MEMORANDUM 

TO: Brian D’Amico, USEPA/OW/OST/EAD 

FROM: Cortney Itle, ERG 

DATE: July 12, 2010 

SUBJECT: Summary of Alaskan Airports Comments 

In 2009, the U.S. Environmental Protection Agency proposed technology-based effluent standards for 

discharges from airport deicing operations. The Agency received multiple comments about Alaska (AK) 

airports and airlines; these comments were received from: 

 State of Alaska Department of Transportation and Public Facilities; 

 State of Alaska Department of Environmental Conservation, Division of Water, Wastewater 

Discharge Authorization Program; 

 Ted Stevens Anchorage International Airport; and 

 Alaska Airlines and Horizon Air. 

The purpose of this memorandum is to review and summarize comment issues that are specific to Alaskan 

airports and airlines. The main topics presented in each of the comments are summarized below. 

State of Alaska Department of Transportation and Public Facilities (EPA-HQ-OW-2004-0038-

1225.1) 

 AK airports have relatively high numbers of commercial aircraft departures. However, they 

use small amounts of aircraft deicing fluids (ADF) due to dry and cold climatic conditions. 

Therefore the aircraft departure thresholds in the rule will impact costs for small remote 

airports but will result in minimal environmental benefits. 

 Because of the remote nature of AK airports, they are generally prepped for individual flights 

and not continuous operations. Because of this, AK airports rely heavily on mechanical 

methods for runway deicing. 

 Some AK airports do not have airport traffic towers and do not track the number of 

departures. The threshold of 1000 jet departures per year should be raised to 2000 to avoid 

causing increased costs to small rural airports. 

 During some conditions, E-36 (potassium acetate) is used, although its effectiveness is 

limited by arctic temperatures. 

 EPA’s cost estimate of switching to alternatives to urea is underestimated, because of the 

need for large storage tanks, application vehicles, and transportation. Heated storage tanks 

with circulation capabilities are needed. Shipments may be required to travel by barge, which 

can only occur in summer months so storage tanks would need to hold a whole winter’s 

supply of potassium acetate. 
 Airports in Kotzebue (OTZ) and Nome (OME) currently use some potassium acetate because 

of their milder temperatures. 

 One AK airport currently holds an 8 year supply of urea. 

 FAA funds have been used to build urea processing plants at AK airports. 

State of Alaska Department of Environmental Conservation, Division of Water, Wastewater 

Discharge Authorization Program (EPA-HQ-OW-2004-0038-1230.1) 

 As noted in the comments from State of Alaska Department of Transportation and Public 

Facilities, the jet departure threshold should be adjusted to 2000 jet departures per year to 

reflect the conditions at rural airports. 

 At Ted Stevens Anchorage International Airport (ANC), the airlines apply and collect the 

ADF. The airlines should be permitted as well as the airport. 

 EPA should investigate the effectiveness and cost of alternative deicers in the arctic climate. 

 General comments on the rule were provided, including: 

o Available ADF should be defined. 

o EPA should study the chemicals and their toxicities in formulations of ADF. 

o The threshold of 460,000 gallons should be lowered to 400,000 gallons. 

o There should be a specific prohibition of discharge of ADF to the land. 

o Guidance is needed for military facilities. 

o For GRVs, requirements are needed for the description of operational coverage of the 

facility, a percentage of the time during deicing days that GRVs must be operated, and a 

requirement that all collected ADF is disposed of in a treatment facility. 

o EPA should consider a phased implementation of the rule. 

o EPA should develop guidance for the states on the environmental impacts or safety issues 

associated with alternative pavement deicers. 

o The rule should account for local safety and climatic conditions in determining the 25 

gallons per aircraft safety exemption. 

o EPA should consider limiting BOD and glycol. 

o The weekly average effluent limitation is better than the monthly average effluent 

limitation. 

o Runways should not be considered new sources, it would be difficult to enforce by the 

permitting authority. 

o The airports should be allowed to choose whether to have single or multiple deicing pads. 

Ted Stevens Anchorage International Airport (EPA-HQ-OW-2004-0038-1212.1) 

 The ban of urea will not necessarily reduce COD load because increased levels of potassium 

acetate are needed to maintain the same level of deicing that urea delivers. 

 General comments on the rule were provided, including: 

o Airports required to use a centralized pad should be allowed a lower cut off for the size of 

planes that are required to use it. 

o New source rule should only apply to new airfields and not to new runways at existing 

airfields. 
o Need to better define difference between "deicing fluid" and "anti-icing fluid". 

o Current rule does little to encourage the use of pollution prevention through alternate 

technologies. 

o Need to allow for separate or multiple permits at one airport. 

o Deicing pads will slow down capacity at ANC. 

o Estimated costs for ANC are incorrect (some specific operational information is 

provided). 

o The length of time after deicing that deicing pads be required to keep diversions in place 

is not specified. 

o The type of emulsifier is not specified. 

o GRV collection rates are not representative. 

o Air quality permits might be needed for treatment facilities and operating multiple GRVs. 

o Normalized ADF can be hard to determine based on information from manufacturer. 

o Snow removal and GRV operation on deicing pads will cause operational difficulties. 

o GRV is not defined. 

o Time frame to install pads must be flexible to allow coordination with other projects. 

o Potassium acetate may increase wear and oxidation on break pads. 

Alaska Airlines and Horizon Air (EPA-HQ-OW-2004-0038-1221.1) 

 Purchasing and operating GRVs at Bethel Airport (BET) would cost over $2.0 million 

dollars. This airport would collect approximately 1,000 gallons of deicing fluid each year in 

support of just two to three daily flights. 

 These requirements would affect other small airports, such as OME and OTZ. The high costs 

would result in very low amounts of COD reduction at each location and little environmental 

benefit. 

 EPA’s estimates for OTZ show costs less than the cost of one GRV unit. In addition, EPA 

estimates that Juneau (JNU), BET, and OME would need to purchase one GRV plus a portion 

of another GRV. GRVs can only be purchased in units of one and in remote locations such as 

AK, rental of GRVs is not an option. 

 The purchase and operation of a GRV at a small airport would represent a large percentage of 

the overall operating budget. 

 Many cities in AK do not have a local POTW, so the airports would need to collect and treat 

the glycol on-site. 

 At locations in arctic AK (such as BET), there is no stormwater to collect during the deicing 

season (October to March) because temperatures are rarely above freezing. Any ADF used 

becomes encapsulated in the snow and becomes runoff during the spring thaw. GRVs would 

not be effective in collecting ADF at these airports. 

 The collected ADF would need to be stored until a sufficient quantity was collected to treat. 

The treatment system would only be run occasionally and an AFB system would not be 

appropriate for these cases. 
 Due to the cost and impracticality of using ADF, AK airports would collect and store the 

stormwater for treatment in the lower-48 states. The construction of storage facilities and the 

cost of shipment are expected to be prohibitive. 

 EPA should establish a new minimum threshold of facilities that use less than 90,000 gallons 

of deicing fluid a year (instead of airports with greater than 1,000 jet departures). ATA has 

evaluated airport and ADF usage data and determined that a new threshold would have little 

impact on the rule because the Tier Two airports that are required to collect 20% account for 

only 1.7% of the ADF usage in the U.S. ATA’s arguments for the creation of a new tier 

would reduce economic and operational burden. 

 Urea provides benefit as a “back-up” deicer when other products are not available, 

particularly because of transportation issues in arctic areas. Urea can be shipped and stored 

more easily than liquid deicers. Closing down AK airports is not an option because they are 

often the only transportation available during winter months to ship in supplies. 

 Urea should be permitted as a “back-up” or severe weather deicer for AK airports to ensure 

that vital airport operations are not impacted by lack of liquid pavement deicers. 

 ANC is not included in the list of Tier One Airports, but according to recent airport reports 

the usage for the last 5 years averaged greater than 460,000 gallons. The costs of a deicing 

pad and treatment system at ANC would require that the costs would be over 5% of operating 

revenues, which exceeds the 3% revenue threshold established for economic achievability. 

EPA will have to re-evaluate the economic achievability analysis for deicing pads. 

 Airlines will be impacted economically by this rule and a Revenue Test or other means of 

assessing economic impact should be performed to determine if the rule is Economically 

Achievable. 

o Although airports will pay for many of the improvements, the costs will be covered 

(either directly or indirectly) by the airline carriers. The rule acknowledges this fact but 

does not consider the impact that these costs will have on airlines. 

o Alaska Airlines hold their own NPDES permits at each of the airports affected by this 

regulation and are not simply “co-permittees”. 

o JNU is owned and operated by the City/Borough of Juneau. Because the city does not 

have enough economic capacity to absorb the cost of new regulatory requirements, the 

majority of the costs would be passed to the airlines. 

o Some airport locations require airlines to own and operate GRVs and dispose of the 

collected stormwater. 

 During the winter months, air transportation is the only means of transportation into and out 

of many AK towns. Additional economic impacts could occur at the locations where airline 

service is essential.