges at Logan. The airline co-permittees 

developed responsive BMPs, and Massport submitted these BMPs to EPA along with a 

certification of permit compliance (which is done annually). Notably, nearly fifteen years of 

Boston Harbor water quality testing has found no evidence of water quality falling below 

established water quality standards during any deicing season for pollutants associated with 

deicer use (i.e., dissolved oxygen). These findings were most recently confirmed by the water 

quality study mandated by EPA in the current NPDES permit. 

Massport is responsible for snow removal around the gates and terminals. Snow, which contains 

an unknown amount of aircraft deicing fluid (ADF) overspray and runoff, is plowed away from 

the gates, collected and dumped into snow melters, which then discharge into the stormwater 

drainage system. Of the 13 in-ground snow melters, seven are on the airfield, two are for the 

west garage, four for the central garage, and four are for the south garage. 
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7.1 Potential Sites for Pad Deicing/Anti-Icing Operations

7.1.1 EPA-Identified Sites 

Massport indicated in its comments on the Proposed Rule that there would be major problems 

associated with trying to develop deicing pads within Logan’s existing footprint. EPA suggested 

that there were three sites that appeared to be potentially usable for pads: (1) Juliet Pad, in an 

expanded form, (2) Governors Island, and (3) the North Cargo area. These will be discussed in 

turn, and their locations are approximately indicated in Figure 3. 

In any event, it is unlikely that even a single deicing pad with sufficient capacity would be 

adequate to enable Logan’s compliance with both the Proposed Rule and applicable Federal 

Aviation Administration (FAA) requirements. As indicated in Figure 3, while Juliet Pad and/or a 

pad at Governors Island would be well-sited for operations in northeasterly winds, they would be 

poorly sited for operations in a southeasterly or southwesterly wind. Similarly, a pad in the 

North Cargo area would pose significant operational difficulties when winds are from the 

southwest or northwest. 

7.1.1.1 Juliet Pad 

There are a number of potential aviation safety and operational constraints that would make the 

expansion of Juliet Pad unsuitable for increased deicing operations. 

 Use of Juliet Pad – expanded or not – would be limited to times when Runways 14/32 

and 9/27 are not in use. Juliet Pad could not be used when Runway 14/32 is open 

because aircraft in deicing positions would violate FAA Runway Safety Area and 

Runway Object Free Area requirements. In most storms, Runway 14/32 is not in use 

because the wind is out of the northeast. However, as storms move through, wind shifts 

occur, and Logan may need to start using Runway 14/32 to maintain operational capacity; 

Juliet Pad cannot be used for deicing if Runway 14/32 is in use. In addition, vertical 

objects on an Expanded Juliet Pad would penetrate FAA “critical airspace surfaces” for 

Runway 9/27, so the pad could not be used when Runway 27 is active or when Runway 9 

is being used for arrivals. 

 Access to Juliet Pad would either require two-way traffic on taxiway J, or the use of 

Runway 14/32 as a taxiway, both of which create safety issues. 

 Because Runway 14/32 is an operational runway, deicing infrastructure cannot be 

installed at Juliet Pad; deicing would have to be performed there using portable 

equipment only, which would cause substantial logistical and delay problems. 

 Juliet Pad can currently be used for aircraft such as Boeing 737s and Airbus A320s, but 

not larger aircraft; taxiways do not provide sufficient clearance, nor is the pavement thick 

enough. Even with expansion, the pad would only be able to deice a limited number of 

larger aircraft; Logan expects only two of nine deicing positions at an expanded Juliet 

Pad would be usable for aircraft larger than FAA Design Group III (e.g., B-737, A320). 
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After the site visit was conducted, Boston Logan indicated that even if Juliet Pad were expanded, 

using it to deice 100 percent of aircraft would result in significant delays due to capacity 

limitations. Specifically, based on current Logan departure rates, patterns and fleet mix, deicing 

all aircraft at an Expanded Juliet Pad would result in total delays of 1,076 to 2,616 aircraft hours 

and 87,191 to 208,025 passenger hours annually. The total annual indirect cost of such delays 

would fall between $4.4 million and $10.5 million. At air traffic levels projected by the FAA for 

Logan for 2020, deicing all aircraft at an Expanded Juliet Pad would result in total delays of 

1,900 to 5,251 aircraft hours and 152,272 to 415,153 passenger hours annually. The annual 

indirect cost of such delays would be between $7.7 million and $21 million. The total indirect 

cost of these delays over the next ten years would be between $65 million and $167 million. 

7.1.1.2 Governors Island 

Governors Island is located in Logan’s southeast corner, between the approach ends of Runways 

4R and 32. Although the potential area available for deicing operations at Governors Island 

appears sizable on a map, the actual available space is much smaller due to the location of FAA 

Air Surveillance Radar to the east, Runway 4R/22L to the west, and Runway 32/14 to the south. 

Moreover, the use of the Governors Island site for deicing operations would interfere with the 

above-referenced FAA Air Surveillance Radar and with FAA-protected ground and airspace, and 

the location of the radar and runways places significant restrictions on the height of anything in 

the Governors Island area. Nothing in this area can exceed the height of the radar platform, 

which is about 20 feet off the ground at approximately the same elevation as the runways. Thus, 

it would be impossible to site a deicing pad here because the aircraft tails would exceed the 

height limit. 

There would be a potential for runway incursions due to the placement of runway and safety area 

crossings for aircraft and vehicles traveling to and from a pad on the Governors Island site., 

Also, access to the site could be difficult for deicing equipment. To reach the island without 

crossing any runways, vehicles would have to travel the perimeter road that starts in the vicinity 

of Juliet Pad. Drivers on the perimeter road require a special license and training. 

After the site visit was conducted, Boston Logan indicated that this area has been used to store 

spoil from the construction of the “Big Dig” (depression of Boston’s Central Artery) and is 

already close to the maximum elevation permitted by the radar. To use this area for a purpose 

such as storage of ADF-containing stormwater, Logan would first have to remove the Big Dig 

spoil material. 

7.1.1.3 North Cargo Area 

The North Cargo Area is located just south of the west end of Runway 15R/33L. As suggested 

by the name, this area is used for air cargo operations. Buildings marked 8, 9, 13, 16, and 92 on 

the map (Figure 3) are perimeter hangers for this area, while the building marked 10 is a recently 
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completed long-term parking garage. Under Logan’s latest master plan, this area is intended for 

significant development; Massport’s plan is to construct multiple hangars in this area, creating a 

“hanger row” between buildings 16 and 92 on the map. However, while Logan is currently 

rehabilitating hangers 8, 9, and 16, it appears there are no immediate plans for demolition of 

existing hangers and expansion of hanger row due to the economic downturn. The large area 

shaded gray just north of the cargo area and hanger 9 is the safety area for Runway 15R/33L, and 

therefore is not usable for deicing. 

While there appears to be some available space in the area for a potential deicing pad, this area is 

a cul-de-sac. Aircraft entering for deicing would need to perform a 180 degree turn to reach the 

taxiways and runways or be pushed backwards. In addition, due to noise restrictions, aircraft 

movements in this area would require a tug, as aircraft are not allowed to move under their own 

power. In short, the operational difficulties that would be involved in maneuvering aircraft to 

and from this location make it an unsuitable location for a centralized deicing pad. 

Additionally, airport staff indicated that the entrance to the North Cargo Area is too small to 

allow more than a single aircraft to enter or exit at a time. The entrance width is constrained by 

the location of Terminal E on one side and the safety area for Runway 15R/33L on the other 

side, and therefore cannot realistically be increased. 

7.1.2 Massport-Identified Sites for Pad Deicing 

After the site visit was conducted, Boston Logan indicated that in order to evaluate Logan’s 

ability to comply with both the Proposed Rule (under which the airport would be expected to 

collect and treat 60 percent of available spent ADF) and applicable Federal Aviation 

Administration (FAA) requirements, Massport retained a team of engineering consultants to 

evaluate the feasibility and cost of installing and operating centralized deicing pads at Logan. 

Specifically, Massport’s team undertook a set of studies to determine the number, size and 

location of deicing pads that might enable Logan to comply with both EPA and FAA 

requirements without reducing airport capacity during weather requiring deicing operations. The 

team concluded that (1) compliance with both EPA and FAA requirements would require three 

separate deicing pads, (2) the siting, construction and operation of three pads would not be 

feasible or affordable, and (3) even a one-pad compliance option – Expanded Juliet Pad – would 

not be feasible due to operational and space constraints. 

The location and size of the three theoretical deicing pads are approximated on Figure 4. One 

pad would be the Expanded Juliet Pad discussed above and shown on Figure 3. The other two 

pads would be located, respectively, north of Runway 15R/33L and west of Runway 22R/4L (the 

“North Pad”), and east of Runway 9/27 and south of Runway 15/R/33L (the “East Pad”). 

All the limitations described in Section 7.1.1 concerning Expanded Juliet Pad apply to this 

configuration. The problems with the North and East Pads are also apparent in Figure 4. To 

achieve the size and location necessary to maintain operations in all weather conditions, both 

pads would require filling approximately 160 acres of Boston Harbor at an estimated cost of 

$1.57 billion (excluding land purchase, environmental litigation, and permitting). On this basis, 

Massport concluded that deicing pads are not a feasible option.