VOLUNTARY AIRPORT LOW EMISSION PROGRAM

TECHNICAL REPORT

Version 7 

Office of Airports 

Airport Planning and Programming 

DOT/FAA/AR-04/37 Revised December 2, 2010
THIS PAGE INTENTIONALLY LEFT BLANK 
TABLE OF CONTENTS

VERSION CHANGES................................................................................................... viii

LIST OF ACRONYMS AND ABBREVIATIONS ....................................................... ix 

CHAPTER 1: INTRODUCTION 

1.1 Program Description ..................................................................................... 1-1 

1.2 Growing Airport Air Quality Responsibilities.............................................. 1-2 

1.3 Benefits of the VALE Program..................................................................... 1-3 

1.4 Agency and Industry Coordination............................................................... 1-4 

1.5 National Environmental Policy Act and Clean Air Act Considerations....... 1-6 

1.6 Airport Eligibility.......................................................................................... 1-7 

1.7 Associated FAA Programs............................................................................ 1-8 

1.7.1 Airport Improvement Program .................................................... 1-8 

1.7.2 Passenger Facility Charges Program ........................................... 1-8 

1.7.3 Inherently Low Emission Airport Vehicle (ILEAV) 

Pilot Program ............................................................................... 1-9 

1.7.4 FAA Emissions and Dispersion Modeling System (EDMS)....... 1-9 

1.8 Contents of this Report ............................................................................... 1-10 

CHAPTER 2: APPLICATION PROCEDURES 

2.1 Early Planning and Coordination with State Air Quality Agencies ............. 2-1 

2.2 Obtaining Technical Information and Resources to Design a Project.......... 2-2 

2.3 Project Application Phase............................................................................. 2-3 

2.3.1 Assembling a Project Proposal .................................................... 2-4 

2.3.2 State and EPA Review of Project Proposal ................................. 2-8 

2.3.3 FAA Funding Approval ............................................................... 2-9 

2.3.4 Format and Distribution of Final Project Proposal...................... 2-9 

2.4 Project Implementation Phase..................................................................... 2-10 

CHAPTER 3: FUEL ELIGIBILITY AND CHARACTERISTICS 

3.1 Eligible Fuels Criteria................................................................................... 3-1 

3.1.1 AIP Eligible Fuels........................................................................ 3-2 

3.1.2 PFC Eligible Fuels ....................................................................... 3-3 

3.2 Clarification of AIP Alternative Fuels Technology...................................... 3-3 

3.3 Relative Emission Benefits of Alternative Fuels.......................................... 3-5 

3.4 Fuel Characteristics....................................................................................... 3-6 

FAA VALE Program Technical Report Page i Version 7
3.4.1 Electricity..................................................................................... 3-6 

3.4.2 Compressed Natural Gas (CNG) and 

Liquefied Natural Gas (LNG)...................................................... 3-6 

3.4.3 Liquefied Petroleum Gas (LPG or Propane)................................ 3-7 

3.4.4 Hydrogen...................................................................................... 3-8 

3.4.5 Ethanol ......................................................................................... 3-9 

3.4.6 Methanol ...................................................................................... 3-9 

3.4.7 Coal-Derived Liquid Fuels ........................................................ 3-10 

3.4.8 Biodiesel .................................................................................... 3-11 

3.4.9 P-Series ...................................................................................... 3-12 

3.5 Proposed Alternative Fuels Evaluation Checklist....................................... 3-14 

CHAPTER 4: GENERAL VEHICLE ELIGIBILITY 

4.1 Expansion of Traditional Eligibility for Low-Emission Projects ................. 4-1 

4.2 Vehicle Types ............................................................................................... 4-2 

4.3 Airport Dedicated Vehicles .......................................................................... 4-2 

4.4 Vehicle Use................................................................................................... 4-2 

4.5 Useful Life for Typical Airport Vehicles...................................................... 4-3 

4.6 New Vehicles and Incremental Costs .......................................................... 4-4 

4.7 Vehicle Retrofit Technology......................................................................... 4-4 

CHAPTER 5: PROGRAM LOW-EMISSION STANDARDS FOR NEW 

VEHICLES 

5.1 Relationship of Federal Vehicle Emission Classes and VALE Low-Emission 

Categories ................................................................................................... 5-2 

5.2 On-road Program Low-Emission Standards ............................................... 5-4 

5.2.1 Vehicle Category 1 – On-road LDVs .......................................... 5-4 

5.2.2 Vehicle Category 2 – On-road MDVs ......................................... 5-5 

5.2.3 Vehicle Category 3 – On-road HDVs.......................................... 5-7 

5.3 Non-road Program Low-Emission Standards ............................................. 5-8 

5.3.1 Vehicle Category 4 – Non-road Spark-Ignition Vehicles ........... 5-8 

5.3.2 Vehicle Category 5 – Non-road CompressionIgnition Vehicles........................................................................ 5-10 

5.4 Summary of VALE Program Low-Emission Vehicle Standards ............. 5-11 

CHAPTER 6: INFRASTRUCTURE ELIGIBILITY AND FUEL FACILITY 

GUIDELINES 

6.1 Infrastructure Project Eligibility ................................................................. 6-1 

6.1.1 Refueling and Recharging Stations.............................................. 6-2 

Public Access............................................................................... 6-2 

FAA VALE Program Technical Report Page ii Version 7
6.1.2 Gate Electrification ...................................................................... 6-3 

6.1.3 Power Plants, HVAC Systems, and Generators........................... 6-3 

6.1.4 Underground Fuel Hydrant Systems............................................ 6-4 

6.1.5 Public Transit Projects at Airports............................................... 6-4 

6.2 Non-Eligible Activities ............................................................................... 6-4 

6.3 Cost-Sharing Factors................................................................................... 6-4 

6.4 Useful Life for Typical Airport Low-Emission Infrastructure ................... 6-5 

6.5 Fuel Facility Guidelines.............................................................................. 6-6 

6.5.1 Electric ......................................................................................... 6-6 

6.5.2 Compressed Natural Gas (CNG) ................................................. 6-7 

6.5.3 Liquefied Natural Gas (LNG)...................................................... 6-8 

6.5.4 Liquefied Petroleum Gas (LPG or Propane)................................ 6-9 

6.5.5 Ethanol (E85)/Methanol (M85) ................................................... 6-9 

6.5.6 Hydrogen...................................................................................... 6-9 

6.5.7 Biodiesel (B85-B100) ................................................................ 6-10 

CHAPTER 7: AIP AND PFC PROJECT ELIGIBILITY 

7.1 Funding ....................................................................................................... 7-1 

7.1.1 AIP Funding................................................................................. 7-1 

7.1.2 AIP Matching Funds.................................................................... 7-2 

7.1.3 PFC Funding ................................................................................ 7-3 

7.2 Timelines..................................................................................................... 7-3 

7.2.1 AIP Funding Timeline ................................................................. 7-3 

7.2.2 PFC Funding Timeline................................................................. 7-4 

7.3 Fuels............................................................................................................ 7-6 

7.4 Ownership................................................................................................... 7-6 

7.4.1 AIP Ownership Requirements ..................................................... 7-6 

7.4.2 PFC Ownership Requirements..................................................... 7-8 

7.4.3 Combined Project Funding and Ownership................................. 7-8 

7.5 Enforceable Agreements............................................................................. 7-9 

7.5.1 Lease Agreements for Program Vehicles and Equipment ......... 7-10 

7.5.2 Agreements for Tenant-Owned Vehicles and Equipment ......... 7-12 

CHAPTER 8: AIRPORT PROGRAM RESPONSIBILITIES 

8.1 Vehicles to Remain at Airport for Useful Life ............................................. 8-2 

8.2 Equipment Labeling...................................................................................... 8-2 

8.3 Tracking and Monitoring Requirements....................................................... 8-3 

8.4 Replacement of Low-Emission Vehicles and Equipment 

for the Useful Life of the Project and AERCs .............................................. 8-4 

FAA VALE Program Technical Report Page iii Version 7
CHAPTER 9: ASSESSMENT METHODOLOGY 

9.1 Baseline and Project Conditions................................................................. 9-1 

9.1.1 Current Year Basis and Examples ............................................... 9-2 

9.1.2 Timeframe.................................................................................... 9-3 

9.1.3 Baseline Comparisons and Factors .............................................. 9-4 

“Old vs. New” Comparisons ...................................................... 9-4 

“New vs. New” Comparisons and Baseline Tables .................... 9-5 

9.2 EDMS Data Collection, Modeling and Reporting...................................... 9-9 

9.2.1 EDMS .......................................................................................... 9-9 

9.2.2 Data and Analysis 

Vehicles...................................................................................... 9-10 

Gate Electrification.................................................................... 9-11 

Boiler/HVAC Systems ................................................................ 9-13 

9.2.3 Emissions Reduction Report...................................................... 9-14 

9.3 Project Cost Effectiveness ........................................................................ 9-16 

9.3.1 Cost Considerations ................................................................... 9-16 

9.3.2 Cost Effectiveness Ranges ....................................................... 9-17 

9.4 Use of AERCs........................................................................................... 9-18 

FAA VALE Program Technical Report Page iv Version 7
Appendices 

A. Glossary of Terms 

B. Vision 100 – Century of Aviation Reauthorization Act 

 Section 121 Low-emission airport vehicles and ground support equipment 

 Section 151 Increase in apportionment for, and flexibility of, noise 

compatibility planning programs 

 Section 158 Emission credits for air quality projects 

 Section 159 Low-emission airport vehicles and infrastructure 

C. Special Conditions for AIP Grants and PFC Approvals 

D. Project Application Worksheets 

E. Project Tracking Worksheets 

F. FAA VALE Application Checklist

G. State Air Quality Agency AERC Letter of Assurance to the FAA 

H. Sample State Air Quality Agency AERC Statement with Sponsor Letter 

of Request 

FAA VALE Program Technical Report Page v Version 7
LIST OF TABLES

Table 3-1. Alternative Fuels Emissions Performance Relative to Conventional Fuels 

for Each Criteria Pollutant ....................................................................... 3-5 

Table 3-2. Fuel Characteristics................................................................................ 3-13 

Table 4-1. Average Useful Life of Typical Airport Vehicles ................................... 4-3 

Table 5-1. Federal Vehicle Emission Classes and Corresponding VALE On-road 

Categories ................................................................................................ 5-2 

Table 5-2. Summary of VALE Low-Emission Standards for New Vehicles ......... 5-12 

Table 6-1. Average Useful Life of Typical Airport Infrastructure............................ 6-6 

Table 6-2. Fueling Station Considerations.............................................................. 6-11 

Table 7-1. General Timeline of the AIP Funding Approval Process ........................ 7-4 

Table 7-2. General Timeline of the PFC Funding Approval Process for Use........... 7-5 

Table 7-3. Comparison of AIP and PFC Program Eligibility ................................... 7-7 

Table 9-1. “New vs. New” Baseline Emission Factors for Vehicle Category 1 ....... 9-6 

Table 9-2. “New vs. New” Baseline Emission Factors for Vehicle Category 2 ....... 9-6 

Table 9-3. “New vs. New” Baseline Emission Factors for Vehicle Category 3 ....... 9-7 

Table 9-4. “New vs. New” Baseline Emission Factors for Vehicle Category 4 ....... 9-7 

Table 9-5. “New vs. New” Baseline Emission Factors for Vehicle Category 5 ....... 9-8 

Table 9-6. Cost-Effectiveness Ranges..................................................................... 9-17 

Table 9-7. Example Application of NOx AERCs ................................................... 9-19 

FAA VALE Program Technical Report Page vi Version 7
LIST OF FIGURES

Figure 1-1. Illustration of Coordinated Effort for the VALE Program........................... 1-5 

Figure 2-1. Flow Chart of Project Application Phase..................................................... 2-4 

Figure 2-2. Flow Chart of Project Implementation Phase ............................................ 2-11 

Figure 8-1. Label for VALE Program-Funded Vehicles and Equipment....................... 8-3 

Figure 9-1. Format of EDMS ER Report ..................................................................... 9-15 

FAA VALE Program Technical Report Page vii Version 7
VERSION CHANGES

This version (Version 7) of the Technical Report should be used for VALE applications 

in FY 2011 and in subsequent years until the next published update of the guidance. 

Below is a list of important Version 7 additions to the Technical Report: 

1. Revised low-emission standards for heavy-duty on-road vehicles acquired through 

the VALE program. (Chapter 5) 

2. New guidance on the emission assessment procedures for gate electrification 

projects involving gate power and preconditioned air. Gate electrification projects 

are the among the most popular and cost effective airport low-emission strategies, 

with direct cost savings to the airlines. Sponsors are provided with detailed 

instructions for making baseline vs. project comparisons. (Chapter 9) 

3. Updated cost effectiveness ranges based on six years of VALE project experience 

and information obtained through the required competitive bidding process. The 

cost effectiveness ranges are an important factor in prioritizing VALE projects. The 

higher ranges were influenced by the trend toward cleaner and more fuel efficient 

vehicles and the costs of supporting infrastructure. (Chapter 9) 

4. Enhancements to the FAA Emissions and Dispersion Modeling System (EDMS) to 

improve the reporting of project emission calculations for VALE proposals and 

airport emission reduction credits. (Chapter 9) 

5. Additional statutory support for VALE airport emission reduction credit 

methodology through EPA April 2010 revisions to the Clean Air Act/General 

Conformity Rule. 

 

FAA VALE Program Technical Report Page viii Version 7
ACRONYMS AND ABBREVIATIONS

ADO Airports District Office 

AEE FAA Office of Environment and Energy 

AERC Airport emission reduction credit 

AERC Report Guidance on Airport Emission Reduction Credits for 

Early Measures through Voluntary Airport Low Emission 

Programs, developed by EPA and FAA 

AERCPP Airport Emission Reduction Credit Post Processor 

AFV Alternative fuel vehicle 

AIP Airport Improvement Program 

APP Airport Planning and Programming 

APU Auxiliary power unit 

AQ Air quality 

bhp Brake horse power 

CAA Clean Air Act, including all subsequent amendments 

CARB California Air Resources Board 

CI Compression-ignition or -ignited 

CNG Compressed natural gas 

DOE United States Department of Energy 

DOT United States Department of Transportation 

EDMS FAA’s Emissions and Dispersion Modeling System 

EIS Environmental Impact Statement 

EPA United States Environmental Protection Agency 

EPAct DOE Energy Policy Act of 1992 

EV Electric vehicle 

FAA Federal Aviation Administration 

FBO Fixed based operator 

FCV Fuel cell vehicle 

FFV Flexible-fuel vehicle 

GAO United States General Accounting Office 

GAV Ground access vehicle 

GSE Ground support equipment 

GVWR Gross vehicle weight rating 

HDDV Heavy duty diesel vehicle 

HDV Heavy duty vehicle 

hp Horse power 

Hz Hertz 

ICAO International Civil Aviation Organization 

ICE Internal combustion engine 

ILEAV Inherently Low Emission Airport Vehicle pilot program 

LDT Light duty truck 

LDV Light duty vehicle 

LEV Low emission vehicle 

FAA VALE Program Technical Report Page ix Version 7
FAA VALE Program Technical Report Page x Version 7

LNG Liquefied natural gas 

LPG Liquefied petroleum gas 

MDPV Medium duty passenger vehicle 

MOBILE6 EPA standard model for on-road vehicle emission factors 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act of 1969 

NGV Natural gas vehicle 

NMHC Non-methane hydrocarbons 

NMOG Non-methane organic gases 

NON-ROAD EPA’s off-road vehicle emissions model 

NPIAS National Plan of Integrated Airport Systems 

NSR New source review 

O&M Operations and maintenance 

OEM Original equipment manufacturer 

PC Passenger car 

PCA Preconditioned air (unit) 

PFC Passenger Facility Charge 

PM Particulate matter 

ppm Parts per million 

psi Pounds per square inch 

R&D Research and development 

RUL Remaining useful life 

SI Spark-ignition or ignited 

SIP State Implementation Plan 

SULEV Super ultra low emission vehicle 

TAF FAA’s Terminal Area Forecast

tpy Tons per year 

ULEV Ultra low emission vehicle 

ULSD Ultra low sulfur diesel 

USAF United States Air Force 

USC United States Code 

VALE Voluntary Airport Low Emission program 

VOC Volatile organic compound 

Vision 100 Vision 100 – Century of Aviation Reauthorization Act 

(Public Law 108-176) 
FAA VALE Program Technical Report Page 1-1 Version 7

CHAPTER 1 

INTRODUCTION

The Voluntary Airport Low Emission Program (VALE) is described in this chapter, 

including VALE program benefits, airport eligibility, agency and industry participants, 

applicable environmental regulations, and associated Federal Aviation Administration 

(FAA) programs. 

1.1 Program Description 

The Vision 100—Century of Aviation Reauthorization Act (Vision 100), signed into law 

in December 2003,1

 established a voluntary program to reduce airport ground emissions 

at commercial service airports in air quality nonattainment and maintenance areas.2

 The 

program is intended to help airport sponsors meet their obligations under the Clean Air 

Act and to assist regional efforts to meet health-based National Ambient Air Quality 

Standards (NAAQS). 

Vision 100 directs the FAA to issue this technical guidance report describing eligible 

airport low-emission activities and how airport sponsors (hereafter referred to as the 

“sponsor”)3

 should demonstrate program benefits. Developed in consultation with the 

U.S. Environmental Protection Agency (EPA) and the U.S. Department of Energy 

(DOE), this guidance discusses program eligibility for converting vehicles to alternative 

and clean conventional fuels and for 

implementing low-emission infrastructure 

improvements. 

To administer the Vision 100 airport 

emission provisions, the FAA created the 

VALE program in 2005. Participation in 

the VALE program is entirely voluntary for 

sponsors and State air quality agencies.4

 

1

 Public Law 108-176, Subtitle B-Passenger Facility Fees, Section 121 (Low-Emission Airport Vehicles 

and Ground Support Equipment); Subtitle C-AIP Modifications: Section 151 (Increase in Apportionment 

for, and Flexibility of, Noise Compatibility Planning Programs), Section 158 (Emission Credits for Air 

Quality Projects), and Section 159 (Low-emission Airport Vehicles and Infrastructure). 2

 49 U.S.C. §§ 40117, 47139 and 47140. 

3

 Airport “sponsors” are planning agencies, public agencies, or private airport owners/operators that have 

the legal and financial ability to carry out the requirements of the AIP program. The term is also used in 

this document to refer to the PFC program, which is restricted to “public agencies.” 4

 Includes delegated district, local, and Tribal air quality agencies. 

The goal of the VALE program is to 

help airport sponsors improve air 

quality in conjunction with regional 

efforts to meet health-based 

National Ambient Air Quality 

Standards. 
FAA VALE Program Technical Report Page 1-2 Version 7

The goal of the VALE program is to reduce the amount of regulated pollutants and other 

harmful air emissions generated by ground transportation sources at airports. To achieve 

this goal, the program provides sponsors with financial and regulatory incentives to 

increase their investments in proven low-emission technology. The program also 

supports U.S. energy independence by emphasizing domestically produced alternative 

fuels that are substantially non-petroleum based. Thus, sponsors are encouraged to 

purchase alternative fuel vehicles (AFVs) and equipment that are suited to the airport 

environment. 

Funding for the VALE program is provided through two airport assistance programs, the 

FAA Airport Improvement Program (AIP), which provides grants to airports from the 

Aviation Trust Fund, and the Passenger Facility Charges (PFC) program, which approves 

locally imposed fees from airline passengers for eligible airport development. These 

programs offer substantial resources to airports for low-emission activities but only if 

such activities represent a higher priority for the airport than other needed airport 

development. 

The VALE program also provides an important regulatory incentive to complement FAA 

capital investments. In accordance with Vision 100, the EPA issued national guidance in 

September 2004 on how airports can receive airport emission reduction credits (AERCs) 

for VALE projects and apply those credits to future airport projects to meet certain CAA 

requirements. This EPA guidance was developed in consultation with the FAA and is 

provided to airport sponsors and States in the document, “Guidance on Airport Emission 

Reduction Credits for Early Measures Through Voluntary Airport Low Emission 

Programs” (hereafter referred to as the “AERC Report”). Under Vision 100, the FAA 

may not approve AIP or PFC funding for VALE projects without a State AERC Letter of 

Assurance5

 that commits to granting appropriate AERCs to the sponsor. 

The eligibility guidelines, requirements, and procedures for the VALE program are based 

on the Vision 100 enabling legislation, the Clean Air Act, and established AIP and PFC 

program regulations. As with other eligible airport activities, the VALE program is 

focused on capital improvement projects and the deployment of proven, cost effective 

technology that is commercially available and no longer in the research and development 

(R&D) stage. 

1.2 Growing Airport Air Quality Responsibilities 

Air quality has emerged as an important environmental issue for transportation and 

aviation planning in the U.S. and around the world. The FAA and the airport community 

recognize that controlling airport emissions and meeting Federal and State air quality 

requirements are essential to the continued growth and improvement of public aviation. 

Aviation continues to be a fast growing sector of the national transportation system and a 

vital link in the national economy. The civil aviation sector provides 11 million jobs and 

 

5

 The recommended AERC Letter of Assurance is provided in Appendix G. 
FAA VALE Program Technical Report Page 1-3 Version 7

represents over one trillion dollars of economic activity, or about 10 percent of the U.S. 

gross domestic product.6

The aviation community is making substantial headway in addressing national air quality 

concerns through efforts like the VALE program, despite the fact that airports are a 

relatively small source of overall regional emissions. The combined emissions from 

aircraft and ground support equipment (GSE) typically represent approximately 3 to 5 

percent of emissions regulated under State Implementation Plans (SIP) nationwide, 

compared to other surface transportation sources (40 to 60 percent), and other point and 

area sources (another 40 to 60 percent). Despite aviation’s relative influence on air 

quality, the aviation community knows that improving air quality is a regional problem 

that requires a collaborative effort by the States, industry, vehicle manufacturers, and 

transportation agencies. 

1.3 Benefits of the VALE Program 

The voluntary VALE program provides opportunities for all participants. Sponsors, the 

FAA, and State air quality agencies benefit from the program’s focus on early and 

accelerated airport emission reductions. For airports, which are changing and responding 

to a dynamic aviation industry, the VALE program offers increased financial and 

regulatory support as sponsor’s plan for the future and seek to balance growing public 

demand for airport services with environmental protection. 

Sponsors have the opportunity to obtain AIP and PFC funding through the VALE 

program to achieve earlier and larger emission reductions. The program also provides 

useful airport planning tools to reduce uncertainty. For example, VALE-generated 

AERCs can be used on future airport development projects to satisfy general conformity 

and new source review (NSR) requirements under the CAA. Specifically, a sponsor can 

apply AERCs to an airport terminal or runway project as “design measures” to keep 

project emissions below general conformity de minimis levels and thereby avoid a 

general conformity determination (see Chapter 9). 

States have the opportunity to realize the environmental and public benefits of early 

reductions in airport emissions in exchange for granting AERCs to airport sponsors. 

Further, the VALE program helps all parties and the environment by: 

 Facilitating dialog between airport sponsors and air quality agencies 

 Expediting the environmental review process for airport projects 

 Encouraging better identification and control of airport emission sources 

In addition to environmental benefits, the VALE program may also lead to economic 

benefits for airports. Current evidence suggests that cleaner-burning alternative fuels and 

 

6

 DOT Future of Aviation Advisory Committee (FAAC) Sustainable Alternative Fuels Briefing Paper, 

August 2010; DRI-WEFA, Inc., in collaboration with the Campbell-Hill Aviation Group, Inc., The 

National Economic Impact of Civil Aviation, July 2002. 
AFVs are effective life-cycle investments. The higher capital costs to purchase AFVs are 

generally offset in a few years by their lower operations and maintenance (O&M) costs. 

The prevailing view is that the AFV market is constrained primarily by the lack of 

refueling infrastructure – a need that is addressed by the VALE program. 

1.4 Agency and Industry Coordination 

The FAA consulted with many agencies and organizations in the process of developing 

the VALE program (see Figure 1-1). The DOE Clean Cities Program provided 

information on alternative fuels and fuel station requirements. The EPA provided 

essential support in several areas: a) identification of airports in nonattainment or 

maintenance areas; b) vehicle low-emission standards; and c) AERC guidance. These 

agencies have an ongoing role in helping the FAA to manage the VALE program and to 

maintain the program low-emission standards. 

In addition, numerous aviation and fuel industry associations provided technical 

suggestions, many of which were incorporated into this guidance. The FAA also relied 

on State air quality agencies, original equipment manufacturers (OEMs), energy 

companies, and environmental organizations to help achieve a realistic balance between 

forward-looking emission standards and the commercial availability of cost effective 

low-emission technology. 

FAA VALE Program Technical Report Page 1-4 Version 7
Figure 1-1. Illustration of Coordinated Effort for the VALE Program 

FAA 

Airports Office 

VALE Program 

Airport Improvement 

Program (AIP) 

Passenger Facility Charges 

(PFC) 

Alternative Fuels 

Project 

Participation 

FAA 

Program 

Experience 

Quantification 

Tools 

FAA Emissions and 

Dispersion Modeling 

System (EDMS) and 

EPA emissions 

methodologies

Regulatory 

Incentive 

Program 

 low-emission 

vehicle 

standards

Airport emission 

reduction credits 

(AERCs)

Emission 

Standards 

Airport 

Eligibility 

Verification of 

airports in 

nonattainment 

and maintenance 

areas

FAA Office of 

Environment and 

Energy (AEE) 

Airport Sponsors, 

State Air Quality 

Agencies, Industry, 

and the Public 

U.S. Department 

of Energy 

(DOE) 

VALE 

Project 

Applications 

U.S. Environmental 

Protection Agency 

(EPA) 

FAA VALE Program Technical Report Page 1-5 Version 7
FAA VALE Program Technical Report Page 1-6 Version 7

1.5 National Environmental Policy Act and Clean Air Act Considerations 

Two major Federal environmental regulations are associated with airport air quality 

concerns – the National Environmental Policy Act of 1969 (NEPA) and the Clean Air 

Act and its Amendments (CAA). NEPA ensures that Federal actions are considered 

carefully for their potential environmental effects and gives citizens and public officials 

an opportunity to comment on proposed projects before Federal decisions are made and 

projects begin. To meet its NEPA responsibilities, the FAA has issued agency 

procedures for NEPA implementation under Order 1050.1E, Environmental Impact: 

Policies and Procedures.

7

 This FAA Order describes how the agency adheres to 

environmental laws and addresses specific impact areas, including noise, air and water 

quality, wetlands, wildlife protection, and historic preservation. 

Given the potential for VALE projects to permanently improve air quality, environmental 

review of VALE projects is expected to be routine. Under general conformity, VALE 

projects are “presumed to conform” and are therefore exempt from further conformity 

evaluation.8 Under NEPA, VALE projects are considered to be separate Federal actions 

with “independent utility” and may be approved without regard to other airport 

development projects. Many types of VALE projects can be “categorically excluded” if 

there are no “extraordinary circumstances” associated with the project.9 

Voluntary emission reductions through the VALE program must be above and beyond 

the existing mitigation commitments made by airport sponsors in environmental 

documents for NEPA, CAA, or agency agreements. For example, if the sponsor has 

completed an Environmental Impact Statement (EIS) and the FAA Record of Decision 

has been signed with air quality commitments, the VALE program cannot be used to fund 

these requirements because it is a voluntary program for additional or surplus 

reductions.10

Under the specific mandates of the CAA, airport development is primarily subject to two 

air quality regulations: general conformity and NSR. The conformity provisions protect 

the public health by ensuring that airport development plans do not interfere with the 

State’s ability to bring designated nonattainment areas into full attainment with the 

NAAQS. Airports can be located in nonattainment or maintenance areas for one or more 

of the six criteria pollutants listed below. 

 Ground level ozone (O3) 

 Carbon monoxide (CO) 

 Particulate matter (PM10 and PM2.5) 

 Nitrogen dioxide (NO2) 

 Sulfur dioxide (SO2) 

 

7

 Federal Register. Volume 69, No. 115, pp. 33778-33822. June 16, 2004. 

8 Federal Presumed to Conform Actions Under General Conformity, Federal Register Notice, July 30, 

2007, Vol. 72, No. 145, pp. 41565-41580. 

9

 FAA Order 5050.4B, Table 6-2. 

10 Apart from the VALE program, documented environmental mitigation requirements may be eligible for 

AIP or PFC funding (see Chapter 7 and AIP Handbook, Order 5100.38C, Section 585). 
FAA VALE Program Technical Report Page 1-7 Version 7

 Lead (Pb) 

For the purposes of the VALE program, “Level One” pollutants are the criteria 

pollutant(s) or designated precursors that cause the nonattainment or maintenance status 

of the region surrounding the airport. “Level Two” pollutants are the remaining criteria 

pollutants that do not contribute to an area’s nonattainment or maintenance status. 

A description of each criteria pollutant is provided in the glossary in Appendix A. Little 

to no lead (Pb) in the conventional and alternative fuels used at commercial service 

airports makes the evaluation of Pb emissions unnecessary for this program. 

The focus of general conformity regulations and the VALE program is on local air 

quality and criteria pollutants. However, consequential reductions in greenhouse gas 

emissions achieved through implementation of VALE projects will also help to mitigate 

global climate change. 

1.6 Airport Eligibility 

To be eligible for the VALE program, an airport must be a commercial service airport 

listed in the FAA’s National Plan of Integrated Airport Systems (NPIAS) and located in 

an EPA-designated nonattainment or maintenance area for one or more of the criteria 

pollutants listed above.11 The FAA, in cooperation with the EPA, prepared a list of 

eligible airports, which is available on the FAA VALE website.12 Sponsors are 

encouraged to contact their State air quality agency for further information or verification 

of their nonattainment or maintenance status. 

Approximately one-third of U.S. commercial service airports, including many of the 

nation’s largest and busiest, are located in EPA-designated nonattainment or maintenance 

areas. Recent changes to the NAAQS have increased the number of airports in 

nonattainment areas. Consequently, more sponsors must perform detailed conformity 

evaluations and plan for the possibility of emission reduction measures. 

Airports are naturally suited to manage emissions from stationary and ground 

transportation sources because of their centralized operations and design. Airport fleets, 

especially GSE, operate primarily, if not exclusively, on airport property. In addition, 

vehicle refueling and recharging stations can often be sited safely and conveniently at 

airports. On the other hand, sponsors have little ability or authority to control aircraft 

emissions. U.S. aircraft emission standards are established by the EPA within an 

international framework administered by the International Civil Aviation Organization 

(ICAO). In addition, aircraft and engine manufacturers require long lead-times to design 

new aircraft engines and must consider numerous factors, including aircraft safety, 

performance, fuel efficiency, noise, and cost. 

 

11 49 U.S.C. §§ 40117, 47139, and 47140. 

12 http://www.faa.gov/airports/environmental/vale. 
1.7 Associated FAA Programs 

The VALE program expands the traditional eligibility of low-emission airport technology 

under the AIP and PFC programs, for instance, by increasing eligibility for mobile 

emission sources. 

It is important to note that project eligibility varies between the two FAA airport funding 

programs in several important respects. Sponsors should consider these funding 

distinctions in planning their VALE projects and in selecting the most appropriate 

funding source or combination of sources to support them (see Chapter 7 on AIP and 

PFC project eligibility requirements). 

1.7.1 Airport Improvement Program 

As authorized by Title 49 U.S.C. Chapter 471 as amended and Public Law 103-

272, the objective of the AIP is to assist sponsors, owners, or operators of publicuse airports in developing a nationwide system of airports adequate to meet the 

needs of civil aeronautics. The forms of assistance to airport sponsors are 

primarily monetary grants, and may also include advisory services and 

counseling. AIP grants are made to eligible sponsors for airport planning and 

development, which includes activities to construct new public airports; improve 

and rehabilitate infrastructure; extend runways; purchase firefighting, rescue, 

security, and snow removal equipment; and install navigation aids. 

Environmental activities under the AIP include the preparation of environmental 

documents and coordination with local and regional authorities on land use 

planning. 

Regulations, guidelines, and literature governing the use of AIP grants are 

provided in FAA Orders and Advisory Circulars (FAA Order 5100.38C, Airport 

Improvement Program Handbook as amended, and FAA Advisory Circulars in 

the 150/5100 series). More information on the AIP is available through the FAA 

website: www.faa.gov/. 

1.7.2 Passenger Facility Charges Program 

The PFC program is authorized by 49 U.S.C. Subtitle VII, Part A – “Air 

Commerce and Safety”, Section 40117. This statute was implemented by the 

Aviation Safety and Capacity Expansion Act of 1990, which amended the Federal 

Aviation Act of 1958, to remove the restriction against imposition of a PFC. The 

statute authorizes the Secretary of Transportation to allow a public agency that 

controls at least one commercial service airport to impose a fee for each paying 

air carrier passenger enplaned at the airport. This revenue finances PFC program 

FAA VALE Program Technical Report Page 1-8 Version 7
eligible airport projects to be carried out at the commercial service airport or any 

other airport that the public agency controls. 

The FAA may grant authority to impose a PFC only if the FAA finds, on the basis 

of an application submitted by the public agency, that the amount and duration of 

the PFC collection will not result in excess revenues and the proposed project(s) 

is: eligible; meets at least one PFC objective or significant contribution finding; 

and is adequately justified. Air carriers and their agents are required to collect 

PFCs imposed by public agencies and must remit those charges, less an FAAauthorized administrative fee, in a timely manner. In addition, the PFCs collected 

by the carrier must be noted on the passenger's ticket. More information about the 

PFC program is available through the FAA website: www.faa.gov/. 

1.7.3 Inherently Low Emission Airport Vehicle (ILEAV) Pilot Program 

The ILEAV pilot program preceded the VALE program and provided a model for 

design and development of the VALE program. Authorized under the Wendell H. 

Ford Aviation Investment and Reform Act for the 21st Century (AIR-21), the 

ILEAV pilot program operated from 2001 to 2005. Ten public use airports were 

awarded individual grants of up to $2 million to demonstrate the benefits and 

economic feasibility of low-emission vehicles and supporting infrastructure. 

Participating sponsors used ILEAV grants to purchase and evaluate mobile and 

stationary low-emission technologies that are applicable to the airport 

environment. The pilot projects also provided useful information about the 

environmental and economic trade-offs of alternative fuels, their safe handling, 

and the commercial availability of low-emission technology. 

The emission reductions that continue to be achieved by ILEAV pilot projects are 

eligible for AERCs provided through the VALE program. ILEAV pilot projects 

are the only prior airport activities that qualify for VALE AERC consideration. 

1.7.4 FAA Emissions and Dispersion Modeling System 

The FAA Office of Environment and Energy (AEE) develops and maintains the 

Emissions and Dispersion Modeling System (EDMS). The FAA created EDMS 

in the mid-1980s in cooperation with the United States Air Force. The model has 

become increasingly sophisticated over time and offers the ability to perform 

emission inventories and dispersion analyses for all of the major emission sources 

in the airport environment. These sources include aircraft engines, auxiliary 

power units (APUs), GSE, ground access vehicles, training fires, and stationary 

sources such as boilers and bulk liquid storage tanks. 

FAA VALE Program Technical Report Page 1-9 Version 7
FAA VALE Program Technical Report Page 1-10 Version 7

EDMS is the FAA required model for assessing aviation emission sources at 

airports and is recognized by the EPA.13 Under the VALE program, sponsors are 

required to begin their projects using the latest version of EDMS. The output 

reports from the model are an integral part of the initial VALE application and the 

sponsor’s application for AERCs from the State air quality agency. 

AEE continues to improve EDMS to meet evolving VALE program requirements 

for accurate quantification and reporting of project emission reduction benefits. 

More information about EDMS and the emissions assessment process is contained 

in Chapter 9. 

1.8 Contents of this Report 

The following chapters of this report explain the process, eligibility, and technical 

requirements of the VALE program. Chapter 2 presents the application steps for 

sponsors to follow in applying for VALE program funds. Chapter 3 addresses fuel 

eligibility requirements and offers information on the technical and emission trade-offs of 

alternative fuels. Chapter 4 discusses general vehicle eligibility issues. Chapter 5

presents the program low-emission standards that new vehicles must meet to be eligible 

for the VALE program. Chapter 6 discusses the eligibility for infrastructure projects and 

fuel facility guidelines. Chapter 7 describes the different eligibility requirements of the 

AIP and PFC programs. Chapter 8 outlines airport program responsibilities and the 

special conditions for participation. And Chapter 9 provides the required assessment 

methodology for emission reduction estimates, AERC use, and project cost effectiveness. 

This report has eight appendices. Appendix A is the Glossary of Terms. Appendix B

provides the sections of Vision 100 that apply to the VALE program. Appendix C lists 

the “special conditions” in the VALE program for AIP grants and PFC funding 

approvals. Appendices D and E offers sample worksheets for project applications and 

project tracking, respectively. Appendix F provides a project checklist for FAA 

personnel to use in reviewing VALE project applications. Finally, Appendices G and H 

contain examples of AERC documentation. Appendix G shows a recommended AERC 

Letter of Assurance from a State air quality agency to the FAA, and Appendix H provides 

an approved AERC Statement that a State air quality agency issued to a participating 

sponsor.

 

13 U.S. Environmental Protection Agency, Guidelines on Air Quality Models (Revised) with Supplements A 

and B, EPA-450/2-78-027R, O.A.Q.P.S., Research Triangle Park, NC, July 1, 1997. Codified in 40 CFR 

Part 51, Appendix W. 
FAA VALE Program Technical Report Page 2-1 Version 7

CHAPTER 2 

APPLICATION PROCEDURES

This chapter describes how sponsors should plan their project, locate needed technical 

resources, and construct their project application to obtain funding approval from the 

FAA and AERCs from the State air quality agency. Application procedures for the 

VALE program are based on statutory and airport program requirements and have been 

simplified as much as possible to help the sponsor. 

2.1 Early Planning and Coordination with State Air Quality Agencies 

The VALE program requires an AERC Letter of Assurance from the State air quality 

agency prior to FAA project approval and funding.14 Therefore, sponsors should discuss 

their project proposals for reducing emissions with their State air quality agency in 

advance of developing their formal project application. The State agency can be helpful 

in a number of ways, beginning with verification of the nonattainment or maintenance 

status of an airport area. The State air quality agency can also provide information about 

appropriate emission reduction strategies, available alternative fuels, and examples of 

similar activities in the State or region. 

The benefits of early coordination with the State air 

quality agency include better understanding of 

mutual goals and responsibilities, access to 

available resources, and development of the 

organizational relationships that can facilitate 

timely and constructive State and EPA reviews. 

Early meetings with the State air quality agency 

also provide an opportunity to discuss how the sponsor will show that proposed emission 

reductions are quantifiable, surplus, Federally enforceable, permanent, and adequately 

supported.15

The sponsor also needs to inquire about the relationship, if any, of the proposed project to 

the State Implementation Plan (SIP) and to discuss any previous air quality commitments. 

States may choose to manage the sponsor’s early reductions independent of the SIP or to 

incorporate these protected airport measures into the SIP through various means. 

 

14 FAA funded voluntary low emission airport projects must receive AERCs. The AIP Handbook, FAA 

Order 5100.38C, Sections 580 and 585 (“Low Emission Systems” and “Other Air Quality Projects”) 

describes the difference between required “mitigation” projects and voluntary “stand-alone” projects. For 

further information, refer to 14 CFR Part 158 (PFC) and to Chapter 7 of this report on AIP and PFC project 

eligibility. 

15 Emissions reduction criteria are defined in EPA “Guidance on Airport Emission Reduction Credits for 

Early Measures through Voluntary Airport Low Emission Programs,” 2004. 

Early coordination between 

the airport sponsor and the 

State air quality agency is 

essential. 
Because SIP revisions take considerable time, the State air quality agency should defer a 

decision on SIP inclusion until after FAA approvals and implementation of the project. 

In doing so, the State air quality agency can submit its AERC Letter of Assurance (see 

Appendix G) to the FAA on a timely basis. Time is needed also because some changes 

to the project are likely to occur between the application period and actual 

implementation. 

2.2 Obtaining Technical Information and Resources to Design a Project 

Sponsors should begin by exploring eligible low-emission technologies and the best 

options to meet their operational needs. Sponsors may want to investigate information 

about certification of low-emission vehicles, the reliability of equipment and 

manufacturers, the availability of fuels, and relative costs. Depending on the project, 

sponsors should consider obtaining technical support to help with fact-finding, project 

formulation, and the required emissions analysis. 

In addition to the information provided in this report, the sponsor may want to obtain 

information from outside sources. Numerous government agencies and private 

organizations are available to provide assistance in developing a VALE project. 

One resource for sponsors may be the local coordinator for the DOE Clean Cities 

Program, which was established by the DOE Energy Policy Act (EPAct) of 1992. Many 

Clean Cities Coalitions exist in metropolitan areas across the nation to work with 

operators of AFV fleets and with fuel providers who are building refueling infrastructure. 

Most of the local coalitions are located in areas that have been classified as air quality 

nonattainment regions. In addition to coordinating activities among AFV stakeholders 

(manufacturers, fleet users, fuel and service providers, government partners, etc.), the 

Clean Cities Program also provides grants and specialized technical assistance to help 

reduce the cost of purchasing AFVs and refueling infrastructure through state energy 

programs. More information about the Clean Cities Program and its local coordinators is 

available at the DOE Clean Cities website. 

Another resource group is experienced airport sponsors. Contact information for 

sponsors that have received VALE grants is provided on the FAA VALE website: 

www.faa.gov/airports/environmental/vale. 

In addition, many sponsors have extensive experience in developing and managing lowemissions projects. Among these sponsors are the Massachusetts Port Authority (Boston 

Logan International Airport), Los Angeles World Airports (Los Angeles International 

Airport), the Port of Seattle (Seattle-Tacoma International Airport), the Dallas/Fort Worth 

International Airport Board (Dallas/Fort Worth International Airport), the City and 

County of Denver (Denver International Airport), and the Port of Portland (Portland 

International Airport). 

FAA VALE Program Technical Report Page 2-2 Version 7
2.3 Project Application Phase 

Following initial fact-finding and coordination with the State air quality agency, the 

sponsor can begin to assemble a project application for FAA, State, and EPA review. 

Figure 2-1 graphically depicts the application process for FAA funding of VALE 

projects. The process consists of the following steps: 

1. Sponsor notifies FAA regional office of intent to submit a VALE project as 

early as possible for inclusion on the FAA Airports Capital Improvement Plan 

(ACIP). 

 

2. Sponsor assembles a draft project proposal (see Section 2.3.1 below) and 

submits it to the FAA. Early consultation with FAA regional offices on 

project scope and eligibility is strongly recommended. 

3. Sponsor submits a revised draft proposal to the State air quality agency when 

project components and emissions calculations are fixed. (Copies of the draft 

should be sent to the FAA for information and to the EPA for concurrent 

review.) It is recommended that this submission occur no more than 45 days 

before the exact amount of the grant request is known and the final project 

proposal is submitted to the FAA. 

4. State air quality agency issues an acceptable AERC Letter of Assurance to the 

FAA (see Appendix G).

5. Sponsor confirms eligible costs with the FAA and submits the final proposal 

to the regional Airports program office and to APP-400. 

6. FAA project approval. 

FAA VALE Program Technical Report Page 2-3 Version 7
Figure 2-1. Flow Chart of Project Application Phase 

 

 

FAA approves Documents

funding of

proposed measures.

Sponsor assembles

 project proposal

State Air Quality Agency 

 issues AERC Letter 

of Assurance to FAA 

with copy to the sponsor

Sponsor submits proposal 

to FAA for funding eligibility

and to State Air Quality Agency

(& EPA) for AERC review 

Actions

2.3.1 Assembling a Project Proposal 

The project proposal does not need to be lengthy or complex but it must contain 

all of the necessary application information discussed below. To make this 

process efficient, the FAA strongly encourages the sponsor to read this Technical 

Report and the AERC Report completely prior to assembling a proposal. 

The sponsor’s project proposal should contain the main narrative containing the 

nine sections described below and four or five appendices. Proposal Appendix A 

is the EDMS ER Report(s) followed by the project application worksheets shown 

in Appendix D of this report and available for use from the VALE website. 

Proposal Appendix B is a representative summary of EDMS data inputs. 

Appendix C is the AERC Letter of Assurance from the State air quality agency. 

Appendix D is the supporting technical and cost information. If applicable, 

Appendix E is supporting leases, tenant letters, and other documentation assuring 

the FAA that VALE special conditions will be met for tenant-operated vehicles 

and equipment. 

FAA VALE Program Technical Report Page 2-4 Version 7
Project Proposal Main Narrative

Section 1: Project Information 

Title information for the application must include the project title, airport threeletter code, airport name, airport sponsor’s name, and two airport contacts with 

their addresses, telephone numbers, fax numbers, and e-mail addresses. 

Section 2: Description of Proposed Emission Reduction Measures 

This section should be a clear and complete description of the project, containing 

as much detailed information as possible. Information must include, but is not 

limited to: 

 Numbers and types of proposed vehicles and equipment. 

 Owner of each proposed vehicle or unit of equipment. 

 Whether proposed new vehicles and equipment would displace 

existing vehicles and equipment or whether the new vehicles would be 

purchased instead of other new equipment that is conventionally 

fueled or higher emitting. 

 Project participants, including airlines, other airport tenants, utility 

companies, State and local governments, etc. 

 Graphics on project location and pictures of proposed equipment. 

 Project cost information, including total cost, Federal AIP or PFC 

share, and if AIP, how the required local match will be financed. 

 Project need for airport leases or enforceable commitments. 

Section 3: Emission Reduction Estimates 

The sponsor should quantify the expected emission reductions from the project in 

tons per calendar year per criteria pollutant. The timeframe for these calculations 

is determined by the useful life of project vehicles and equipment and may be 

extended in some cases if the sponsor agrees to replace VALE vehicles and 

equipment in the future with equivalent low-emission units. The sponsor must 

cite and justify any supplemental methods or computer models used to derive 

baseline and project estimates. 

Section 4: Confirmation that Estimated Emission Reductions Meet CAA 

Criteria 

The sponsor should refer to Chapter 3 of the AERC Report when preparing the 

discussion of criteria: 

Section 4.1 Quantifiable 

Section 4.2 Surplus (see Section 5 below) 

Section 4.3 Federally Enforceable 

Section 4.4 Permanent 

Section 4.5 Adequately Supported

This section of the proposal provides the State air quality agency with 

confirmation that CAA criteria will be met. For example, the discussion in 

FAA VALE Program Technical Report Page 2-5 Version 7
Section 4.5 should include the sponsor’s financial and organizational capacity to 

track and maintain funded vehicles and equipment over the life of the project. 

Section 5: Relationship to State Implementation Plans 

As part of the sponsor’s evidence that its proposed early emission reductions are 

surplus to the SIP, the sponsor should consult with the State air quality agency to 

identify what, if any, provisions in the SIP or other state agreements might affect 

the proposed measures or the sponsor’s calculation of emission reductions. 

Section 6: Funding Sources 

This section summarizes total project costs, the amount of requested AIP and PFC 

funds, the amount and source of required AIP local matching funds, and other 

local contributions to the program if any. The sponsor should take note of the 

differences in funding eligibility between AIP and PFC programs (see Chapter 7). 

AIP and PFC eligibility differences can affect the sponsor’s range of options and 

how the project is designed. 

Section 7: Cost Effectiveness 

Cost effectiveness is calculated for individual criteria pollutants based on total 

project dollars divided by total emission reductions for each pollutant achieved 

over the useful life of vehicles and equipment. Instructions on the way to 

calculate cost effectiveness are presented in Chapter 9. 

Section 8: Vehicle and Equipment Commitments 

This section addresses the sponsor’s use commitments for project vehicles and 

equipment in accordance with VALE special conditions and other AIP/PFC 

requirements: 

 Airport-dedicated. 

 Operated and maintained at the airport throughout their useful life, and not 

transferred, re-converted to conventional fuels, or in some other way 

disabled from providing the expected long-term emission benefits for the 

airport. 

 Supported by enforceable agreements when the sponsor is leasing vehicles 

and equipment or supporting tenant-owned vehicles and equipment under 

the PFC program. These agreements must be ready-to-sign prior to 

funding approval, consistent with the special conditions of the VALE 

program (see Appendix C). 

 Replaced during their useful life by equivalent vehicles or equipment with 

equal or lower levels of emissions. This commitment is related to the 

CAA requirement that project emission reductions are "permanent." The 

sponsor may choose to extend this commitment beyond the useful life of 

individual vehicles or units of equipment for purposes of extending 

AERCs up to 20 years (see Chapter 9). 

 Labeled with the VALE logo prominently displayed. 

 Tracked by the sponsor for actual usage rates. 

FAA VALE Program Technical Report Page 2-6 Version 7
Section 9: Schedule 

Clearly define the proposed timeline for completing the application process and 

implementing major phases of the project (e.g., vehicle acquisition, vehicle 

deployment, completion of infrastructure). Provide realistic dates and milestones 

for major activities and project completion dates. 

Project Proposal Appendices

Several appendices should be included in a VALE proposal. Please note the 

difference between the project proposal appendices discussed below and 

references to the appendices of this report (in bold). 

Project Proposal Appendix A 

This first appendix must start with the “Emissions Reduction (ER) Report”, which 

is the standard and required EDMS output report for VALE projects (see Chapter 

9). Calculation of AERC Option years is automatically included in the ER Report 

if the option is selected in EDMS. (See Appendix D, Page 1 of the Project 

Application Worksheets). 

The ER Report(s) should be followed by the VALE project application 

worksheets (see Appendix D). The application worksheets must be filled out 

completely, including information about the owner of each proposed vehicle or 

unit of equipment, the useful life or remaining useful life of all vehicles, the 

vehicle identification number of any replaced/displaced conventionally fueled 

vehicles, the estimated level of vehicle and equipment usage, and the 

specifications for proposed low-emission infrastructure and equipment. (Note: If 

a project consists entirely of vehicles or entirely of infrastructure, the unused 

worksheets can be eliminated from the application or labeled as “nonapplicable”). 

Project Proposal Appendix B 

Include additional summary information on EDMS inputs, EDMS outputs, and 

the emissions analysis as appropriate. This information should be clearly 

presented and include the different low-emission vehicle and equipment 

categories that are part of the project. Do not include all EDMS input and output 

sheets that are part of or used to develop the summary information. Document 

any supplemental emission factors or data used for the emission calculations. 

Project Proposal Appendix C 

Include a signed copy of the required “State Air Quality Agency AERC Letter of 

Assurance to the FAA” (see Appendix G). If the Letter of Assurance is pending, 

include a draft of the proposed letter, including the name and title of the 

appropriate State signatory and FAA addressee(s). A signed and acceptable 

Letter of Assurance is required for project approval. 

FAA VALE Program Technical Report Page 2-7 Version 7
FAA VALE Program Technical Report Page 2-8 Version 7

Project Proposal Appendix D 

Include relevant technical and cost information about the proposed equipment or 

use of the equipment, including documentation that the required competitive bid 

process has been completed. Technical information may include emission 

certifications, equipment specifications, and vehicle activity logs. 

Vehicles acquired or upgraded through the program must be certified or verified 

to meet or exceed program low-emission standards. Required documentation will 

vary by vehicle type. For example, a sponsor purchasing new light-duty vehicles 

should attach a copy of related EPA low-emission rankings from the EPA Green 

Vehicle Guide.16 Sponsors can also submit price quotes from OEMs or 

dealerships to their proposal as appropriate. 

Project Proposal Appendix E 

If the project involves tenant-owned or leased equipment, or non-project vehicles 

using VALE-funded facilities, a signed letter of assurance from the tenant or 

third-party must be included in this appendix stating that the tenant/party will 

meet all relevant program assurances and conditions (see Appendix C). In 

addition, the sponsor should include other pertinent information (e.g., draft lease 

agreement) that describes the sponsor’s planned enforcement of VALE program 

special conditions. 

2.3.2 State and EPA Review of Project Proposal 

Upon receipt of the sponsor’s draft proposal, the State air quality agency has 45 

calendar days to review the proposal and make its finding to the sponsor and the 

FAA. EPA review of the proposal is concurrent with State review. Any 

comments by the EPA must be received by the State (with copies to the FAA and 

sponsor) within the 45-day State review period and should not delay the State’s 

response to the FAA. The State air quality agency and the EPA should review the 

sponsor’s proposal according to criteria presented in this guidance and the AERC 

Report. 

A timely State review and AERC Letter of Assurance (see Appendix G) to the 

FAA are critical to the planning and budgeting of the project. Because AIP and 

PFC programming schedules are tight, a delay by the State in its review and 

issuance of the AERC Letter of Assurance to the FAA could jeopardize a 

sponsor’s ability to obtain funding for a VALE project in the current fiscal year, 

representing a project delay for the sponsor of as much as one year. 

If the State air quality agency does not respond within the 45-day review period, 

the sponsor should notify the appropriate FAA regional office. The sponsor, 

FAA, and EPA should work with the State air quality agency, and other State and 

local officials, if appropriate, to resolve the delay as soon as possible. 

 

16 The web address for the EPA Green Vehicle Guide is: www.epa.gov/greenvehicles/. 
2.3.3 FAA Funding Approval 

The program office should review the draft proposal(s) for technical feasibility 

and cost effectiveness. Once the FAA has received an acceptable State AERC 

Letter of Assurance, the FAA funding application can proceed. For the PFC 

program, the PFC application may then be submitted by the public agency with 

the attached AERC Letter of Assurance. 

The FAA may approve all, some, or none of the proposed airport low-emission 

measures based on the availability of funding, project cost effectiveness, regional 

considerations, and other factors in the AIP and PFC decision process. The FAA 

may also stipulate modifications to proposed measures as needed. 

The FAA funding decision is one of several factors that could affect the sponsor’s 

proposal between the application phase and the implementation phase. Other 

factors that could affect the sponsor’s acquisition and deployment of equipment 

include the availability of new or improved technology, changing usage estimates, 

unexpected costs, or the status of participating manufacturers or operators. 

2.3.4 Format and Distribution of Final Project Proposal 

Proposal Format 

 Standard page size of 8.5 inches x 11 inches (including any figures or 

airport maps). 

 12 point font size. 

 Include the project title and page number on each page of the proposal. 

 The main sections of the proposal and the appendices should be as short 

and succinct as possible without sacrificing a clear and complete 

presentation of the material. 

 Effective graphics, charts, and maps are encouraged. 

Distribution 

Airport project applications should be mailed electronically to the appropriate 

FAA Regional Airports Division Office or Airport District Office and to the 

program contact for APP-400 (see below). The final application must be a 

complete package, including the State’s AERC Letter of Assurance and financial 

information; no external material will be accepted. 

Copies of the final proposal should also be submitted to the State air quality 

agency and the EPA Region Office as a courtesy. These copies may be submitted 

electronically if acceptable to agency representatives. 

FAA VALE Program Technical Report Page 2-9 Version 7
Contact Information 

Sponsors are encouraged to contact their FAA Regional Airports Division 

Manager or the ADO Manager. The FAA Headquarters contact is Dr. Jake Plante 

(202) 493-4875, jake.plante@faa.gov in the Airports Office, Planning and 

Environmental Division, APP-400. Program material is posted on the following 

FAA Airports website: http://www.faa.gov/airports/environmental/vale

2.4 Project Implementation Phase 

The implementation phase of the VALE program begins with FAA funding approval. 

Figure 2-2 illustrates the seven steps to project implementation as listed below. 

1. Sponsor orders equipment and begins deployment. 

2. Sponsor verifies project implementation. 

3. Sponsor revises emission reduction estimates and provides an updated report to 

the State air quality agency for AERCs, with copies to FAA and EPA. 

4. State air quality agency confirms the sponsor’s emission reduction calculations. 

5. State air quality agency issues AERCs through an AERC statement. 

6. Sponsor continues to track the progress of the project. 

7. Sponsor uses the AERCs, as needed, for general conformity or NSR requirements. 

Following the deployment of equipment, the sponsor is free to decide when to submit an 

updated project emission reduction estimate to the State air quality agency for AERCs. 

The sponsor’s updated report should reflect any changes in project vehicles and 

equipment or their usage. In addition, the sponsor should attempt, as practicable, to use 

actual operations data for updating its project emission reduction estimates (based 

originally on certification, modeling, and manufacturer data). 

The report should be presented to the State air quality agency similar to the initial 

application. It is expected that State program review during the implementation phase 

will proceed quickly because of the previous State review of the project application. 

FAA VALE Program Technical Report Page 2-10 Version 7
Figure 2-2. Flow Chart of Project Implementation Phase 

Documents

Airport AERC Actions

use.

Airport project 

implementation

Verification 

(AIP/PFC 

compliance, etc.)

Tracking process

State AQ agency 

issues AERCs

Updated report on 

project emission 

reductions to State AQ

agency & EPA

Airport AERC 

Statement

FAA VALE Program Technical Report Page 2-11 Version 7
FAA VALE Program Technical Report Page 2-12 Version 7

THIS PAGE INTENTIONALLY LEFT BLANK 
CHAPTER 3 

FUEL ELIGIBILITY AND CHARACTERISTICS

A major goal of the VALE program is to provide commercial service airports with the 

ability to purchase low-emission vehicles and equipment. To meet this goal, lowemission vehicles and equipment purchased through the program must use alternative 

fuels or cleaner burning conventional fuels (e.g., gasoline and diesel). Under the VALE 

program, PFC funding is not limited by fuel type, while AIP funding is only available for 

vehicles and equipment using eligible alternative fuels. 

Congress recognized the need for a more sophisticated approach in Vision 100 as 

compared with the earlier AIR-21 ILEAV pilot program, which specified only six 

eligible alternative fuels and a single low-emission standard for light-duty vehicles. In 

response, the VALE program relies heavily on the expertise of the EPA and DOE to 

define alternative fuels and to establish “best achievable” low-emission standards for 

several vehicle categories and weights. Below are the basic funding requirements on the 

integrated fuel and low-emissions standards for the program: 

 Alternative fuels that are substantially non-petroleum based (AIP and PFC 

eligible) 

 Clean conventional fuels (PFC eligible only) 

 Best achievable low-emission standards for program vehicles and eligible 

fuels (AIP and PFC) 

The VALE program is fuel neutral to the greatest extent possible. All of the eligible 

alternative fuels (AIP and PFC) and clean conventional fuels (PFC only) can lead to 

substantial emission reductions. The sponsor must consider which fuel type does the best 

job of reducing emissions for the area’s Level One pollutant(s), minimizing costs, and 

meeting logistical requirements for safety, handling, and siting. 

This chapter discusses the types of fuels that may be used in low-emission vehicles and 

equipment acquired through the VALE program, as well as the comparative emissions 

reduction benefits and other characteristics of those fuels. Within the established 

framework of the program, sponsors have a great deal of flexibility to determine the fuel 

that is the most appropriate for their airport and operational needs. 

3.1 Eligible Fuels Criteria 

The following information is intended to help sponsors understand the characteristics and 

parameters for alternative fuels, their relative emission benefits, and how to weigh 

various fuel-related factors in developing a VALE project. 

FAA VALE Program Technical Report Page 3-1 Version 7
FAA VALE Program Technical Report Page 3-2 Version 7

There are some limitations that sponsors need to consider in their selection of alternative 

fuels. First, new VALE-funded vehicles must meet program low-emission standards, 

regardless of the fuel used. These low-emission standards are discussed in detail in 

Chapter 5. Second, the VALE program is restricted to funding of capital improvements 

and therefore does not pay for O&M expenses, including fuel costs. Third, the sponsor, 

along with their project partners, must comply with all national safety standards 

pertaining to alternative fuel use, as appropriate, for all project vehicles and activities 

undertaken as part of the VALE program. 

3.1.1 AIP Eligible Fuels 

Under Vision 100, if a sponsor 

chooses to use AIP funds to 

purchase low-emission vehicles, 

these vehicles must be powered 

exclusively by dedicated alternative 

fuels as defined by the DOE, not 

excluding hybrid engine systems. 17 

Under designated DOE EPAct guidelines, eligible alternative fuels are as follows:

 Electricity (including photovoltaics) 

 Natural gas and liquid fuels domestically 

produced from natural gas (compressed or 

liquefied natural gas (CNG or LNG)) 

 Liquefied petroleum gas (LPG/propane) 

 Mixtures containing 85 percent or more 

by volume of alcohol fuel with gasoline, 

including denatured ethanol (E85) and 

methanol (M85) 

 Hydrogen 

 Coal-derived liquid fuels 

 Biodiesel (B85 to B100-biofuel) 

 P-series fuels 

 

17 Section 301(2) of EPAct defines alternative fuels and sets forth authority for the DOE to add more 

alternative fuels to the list of authorized alternative fuels, which are defined in Section 301(2). Newly 

added alternative fuels are called P-series. 

VALE alternative fuel requirements: 

 Cleaner burning than conventional 

petroleum-based fuels 

 Primarily non-petroleum based to 

enhance energy security 

AIP funding is restricted to 

alternative fuels only: 

 Electric 

 Natural gas (CNG, LNG) 

 Propane (LPG) 

 Ethanol 85 

 Methanol 85 

 Hydrogen 

 Coal-derived liquid fuels 

 Biodiesel (B85 to B100-

biofuel) 

 P-Series 

and 

 Hybrid systems 
These alternative fuels meet the program goals of EPAct – they are cleaner 

burning than conventional fuels, substantially non-petroleum based, and available 

domestically to reduce foreign imports. 

Hybrid vehicles, which Congress did not want to exclude from full eligibility, 

must meet program low-emission standards in the same way as other AFVs. 

Typical hybrid vehicle technology combines gasoline or diesel engines with 

shared power supply from an electric motor. Most hybrids today are light-duty 

vehicles although some medium and heavy-duty vehicle manufacturers also plan 

to offer hybrid electric vehicles using natural gas or propane engines. 

3.1.2 PFC Eligible Fuels 

The fuel choices for the program using PFC funds are somewhat less restrictive 

than using AIP funds. However, the underlying requirements for achieving 

program low-emission 

standards remain the same. 

Provided that program lowemission standards are met, the 

selection of fuels using PFCs is 

open to all alternative and 

clean conventional fuels, 

including clean diesel, clean 

gasoline, and biofuels. 

Difference in program fuel eligibility: 

 AIP funding requires only alternative 

fuels as defined by DOE. 

 PFC funding allows all alternative 

fuels plus clean conventional fuels. 

3.2 Clarification of AIP Alternative Fuels Technology 

The discussion below provides additional information and clarification on the alternative 

fuels that are available to the sponsor for their VALE projects under the AIP program. 

Domestic Fuel Distinctions

The DOE-designated alternative fuels approved for the VALE program are primarily 

domestic, burn cleaner than conventional fuels, and lessen the Nation’s dependence on 

imported crude oil. Natural gas is produced from natural gas wells and in conjunction 

with crude oil wells. Although some natural gas wells are in Canada and Mexico, 

domestic usage is primarily from U.S. wells. Moreover, gaseous and liquid fuels derived 

from natural gas (CNG, LNG, and LPG) are designated under EPAct as non-petroleum 

based fuels. LPG can also be derived from the petroleum refining process, and is not 

considered to be an exclusively petroleum-based fuel that is part of the oil refining 

process. Natural gas is distributed through underground pipelines and served to 

compressors at CNG fueling stations to produce CNG as a vehicle fuel. Natural gas is 

also delivered through the same underground pipeline to strategically located liquefaction 

plants to produce LNG as a transportation fuel. LPG is distributed in tanks by truck and 

is available widely throughout the United States. 

FAA VALE Program Technical Report Page 3-3 Version 7
Flexible-Fuel Technology

Flexible-fuel vehicles (FFVs) automatically detect the blended fuel composition in the 

fuel tank and adjust the combustion parameters for optimum engine performance. FFVs 

are permitted under the AIP program only if a minimum 85 percent fuel blend of eligible 

alternative fuels is used on a guaranteed basis. Eligible EPAct-designated blended fuels 

include E85 and M85 and satisfy Vision 100 criterion of primarily non-petroleum based 

fuels, consistent with DOE eligible alternative fuels. Flexible fuel systems are eligible in 

forms below the 85 percent minimum level only when the equipment is funded with 

PFCs and local funds. AIP funds cannot be included in the project. Sponsors are 

responsible for required assurances that E85, M85, or other eligible alternative fuel 

blends are used on a permanent and dedicated basis and that program low-emission 

standards are always met. 

Blended-Fuel Technology

Unlike FFVs, other blended fuels (biodiesel) are not adjusted by the combustion 

technology. These blended fuels must be used on a permanent and dedicated basis in 

order to assure that program low-emission standards are always met. 

Bi-Fuel Technology

Bi-fuel vehicles have the ability to operate on either one fuel or another, but not 

simultaneously. Generally, bi-fuel vehicles have two or more fuel tanks and the operator 

can manually switch from one fuel tank to another. Typical bi-fuel vehicles available 

today do not provide adequate assurance that low-emission fuels are being used and that 

predicted emission benefits are being realized under actual conditions. As a result, bifuel vehicles will not qualify for funding unless both fuels are eligible alternative fuels 

and the vehicle is EPA-certified or verified to meet program low-emission standards 

during operation of either fuel source. 

Dual Fuel Technology

Dual fuel vehicles have the ability to combust two fuels from separate fuel tanks 

simultaneously (e.g., CNG and diesel). Dual fuel technology is accepted under the 

VALE program provided that the technology is EPA-certified to meet program lowemission vehicle standards. Dual fuel systems are distinct from hybrid technology and 

are AIP and PFC-eligible if both fuels are alternative fuels. If the system uses 

conventional fuel in any amount, project eligibility is restricted to the PFC program. 

Hybrid Technology

Eligible hybrid AFVs must substantially displace the vehicle’s gasoline or diesel fuel use 

and meet the VALE program low-emission standards. In the airport environment, this 

should be accomplished by the intrinsic nature of airport driving conditions that demand 

frequent braking, which regenerates the electrical battery portion of the hybrid system. 

Non-propulsion and accessory functions are not considered relevant hybrid-electric 

applications for determining vehicle eligibility (e.g., plugging a utility into the car’s 

cigarette lighter). 

FAA VALE Program Technical Report Page 3-4 Version 7
Fuel Cells

Fuel cells may be thought of simply as batteries that operate with hydrogen and oxygen. 

The energy released from the oxidation of hydrogen to water is directly converted to an 

electrical current. Fuel cells may be directly fueled by hydrogen or may use reformers to 

generate hydrogen from methanol, natural gas, or other hydrocarbons with water. 

However, adding a reformer increases the cost, bulk, and complexity of the fuel cell 

system. Fuel cell technology used for power generation or the propulsion of vehicles has 

a promising future. However, fuel cell systems are primarily in the R&D stage and not 

yet commercially viable. 

3.3 Relative Emission Benefits of Alternative Fuels 

Table 3-1 provides a general guide to selecting alternative fuels based on the criteria 

pollutant causing the nonattainment or maintenance status in the vicinity of the airport. 

The table provides a quick comparison of each eligible alternative fuel relative to the 

emission performance of conventional fuels. The relative scale was developed from 

emissions criteria and databases commonly available on the internet from the EPA, the 

fueling industry, and several state agencies. To be consistent with the EPA’s approach to 

tail pipe emission standards, the electric emissions criterion is considered to be zero at the 

tailpipe without consideration of transmission line efficiency or stack emissions at the 

power plant. 

Table 3-1. Alternative Fuels Emissions Performance Relative to Conventional 

Fuels for Each Criteria Pollutant 

O3 AIP Eligible Fuels VOC NOx

NO2 SO2 PM CO 

Electric 

CNG 

LNG 

Propane 

E85 

M85 

Hydrogen 

B100 

 = worse = better = best 

Scale is in comparison to baseline emissions from conventional fuels 

FAA VALE Program Technical Report Page 3-5 Version 7
3.4 Fuel Characteristics 

This section describes the characteristics of the cleaner-burning alternative fuels that 

potentially meet the VALE program low-emission goals. Each alternative fuel discussed 

is an EPAct-designated fuel and qualifies for AIP and PFC programs. Additionally, these 

fuels meet the DOE requirements of being substantially non-petroleum based and 

domestically available to reduce U.S. dependence on foreign oil. 

3.4.1 Electricity 

Electricity can be used as a transportation fuel to power battery-electric and fuel 

cell vehicles. Electricity is unique among the alternative fuels in that mechanical 

power is derived directly from it, whereas the other alternative fuels release stored 

chemical energy through combustion to provide power. When used to power 

electric vehicles (EVs), electricity is stored in an energy storage device such as a 

battery. EV batteries have limited storage capacity and must be replenished by 

plugging the vehicle into a recharging unit. The electricity for recharging the 

batteries can come from the existing power grid or from distributed renewable 

energy sources such as solar or wind. 

The principal benefit of using EVs is that there are no vehicle tailpipe emissions. 

The economic advantage of using EVs, after the relative high initial capital cost, 

comes through lower “fuel” and maintenance costs. The cost of an equivalent 

amount of fuel for EVs is less than the price of gasoline. Additionally, 

maintenance for EVs is less because they have fewer moving parts to service and 

replace. 

3.4.2 Compressed Natural Gas (CNG) and Liquefied Natural Gas (LNG)

Natural gas is a mixture of hydrocarbons, mainly methane, and is extracted from 

underground either from gas wells or in conjunction with crude oil production. 

The interest in using natural gas as an alternative transportation fuel stems mainly 

from its clean burning qualities, its domestic resource base, and its availability via 

underground pipelines to end-use markets. 

Natural gas can be used as a transportation fuel in either a gaseous form (CNG) or 

as a liquid (LNG). CNG is dispensed into vehicles at 3,600 pounds per square 

inch (psi), and LNG is dispensed as super-cooled liquid at -260 oF. In order to 

achieve comparable travel distances to gasoline or diesel vehicles, CNG is stored 

onboard as a gas in high-pressure cylinders and LNG is stored as a liquid in 

super-insulated tanks. To the vehicle user, performance and drivability of natural 

gas vehicles (NGVs) is essentially the same as for gasoline and diesel vehicles. 

FAA VALE Program Technical Report Page 3-6 Version 7
Natural gas is safer for storage than other liquid transportation fuels. It is lighter 

than air and does not pool on the ground, so it poses less of a hazard in the event 

of a leak or spill. The fuel storage cylinders are, of necessity, much stronger than 

gasoline or diesel fuel tanks, which is a safety benefit in the event of a collision. 

Natural gas is odorless, non-toxic and non-corrosive, cannot be absorbed through 

the skin, and will not contaminate ground water. The familiar “rotten egg” smell 

associated with natural gas is added as a safety feature for leak detection. Natural 

gas vehicle fueling systems are sealed or closed loop, so no gas escapes during the 

refueling process and virtually zero evaporative emissions are produced. 

Like electricity, the economic advantage of using NGVs, after the relative high 

initial capital cost, comes through lower fuel and maintenance costs. Depending 

upon market conditions, the cost of an equivalent amount of fuel for NGVs can be 

less than the price of gasoline or diesel. Additionally, maintenance for NGVs can 

be less because the fuel does not contaminate the engine oil like gasoline and 

diesel. The most commonly cited benefits of NGVs include extended oil change 

intervals, increased spark plug life, and extended engine life. 

3.4.3 Liquefied Petroleum Gas (LPG or Propane)

Liquefied petroleum gas (LPG or propane) is a mixture of various hydrocarbons 

(propane, propylene, butane, and butylene) that exist as gases at atmospheric 

pressure and temperature, and yet liquefy at higher pressures. For all such fuel 

mixtures in the United States, it is also named for its major constituent, propane. 

Propane is a natural derivative of both natural gas processing and crude oil 

refining. 

Propane is stored onboard a vehicle at pressures between 130 and 170 psi. Within 

this pressure range propane exists in a liquid state. Tanks are filled to no more 

than 80 percent of capacity to allow for liquid expansion as ambient temperatures 

rise. 

Propane is heavier than air and pools on the ground like other liquid 

transportation fuels. Propane vapors are also heavier than air and will collect at 

ground level like gasoline and diesel. However, propane vapors will dissipate 

more rapidly than vapors of gasoline or diesel fuel. Sponsors should consider 

placing propane storage/dispensing facilities away from confined spaces. The 

vehicle fuel storage cylinders are much stronger than gasoline or diesel fuel tanks. 

Propane is considered to be non-toxic and non-corrosive, and will not contaminate 

ground water. 

Propane vehicles are typically converted gasoline or diesel vehicles. The 

economic advantage of using propane comes from lower fuel and maintenance 

costs. The cost of an equivalent amount of fuel for propane-powered vehicles can 

be less than the price of gasoline or diesel, depending on demand fluctuations in 

FAA VALE Program Technical Report Page 3-7 Version 7
the fuel distribution market. Similar to natural gas, propane does not contaminate 

engine oil the way gasoline and diesel fuels do. Propane-powered vehicles also 

deliver extended oil change intervals, increased spark plug life, and extended 

engine life. Propane-powered vehicles exhibit similar tailpipe emission benefits 

as natural gas-powered vehicles. Propane vehicle fueling systems are also sealed 

or closed loop, so no gas escapes during the refueling process and virtually zero 

evaporative emissions are produced. 

3.4.4 Hydrogen

Hydrogen (H2) is being explored for use in internal-combustion engines (ICE) and 

fuel-cell electric vehicles. H2 is the simplest and lightest fuel and is a gas at 

normal temperatures and pressures, which presents greater transportation and 

storage hurdles than what currently exists for liquid fuels. Storage systems being 

developed include compressed hydrogen, liquid hydrogen, and chemical bonding 

between hydrogen and a storage material like metal hydrides. 

Unfortunately, hydrogen does not exist naturally as a fuel. H2 must be produced 

through one of two current methods. The first is electrolysis and the second is 

synthesis gas production from steam reforming or partial oxidation. 

Electrolysis uses electrical energy to split water molecules into hydrogen and 

oxygen. The electrical energy can come from any electricity production sources 

including renewable fuels. Fuel cell vehicles (FCVs) can then use electricity 

produced from an electrochemical reaction that takes place when the produced 

hydrogen (from electrolysis or reformation) is oxidized in the fuel cell “stack.” 

The production of electricity using fuel cells takes place without combustion or 

pollution and leaves only two byproducts, heat and water. 

The predominant method for producing synthesis gas is steam reforming of 

natural gas, although other hydrocarbons can be used as feedstocks. For example, 

biomass, and coal can be gasified and used in a steam reforming process to create 

hydrogen. 

Internal-combustion engines used in today’s vehicles convert less than 30 percent 

of the energy in gasoline to power that moves the vehicle. FCVs that reform 

hydrogen from gasoline can use about 40 percent of the energy in the fuel. 

While no transportation distribution system currently exists for hydrogen 

transportation use, the ability to create the fuel from a variety of resources and its 

clean-burning properties make it a desirable alternative fuel. 

FAA VALE Program Technical Report Page 3-8 Version 7
3.4.5 Ethanol

Ethanol (E100) (ethyl alcohol, grain alcohol, EtOH) is a clear, colorless liquid 

with a characteristic, agreeable odor. In dilute aqueous solution, it has a 

somewhat sweet flavor, but in more concentrated solutions it has a burning taste. 

In the United States, ethanol is made primarily from corn. The grain alcohol 

produced is denatured or poisoned prior to shipment to prevent ingestion. Like 

gasoline, ethanol contains hydrogen and carbon, but ethanol also contains oxygen 

in its chemical structure. The oxygen makes ethanol a cleaner burning fuel than 

gasoline. 

Ethanol is blended with gasoline to improve the burning characteristics of 

gasoline. For a blend of ethanol and gasoline to qualify as an alternative fuel 

under the AIP portion of the VALE program ethanol must be mixed or blended to 

a ratio not less than 85 percent ethanol and 15 percent gasoline. The final product 

is termed “E85” and is an EPAct designated alternative fuel and qualifies as a 

primarily non-petroleum based fuel consistent with DOE eligibility requirements. 

Other blends of ethanol and gasoline may qualify under PFC funding. 

The emissions from an E85 powered vehicle are the same as those from a gasoline 

vehicle, but lower in terms of quantity. E85 cannot be burned in a conventional 

gasoline vehicle. The vehicle manufacturer makes modifications to the engine 

and vehicle fuel system to accommodate E85. FFVs are capable of optimizing the 

vehicle performance when burning ethanol-blended fuels. 

E85 fuel is heavier than air and pools on the ground like gasoline. E85 vapors are 

also heavier than air and will collect at ground level like gasoline. E85 is 

considered to be toxic and corrosive, since it is blended with potential 

contaminants from gasoline, and will contaminate ground water. Due to the 

corrosive nature of some alcohol fuels, fuel pumping and dispensing equipment 

must be properly designated without aluminum or other materials that are not 

compatible. Gasoline and diesel pumps cannot be used to dispense alcohol fuels 

until they have been modified. 

3.4.6 Methanol

Methanol (M100) is a clear, colorless liquid with a faintly sweet pungent odor 

similar to ethyl alcohol. It is fully soluble in water. In the United States methanol 

is made primarily from natural gas, however it can be made from coal and 

biomass (e.g., wood). The alcohol produced is poisonous, can be absorbed 

through the skin, and cannot be made non-poisonous. Methanol, which contains 

hydrogen and carbon like gasoline, also contains oxygen in its chemical structure. 

The oxygen makes methanol a cleaner burning fuel than gasoline. 

FAA VALE Program Technical Report Page 3-9 Version 7
Like ethanol, methanol is blended with gasoline to improve the burning 

characteristics of gasoline. For a blend of methanol and gasoline to qualify as an 

alternative fuel under the AIP portion of the VALE program, methanol must be 

mixed or blended to a ratio not less than 85 percent methanol and 15 percent 

gasoline. The final product is termed “M85” and is an EPAct designated 

alternative fuel that qualifies as a non-petroleum based fuel consistent with DOE 

eligibility requirements. Other blends of methanol and gasoline may qualify 

under PFC funding. 

As a vehicle fuel M85 has similar benefits as E85 in reducing both vehicle 

tailpipe emissions and evaporative emissions. The types of emissions from an 

M85 powered vehicle are essentially the same as those from a gasoline vehicle, 

but lower in quantities. 

M85 cannot be burned in a conventional gasoline vehicle. The vehicle 

manufacturer makes modifications to the engine and vehicle fuel system to 

accommodate M85. Most FFVs are capable of using M85 as a transportation 

fuel. Due to the corrosive nature of some alcohol fuels, fuel pumping and 

dispensing equipment must be properly designed without aluminum or other 

materials that are not compatible. Gasoline and diesel pumps cannot be used to 

dispense alcohol fuels until they have been modified. 

M85 fuel is heavier than air and pools on the ground like gasoline. M85 vapors 

are also heavier than air and will collect at ground level like gasoline. M85 is 

considered to be toxic and corrosive, can be absorbed through the skin, and will 

contaminate ground water. 

3.4.7 Coal-Derived Liquid Fuels

The main fuel in the coal-derived liquid fuel category is Fisher-Tropsch liquids. 

Fischer-Tropsch technology was developed in 1923 by two German coal 

researchers, Franz Fischer and Hanz Tropsch. Their technology converts coal, 

natural gas, and low-value refinery products into high-value, clean burning fuel 

that can be a replacement for diesel fuel. The resultant fuel is colorless, odorless, 

and low in toxicity. In addition, it is virtually interchangeable with conventional 

diesel fuels and can be blended with diesel in any ratio with little to no 

modification. Fischer-Tropsch fuels offer important emissions benefits compared 

with diesel, reducing NOx, CO, and PM. Fischer-Tropsch liquids are another way 

to use alternative fuels in diesel engines without impacting infrastructure or 

refueling costs. These fuels are slightly less energy dense than diesel, which 

could result in lower fuel economy and power. 

FAA VALE Program Technical Report Page 3-10 Version 7
3.4.8 Biodiesel

Biodiesel (B100) (fatty acid alkyl esters) is a cleaner-burning diesel-like fuel 

replacement made from natural renewable sources such as soybean oil, new and 

used vegetable oils, and animal fats. Just like petroleum diesel, biodiesel operates 

in diesel-fueled compression-ignition (CI) engines. Because biodiesel is 

considered to be a solvent, it should not be stored for longer than 6 months in fuel 

storage tanks or in onboard vehicle fuel tanks. As an organic substance, longterm storage of bio-fuels can also promote the growth of living organisms in the 

fuel tanks and should be guarded against. Additionally, the fuel should not come 

in contact with painted surfaces since the solvent characteristics of the fuel will 

degrade the paint finish. 

Biodiesel should be used only in compression-ignition engines with vehicle fuel 

systems specially suited for the fuel. It is not advisable to use pure biodiesel in 

existing diesel powered engines and fuel systems without first consulting with the 

engine manufacturer. The solvent characteristics of the biodiesel may not be 

compatible with current engine and fuel system materials such as rubber gaskets 

and hoses. In some cases, the engines must be retrofitted with synthetic materials 

that are compatible with the solvent effect of biodiesel. 

Biodiesel is desirable as an alternative fuel to diesel because of its clean burning 

characteristics and resulting lower tailpipe emissions. One disadvantage of 

biodiesel is an increase in NOx emissions. This tendency is due to high 

concentrations of polyunsaturated compounds in the fuel. Biodiesel contains no 

nitrogen or aromatics and typically contains less that 15 parts per million (ppm) of 

sulfur, so it is compatible with many of the latest diesel emissions aftertreatment 

equipment designed for ultra low sulfur diesel (ULSD). Biodiesel contains 11 

percent oxygen by weight, which accounts for its lower carbon monoxide, 

particulate, soot and hydrocarbon tailpipe emissions. The energy content of 

biodiesel is roughly 10 percent less than No. 2 diesel, therefore the vehicle miles 

per gallon will be reduced by approximately 10 percent. The fuel efficiency is the 

same as diesel. 

Contamination levels in biodiesel can be reduced by storage in tanks kept free of 

water; tankage should have water-draining provisions on a scheduled basis. 

Underground or isothermal storage is preferred in order to avoid temperature 

extremes because high storage temperatures accelerate fuel degradation. 

Therefore, above ground storage tanks should be sheltered or painted with 

reflective paint. Fixed roof tanks should be kept full to limit oxygen supply and 

tank breathing. The use of airtight sealed containers, such as drums or totes, can 

enhance the storage life of biodiesel. Copper and copper-containing alloys should 

be avoided with biodiesel due to increased sediment and deposit formation. 

Contact with lead, tin, or zinc can also cause increased sediment levels that can 

rapidly plug filters and should be avoided. 

FAA VALE Program Technical Report Page 3-11 Version 7
FAA VALE Program Technical Report Page 3-12 Version 7

3.4.9 P-Series

P-Series fuel is a unique blend of natural gas liquids (pentanes plus), ethanol, and 

the biomass-derived co-solvent methyltetrahydrofuran (MeTHF). The ethanol 

and MeTHF can be derived from renewable domestic feedstocks, such as corn, 

waste paper, cellulosic biomass, agricultural waste and wood waste from 

construction. P-series fuels are clear, colorless, liquid blends. 

These fuels are designed to operate in FFVs that can run on E85, gasoline, or any 

blend of the two. The P-series fuels emissions are generally below those of 

reformulated gasoline and are well below federal emissions standards. These 

fuels are not currently being produced in large quantities and are not widely used. 

Table 3-2 below provides a guide for selecting alternative fuels based on selected fuel 

characteristics. The table provides a quick comparison of each eligible alternative fuel 

with unleaded gasoline and diesel relative to the selected fuel characteristics. The 

information was developed from fuel characteristics and databases commonly available 

on the Internet and from the DOE and fueling industry. 
Table 3-2. Fuel Characteristics 

Fuel 

Property Unit Compressed 

Natural Gas 

Liquefied 

Natural Gas Diesel Automotive Gasoline* Propane (LPG) Ethanol (E85) Methanol (M85) Hydrogen 

(No. 2)* 

(CNG) (LNG) 

Higher Heating Value(HHV) (600F Liquid) 

Btu/lb 19,400 avg 20,100 avg 22,179 23,890 21,489 12,770 9,751 61,000 

Btu/gal 138,700 avg 125,000 avg 140 84,242 90,830 84,532 64,732 

(Gas at 600 F & 1 atm) Btu/scf NA NA 1,050 1,010 2,516 867 317 Lower Heating Value (LHV) (600 F liquid) Btu/lb 18,300 18,900 20,476 21,501 19,757 11,531 8,559 51,532 

Btu/gal 131,000 117,180 124 75,818 83,509 76,331 56,819 

(Gas at 600 F & 1 atm) Btu/scf NA NA 930 909 2,315 unknown 766 267 Heat of Vaporization (at boiling point) Btu/lb 90 150 219 219 183 359 463 192.1 Density: 

lb/ft3 Liquid at 60 52.7 46.4 NA 23.6 31.6 49.5 49.7 NA 

0 F, 

except methane lb/gal 7.05 6.2 NA 3.16 4.23 6.62 6.64 NA 

Gas at 600 F & 

3,000 psig lb/ft3 NA NA 10.6 10.5 unknown NA NA unknown 

Vapor gas at 600F 

& 1 atm lb/ft3 0.30 – 0.45 0.15 – 0.30 0.0454 0.0423 0.116 0.121 0.084 unknown 

Storage Volume Relative to Diesel % 100% 110% 445% 190% 154% 170% 228% 1,722% Reid Vapor Pressure psia 0.02 – 0.2 7 - 14 2,400 NA 189 2.31 4.63 (gas) Flammability Limits (by volume) lower 0.60% 1.40% 5.00% 5.00% 2.00% 3.28% 5.50% 4% 

upper 5.50% 7.60% 15% 15% 9.50% 19.00% 44.00% 75% 

Autoignition Temperature 

0F 480 495 999 999 919 793 867 1,050 

* Only eligible for PFC funding, provided that the tailpipe emissions meet the prescribed program standards. 

FAA VALE Program Technical Report Page 3-13 
3.5 Proposed Alternative Fuels Evaluation Checklist 

The following checklist is provided to help sponsors to evaluate which alternative fuel(s) 

would be best for the airport. The considerations presented are by no means exhaustive 

or applicable to all airports or situations. Additional information comparing the 

requirements of fueling stations by different alternative fuels is provided in Chapter 6. 

General checklist for evaluating alternative fuels for airport use: 

1. Asses your existing vehicle fleet 

a. Inventory your current fleet 

i. What vehicles are due to be replaced? 

1. In the current year? 

2. Beyond the current year? 

b. Project future fleet needs 

i. Rate of fleet turnover 

ii. New vehicles needed 

iii. Changes in fleet mix: Auto/LD/MD/HD/Transit/Specialty 

2. Analyze the existing fueling infrastructure 

a. Plot service area for existing fueling infrastructure 

b. Fleet fueling assessment 

i. Physical considerations 

1. Location of existing stations 

2. Excess space availability 

3. Local availability of alternative fuel 

ii. Security 

iii. Ingress/egress 

c. Build a new fueling facility? 

i. Evaluate usability 

ii. Determine type of alternative fuel for fueling station 

iii. Design and construction 

iv. Sizing, equipment selection, specifications 

v. Contractors 

3. Understand alternative fuel characteristics 

a. Safety parameters (flammability, etc.) 

b. Energy content 

4. Economics 

a. Cost of available fuels 

b. Cost to build a fueling station 

c. Ownership or lease options 

d. Partnerships for regional air quality improvements 

5. Consider available AFV options 

6. Decide on an implementation strategy

FAA VALE Program Technical Report Page 3-14 Version 7
FAA VALE Program Technical Report Page 4-1 Version 7

CHAPTER 4 

GENERAL VEHICLE ELIGIBILITY

The acquisition and conversion of VALE vehicles through the AIP and PFC programs are 

discussed in this chapter. The areas of discussion include general eligibility requirements 

for vehicle types, useful life estimates, Federally-eligible reimbursable costs, and retrofit 

technology for existing vehicles. 

 

To understand vehicle eligibility for the VALE program, the sponsor needs to become 

acquainted with how project and vehicle requirements differ between the AIP and the 

PFC programs (Chapter 7). Areas of difference in AIP and PFC program eligibility 

include allowable fuel types, vehicle ownership, and local cost-share requirements. 

4.1 Expansion of Traditional Eligibility for Low-Emission Projects 

The AIP and PFC programs are intended to support capital improvement projects at 

airports. Traditionally, these projects involve publicly owned airport facilities, take place 

on airport property, and represent easily monitored fixed assets. With this continuing 

emphasis, Vision 100 expanded AIP and PFC project eligibility to allow earlier funding 

for more varied low-emission projects at airports, including mobile equipment. 

Prior to the VALE program, only a small number of airport-owned vehicles were AIP 

and PFC-eligible (e.g., fire trucks, snow removal equipment) because of their essential 

role in airport safety, capacity, and security.18 Although low-emission models of these 

vehicle types were eligible, sponsors had to provide the FAA with documentation of a 

CAA requirement (e.g., general conformity determination) in advance of funding 

approval. It is important to note that this so-called “traditional” eligibility for airport 

low-emission vehicles and equipment continues to exist apart from the VALE program. 

 

18 Chapter 5, Section 5, Safety, Security, and Related Projects, Airport Improvement Program Handbook, 

FAA Order 5100.38C, June 2005; and Vision 100, Section 151. Sponsors may continue to use AIP grants 

and PFC revenue to fund the base cost of traditionally "AIP-eligible" vehicles that meet the criteria 

presented in this section of the AIP Handbook. Historically AIP-eligible vehicles include airport-owned 

safety and security-related equipment, including snow removal and aircraft rescue and fire fighting 

equipment. Thus, if a traditionally AIP-eligible vehicle meets the low emission standards of the VALE 

program, it is possible for the sponsor to fund both the vehicle’s base cost and the low-emission 

incremental or retrofit costs for the vehicle through the AIP or PFC programs. 
FAA VALE Program Technical Report Page 4-2 Version 7

4.2 Vehicle Types 

The wide variety of vehicles in use at airports is a microcosm of the national vehicle 

fleet. The VALE program is structured to address these varied technologies, imposing 

few restrictions on vehicle type. Vehicle eligible for the VALE program include airportdedicated on-road or ground access vehicles (GAVs) and many types of GSE to support 

aeronautical services, airport maintenance, airport security, and other essential airport 

needs.19 

4.3 Airport-Dedicated Vehicles 

All vehicles and equipment purchased or converted under the VALE program must be 

“airport-dedicated”, meaning that they must be an integral part of the aeronautical, 

transportation, security, or maintenance services at the airport, used on a regular basis in 

normal operation of the airport, and stored and maintained within the airport boundary. 

Use of on-road vehicles outside the airport boundary is permitted only if such use is 

minor, intermittent, and related to its primary mission to deliver airport services at the 

airport. 

The requirement for vehicles to be airport-dedicated is consistent with AIP and PFC 

program management. In addition, this requirement prevents potential overlap with other 

Federal transportation programs and related emission reduction measures already 

considered as part of metropolitan transportation plans and transportation improvement 

programs reflected in the transportation conformity process. 

Airport-dedicated vehicles include most GSE and many on-road vehicles, such as airport 

parking lot shuttles and buses, airport security vehicles, and airport maintenance vehicles. 

Vehicles that are not eligible include general use automobiles, buses, taxicabs, 

limousines, rental cars, super shuttles, and other vehicles that operate to and from the 

airport as part of a regional transportation circuit or inter-airport service. 

4.4 Vehicle Use 

Vehicle owners are expected to operate vehicles acquired under the VALE program at the 

same level of use that was estimated in the airport sponsor’s VALE project proposal. 

Vehicle owners may not substantially reduce their use of program vehicles or park these 

vehicles for extended periods of time without prior notification to the FAA (and sponsors 

if vehicles are tenant-owned). If any substantial change in projected or typical vehicle 

use occurs (e.g., hours or mileage), the sponsor and owners must provide timely notice to 

the FAA with updated project emission reduction estimates. This information must also 

be provided to the State air quality agency and the EPA.

 

19 Segways, for example, are considered non-essential and therefore are not eligible. 
4.5 Useful Life for Typical Airport Vehicles 

All vehicles acquired or converted under the VALE program must remain in operation at 

the airport for their useful lives (see Chapter 8 and Appendix C for “Special 

Conditions”). Table 4-1 provides average useful life data for typical new airport 

vehicles. These estimates should be used to calculate VALE project emission reductions 

unless a specific vehicle type (e.g., specialized GSE) is not included in the table or the 

sponsor can document more refined data to support modification of the estimate provided 

in the table. 

Airport-dedicated vehicles represent a variety of on-road and non-road vehicles. Because 

these vehicles operate primarily on airport property, their useful lives can differ from the 

typical life spans of the same vehicles when used off-airport. The following useful life 

estimates for common airport vehicle types are based on FAA project experience, airport 

air quality studies, and discussions with manufacturers, users, and airport consultants. 

Table 4-1. Average Useful Life of Typical Airport Vehicles 

Category/Type Average Useful Life (years) 

GSE

Baggage tug 13 

Belt loader 11 

Aircraft tractor 14 

Cargo loader 11 

Lavatory truck 13 

Cabin service truck 10 

Water service truck 10 

Deicer trucks 14 

Fork lifts 13 

Fuel cart 14 

Construction equipment 10 

Lawn care equipment 10 

Snow removal equipment 10 

Mobile ground power unit 10 

Emergency equipment 10 

GAV

Cars/vans/pickup trucks 10 

Flatbed/large trucks 12 

Vacuum sweeper trucks 10 

Fuel trucks 14 

Dump trucks 11 

19-35 foot buses 10 

40+ foot buses 12 

FAA VALE Program Technical Report Page 4-3 Version 7
4.6 New Vehicles and Incremental Costs 

For purposes of the VALE program, new vehicles are defined as vehicles purchased from 

an OEM or an associated dealer that are pre-market (i.e., “neofits”) with essentially zero 

miles. No retrofits, re-engined vehicles, or aftermarket modifications qualify as new. 

VALE program funding for new vehicles is restricted to the incremental cost of the 

vehicles. Incremental cost is defined as the differential in cost between the higher price 

for an eligible low-emission vehicle and the current market value for a new equivalent 

conventional fuel (i.e., gasoline or diesel) vehicle. Vehicle base costs are not eligible. 

The VALE program simply offers a way to offset the higher purchase price of a lowemission vehicle (i.e., incremental cost) as a factor in the owner’s decision about 

replacing a vehicle. By making low-emission vehicles no more expensive to purchase 

than conventional-fuel vehicles, the VALE program provides a reasonable incentive to 

buy cleaner vehicles. 

Incremental cost is the differential 

between the higher cost of an eligible 

low emission vehicle and the current 

market value for a new equivalent 

conventional fuel vehicle. 

The VALE program cannot be used 

under any circumstances to help finance 

the non-incremental base costs of airport 

low-emission vehicles. Vehicle owners 

must buy necessary new vehicles on 

their own. Moreover, sponsors may not 

use base costs for local matching funds 

or as any part of VALE grant and cost 

effectiveness calculations. 

In addition, program eligibility for all vehicles (new or retrofit) is limited to capital 

improvement costs and does not extend to O&M costs, including fuel. 

4.7 Vehicle Retrofit Technology 

The FAA prefers new vehicles to retrofits because new vehicles have longer useful lives, 

more reliable emissions savings, and greater cost-effectiveness. However, because it is 

not always feasible to purchase new vehicles and because verified retrofit technology has 

been shown to lower vehicle emissions, the FAA allows sponsors to acquire retrofit 

technology for existing vehicles. VALE retrofit projects must follow all of the airport, 

project, and vehicle eligibility requirements of the VALE program unless otherwise noted 

below. 

Verified retrofit aftermarket technology may be purchased through the VALE program 

for application on existing airport vehicles. An engine "retrofit" includes, but is not 

limited to, any of the following activities: 

FAA VALE Program Technical Report Page 4-4 Version 7
FAA VALE Program Technical Report Page 4-5 Version 7

 Addition of new/better pollution control after-treatment equipment to certified 

engines 

 Re-engining or re-powering 

 Upgrading of certified engines to cleaner certified configurations 

 Upgrading uncertified engines to cleaner "certified-like" configurations 

 Conversion of engines to cleaner fuels 

 Early replacement of older engines with newer (presumably cleaner) engines (in 

lieu of regular expected rebuilding) 

Only aftermarket low-emission technology that has been officially verified by the EPA or 

the California Air Resources Board (CARB) may be used to retrofit existing airport 

vehicles and equipment. For purposes of the VALE program, qualified vehicle retrofit 

technology is defined as the low-emission equipment and devices that are listed on the 

EPA website, www.epa.gov/otaq/retrofit under the menu selections: “Diesel Retrofit 

Technology Verification” and “Verified Technologies List”. Qualified retrofit 

technology extends to equipment and devices covered under the EPA and CARB 

Memorandum of Agreement, entitled “Coordination and Reciprocity in Diesel Retrofit 

Device Verification” (see links to “Memorandum of Agreement” and “CARB 

Verification Program” on the EPA website above).20 

Airport sponsors must provide documentation that the proposed retrofit after-treatment 

technology (e.g., particulate filters, catalytic converters, oxidation catalysts) is verified by 

EPA or CARB. In addition, the sponsor must provide or attach information in its VALE 

project application to meet the following requirements:21 

 The vehicle identification number (VIN) for each existing vehicle that is proposed 

for retrofitting (“target vehicle”). 

 Assurance that the target vehicle has a remaining useful life (RUL) of at least 

seven years. 

 Written confirmation from the manufacturer that the proposed retrofit technology 

or device is applicable to the engine type, model year, and configuration of the 

target vehicle if specific matching reference to the EPA or CARB verified 

products lists is unclear. 

 Analysis of estimated emissions benefits and cost-effectiveness using required 

program methodology, including models, reports, and project application 

worksheets (see Chapter 9 and Appendix D). 

 Assurance that program funding is not being used to retrofit a vehicle for a second 

time, regardless of how the initial retrofit of the vehicle was performed. 

 

20 Because no practical method exists for comparing new and retrofit vehicle low-emission ratings, vehicle 

retrofits proposed under the VALE program are not subject to VALE low-emission standards for new 

vehicles (see Chapter 5). As a result, the FAA will give priority consideration to retrofit projects that 

achieve the greatest emission reductions per dollar spent. 

21 The sponsor is responsible for any uncertainties or lack of information that may exist regarding the 

required verification. 
FAA VALE Program Technical Report Page 4-6 Version 7

Eligible expenses include the full cost of retrofitting existing vehicles with verified low 

emission equipment, notwithstanding AIP local matching requirements. Similar to costs 

for new low-emission vehicles, reasonable costs are also permitted for refueling or 

recharging equipment needed in support of retrofit vehicles that are powered by 

alternative fuels. 

Although AIP and PFC eligibility requirements for vehicle retrofits are similar (see 

above), the use of AIP funding for vehicle retrofits is more restrictive due to the limited 

authorization for vehicle retrofits through the Airport Ground Support Equipment 

Emissions Retrofit Pilot Program.22 Additional terms or restrictions under the AIP pilot 

program for retrofit vehicles include: 

 A limit of ten projects, each eligible for no more than $500,000. 

 The definition of eligible equipment as “ground service or maintenance 

equipment that is located at the airport [and] is used to support aeronautical and 

related activities at the airport...” (Vision 100) 

 Priority consideration for eligible equipment that is airport-owned versus possible 

tenant-owned equipment through the PFC program. 

 FAA Headquarter approval of pilot project applications. Sponsors that apply for 

AIP retrofit pilot projects should follow standard application procedures (see 

Chapter 2). FAA regional offices will consider the sponsor’s application for 

completeness and Headquarters (APP-400 and APP-520) will perform the 

technical and financial evaluations. 

 

22 49 U.S.C. §47140 per Vision 100, Section 159. 
CHAPTER 5 

PROGRAM LOW-EMISSION STANDARDS 

FOR NEW VEHICLES 

In accordance with Vision 100, the FAA has established new vehicle low-emission 

standards for the VALE program that represent the best achievable standards for 

emissions performance. These standards reflect the need for a balance between emission 

reductions and the commercial availability of proven low-emission technology. To 

maintain an appropriate balance, the FAA will review and update its vehicle lowemission standards and requirements annually in consultation with the EPA. 

Vehicles and engines that are eligible for AIP or PFC funding under the VALE program 

must either be EPA certified (new vehicles) or EPA verified (retrofit technology). 

Information about eligible retrofit aftermarket vehicle technology is provided in 

Chapter 4. 

This chapter specifically addresses new vehicles, which must be obtained directly from 

an OEM or an associated dealer to be eligible under the VALE program. VALE lowemission standards for new vehicles are based on EPA-certified national emission 

standards and are referenced in some cases to comparable California Air Resources 

Board standards. Eligibility is determined by the most recent year of vehicle certification 

data. 

The main purpose for establishing program low-emission vehicle standards is to ensure 

project cost effectiveness (i.e., lifetime emission reductions per project dollars spent). 

Accordingly, the FAA will not fund low-emission projects that simply offer a marginal 

benefit in the near term. By setting challenging emission standards at cleaner levels than 

presently regulated emission levels, the FAA seeks to invest in capital equipment that 

provides substantial emission reduction benefits over many years. 

The FAA is also interested in simplifying low-emission standards for sponsors by 

focusing solely on tail pipe emissions. Although the emissions from evaporation of fuels, 

hot soak, and crankcases are sometimes substantial, the inclusion of these emissions 

would increase the complexity of the VALE 

program. The VALE program is based on EPA 

tailpipe emissions and not the “wellto-wheels” approach that accounts for 

the full energy production cycle, 

including emissions from power 

plants, transmission losses, etc. 

The VALE low-emission standards apply to 

all eligible fuel types, whether they are AIPeligible (alternative fuels) or PFC-eligible 

(alternative fuels and clean conventional 

fuels). For purposes of the PFC program, 

FAA VALE Program Technical Report Page 5-1 Version 7
“clean conventional fuels” are eligible options if they lower vehicle emissions to meet 

VALE low-emission standards. 

Because VALE project applications and lifetime emission estimates are based on existing 

emission standards for the year of AIP or PFC funding, sponsors do not have to reassess 

emission reduction estimates or to replace vehicles and equipment purchased or upgraded 

through the VALE program in response to future changes in national EPA emission 

standards or in VALE program low-emission standards. 

5.1 Relationship of Federal Vehicle Emission Classes and VALE Low-Emission 

Categories 

The VALE program low-emission standards described below for new vehicles are based 

on a number of factors related to EPA national standards. The EPA (and CARB) 

classifies vehicles by size and use, engine type, and weight when assigning emission 

standards. For instance, vehicles are described as either on-road or non-road depending 

upon their use. The EPA defines on-road vehicles primarily by weight class, such as 

light, medium, and heavy duty. Non-road vehicles are defined primarily by engine type, 

such as spark-ignited (e.g., gasoline) versus compression-ignited (e.g., diesel), and by 

engine horsepower (hp) ratings. Table 5-1 below presents the EPA classifications for onroad vehicles and the corresponding low-emission categories for the VALE program. 

Table 5-1. Federal Vehicle Emission Classes and Corresponding VALE 

On-road Categories 

Federal Cutpoints 

Applied to VALE Standards 

(GVWR in pounds) 

Federal Class 

VALE 

On-Road 

Categories 

Passenger Cars and Trucks 

 6,000 

PC 

LDT1 

LDT2 

1 

LDV 

Trucks 

6,001 - 8,500 

LDT3 

LDT4 

Comp. HDV < 10,000, < 6’ Cargo 

Box, 

 12 Seats/ 9 Rear 

MDPV 

2 

MDV 

HD Vehicles or Trucks >8500 

and Not MDPV HDV 3 HDV 

GVWR – Gross vehicle weight rating 

PC – Passenger car 

LDT – Light duty truck 

LDV – Light duty vehicle 

MDPV – Medium duty passenger vehicle 

HDV – Heavy duty vehicle

FAA VALE Program Technical Report Page 5-2 Version 7
Developing effective low-emission vehicle classifications and standards for the VALE 

program is difficult for several reasons. Sometimes EPA low-emission standards for 

certain vehicle categories are not stringent enough for some pollutants, and sometimes 

they are too stringent, at least for the next few years while vehicle manufacturers 

endeavor to meet them. In addition, EPA low-emission standards are generally 

developed on the basis of fleet averaging and monitored by the EPA according to 

individual manufacturers. In contrast, the VALE program is focused on the acquisition 

of individual airport vehicles that meet applicable low-emission standards regardless of 

manufacturer or fleet ownership.

Light duty vehicles (LDVs) are a good example of EPA fleet averaging for emissions. 

Specifically, the total population of LDVs produced within a model year is balanced by 

emissions performance centered on the EPA Tier2-Bin5 emissions standard (ranging 

from the cleanest Bin1 to the dirtiest Bin8). In contrast, the best achievable low-emission 

standard for LDVs purchased and deployed under the VALE program, Tier2-Bin3, is 

more stringent than the Tier2-Bin5 industry fleet average. Based on EPA national fleet 

standards, VALE standards pursue the best performing individual vehicle technology for 

lowering emissions at specific airports. 

The following VALE program low-emission standards for new vehicles are intended to 

produce the greatest emission reductions and associated AERCs. The emission standards 

are broken down into five vehicle categories, consisting of three standards for on-road 

vehicles and two standards for non-road vehicles: 

 On-road light duty vehicles and trucks (LDVs and LDTs) 

 On-road medium duty vehicles (MDVs) 

 On-road heavy duty vehicles (HDVs) 

 Non-road spark-ignition (SI) vehicles 

 Non-road compression-ignition (CI) vehicles 

It is important to note that dedicated electric drive vehicles, which EPA rates as zero 

emissions, meet the program standards in all vehicle categories. 

FAA VALE Program Technical Report Page 5-3 Version 7
FAA VALE Program Technical Report Page 5-4 Version 7

5.2 On-road Program Low-Emission Standards 

The following three subsections describe on-road vehicle program standards. 

5.2.1 Vehicle Category 1 – On-road LDVs 

Vehicle Category 1 Program Low-Emission Standard 

On-road Light-Duty Vehicles 

(LDVs) 

Combined EPA Tier2-Bin2 

and EPA CO2 ratings 

Vehicle Category 1 is limited to on-road light duty vehicles (LDVs), including 

passenger cars (PCs) and lighter duty trucks (LDT1 and LDT2) that would be 

used at an airport. The vehicles in this category cannot weigh mores than 6,000 

pounds gross vehicle weight rating (GVWR).23 Relative to GSE and other airport 

service vehicles, on-road LDVs represent a small population at airports. 

The program Category 1 standard is a combined standard for criteria pollutants 

and greenhouse gases. It is based on EPA Green Vehicle Guide ratings of 0-10 on 

Air Pollution and Greenhouse Gas Scores. The web address for the EPA Green 

Vehicle Guide is: www.epa.gov/greenvehicles/. 

The program standard for Category 1 is set between the EPA “SmartWay” and 

“SmartWay Elite” classifications. Eligible low-emission vehicles must score “8” 

or higher on both the Air Pollution Score (equal to the Tier2-Bin2 certification 

level) 24 and the Greenhouse Gas Score, and must achieve a combined score of at 

least 17 when added together. In effect, one of the two scores must be at the 

cleaner level of “9” or “10”. 

Commercial Availability. Vehicle eligibility under Category 1 applies to the last 

complete model year or new model year listed in the EPA Green Vehicle Guide. 

Several small and mid-size passenger vehicles meet Category 1 program 

standards, including several hybrids: Ford Fusion, Lincoln MKZ, Mercury Milan, 

Honda Civic, Nissan Altima, and Toyota Camry.25 Also, the CNG-fueled Honda 

Civic is potentially eligible, as are all-electric vehicles. Eligibility depends on 

whether the vehicle is manufactured in the U.S. and, in some cases, whether the 

California-certified version of the vehicle is selected. 

 

23 GVWR is the value specified by the manufacturer as the maximum design loaded weight of a single 

vehicle (40 CFR 86.1803-01). 

24 Regarding the Air Pollution Score, manufacturers can certify vehicles under Federal emission standards 

or cleaner California emission standards. If necessary, sponsors should contact manufacturers to determine 

the national availability of California-certified vehicles.

25 The Toyota Prius hybrid does not currently meet the AIP “Buy American” requirement but is expected to 

do so in the future with Toyota’s plans to manufacture hybrid vehicles in the United States. 
FAA VALE Program Technical Report Page 5-5 Version 7

5.2.2 Vehicle Category 2 – On-road MDVs 

Vehicle Category 2 Program Low-Emission Standard 

On-road Medium Duty 

Vehicles (MDVs) 

EPA Tier2-Bin5 

Vehicle Category 2 is limited to medium size vehicles (MDVs) that weigh over 

6,000 pounds GVWR.26 Vehicles in this category include passenger and cargo 

vans (MDPVs) and heavier light duty trucks (LDT3 and LDT4). Vehicles of this 

size are popular at airports nationwide because of their passenger and cargo 

storage capacities. Fleet averaging methodology applies to certified emissions 

from MDVs as well as for the smaller VALE Category 1 LDVs. Because the 

industry averages emissions for MDVs and LDVs together, the heavier MDVs are 

typically found on the “dirtier” side of the fleet average standard of Tier2-Bin5. 

Commercial Availability. Based on EPA Green Vehicle Guide Air Pollution 

Scores for the last complete or new model year, several pick-up trucks may meet 

Vehicle Category 2 standards. An Air Pollution Score of “5” equals the Tier2-

Bin5 certification level. However, because the EPA does not publish certified 

vehicle weights, these data need to be obtained from the manufacturer and then 

verified with the FAA and EPA. Eligible vehicles in this category include the 

following hybrid gasoline-electric models: GMC Sierra (6,400 GVWR), GMC 

Yukon 1500 (7,200 GVWR) Chevrolet Silverado (6,100 GVWR), and Chevrolet 

Tahoe 1500 (7,100 GVWR). Also, the dedicated CNG Ford 350 van (8,700 

GVWR) may be eligible, as well as any all-electric vehicles in this category. 

Flexibility Provision. In recognition of the current limited availability of MDVs 

at the Tier2-Bin5 level, particularly vans, sponsors have the option of acquiring 

MDVs (including hybrids) that are EPA-certified to meet Tier2-Bin5 standards 

for the applicable Level One pollutants only. For example, if an airport is located 

in an ozone nonattainment area, the proposed vehicle only needs to meet the lowemission standards for nitrous oxides (NOx) and non-methane organic gases 

(NMOG). In a CO nonattainment area, the proposed vehicle only needs to meet 

the low-emission standard for CO. In a PM nonattainment area, the proposed 

vehicle only needs to meet the low-emission standard for PM. 

The FAA provides this flexibility provision because of the shortage of vehicles in 

this category to meet the low-emission standards at this time. The sponsor may 

use this provision only when the VALE program application includes a 

demonstration that no reasonable commercial options are available for similar 

vehicle types that meet the VALE program low-emission standards for all 

 

26 EPA does not publish certified vehicle weights. Consequently, sponsors should verify Category 2 

vehicle weights with the FAA and EPA using manufacturer data and documentation. 
pollutants. Sponsors should consult the EPA Green Vehicle Guide website, 

OEMs, and other information sources in making this demonstration. 

New technology is expected to meet the Vehicle Category 2 standards soon. 

Once reasonable commercial availability exists for this category, then the 

flexibility provision will no longer be valid. 

FAA VALE Program Technical Report Page 5-6 Version 7
FAA VALE Program Technical Report Page 5-7 Version 7

5.2.3 Vehicle Category 3 – On-road HDVs 

Vehicle Category 3 Program Low-Emission Standard 

On-road Heavy-Duty 

Vehicles (HDV) 

EPA On-road Heavy-Duty 

Emission Standards (g/bhp-hr) 

0.17 - NOx 

0.13 - NMHC 

6.5 - CO 

0.009 - PM 

Vehicle Category 3 is limited to HDVs, which represent the largest on-road 

vehicles weighing more than 8,500 pounds GVWR, such as fueling and catering 

trucks.27 The EPA HDV standards for the VALE program are: 0.17 grams per 

brake horsepower hour (g/bhp-hr) for NOx, 0.13 g/bhp-hr for non-methane 

hydrocarbons (NMHC), 6.5 g/bhp-hr for CO, and 0.009 g/bhp-hr for PM. 

The latest EPA heavy-duty diesel vehicle (HDDV) emission standards were fully 

implemented in 2010 with the support of credits from the averaging, banking, and 

trading program (ABT Program). The on-road HDDV emission standards 

complement the 2006 on-road HDDV mandate regarding ultra-low sulfur diesel 

fuel (ULSD). 

 

Commercial Availability. Engine manufacturers including Cummins Westport, 

BAF Technologies, Doosan Infracore America, and Baytech Corporation have 

certified natural gas (CNG) engine technologies that meet the Category 3 

standards. Likewise, the standards are met by Clean Fuel USA and Baytech 

Corporation with propane (LPG) engine technologies, by Capstone Turbine 

Corporation with diesel-hybrid technology, and by Azure Dynamics with 

gasoline-electric hybrid technology. Within this category, several manufacturers 

produce “medium-heavy duty” and “heavy heavy-duty” engines, which in some 

cases are designed for urban buses. This information indicates that the 

commercial potential exists in the near term to achieve the low-emission 

standards for Vehicle Category 3, thus eliminating the need for a flexibility 

provision in this category. 

 

27 An exception is MDPVs, which can weigh up to 10,000 pounds GVWR. 
5.3 Non-road Program Low-Emission Standards 

The following two subsections describe the VALE program low-emission standards for 

non-road vehicles. Non-road standards differ from on-road standards in that they are 

based on the horsepower (hp) of the engine rather than the vehicle weight (GVWR). 

Because the non-road standards presented below are for SI and CI engines, sponsors 

interested in purchasing non-road alternative fuel vehicles (AFVs) are allowed to meet 

the less stringent standards between Vehicle Category 4 (SI) and Vehicle Category 5 

(CI/diesel) for each certification pollutant. 

5.3.1 Vehicle Category 4 – Non-road Spark-Ignition Vehicles 

Vehicle Category 4 Program Low-Emission Standard 

Non-Road 

SI Vehicles EPA Blue Sky Engine Program 

The only regulatory mechanism that preserves adequate cost effective emission 

reductions for large SI non-road engines is the EPA’s voluntary Blue Sky Engine 

Program, which mandates qualifying emission standards of 0.6 g/bhp-hr for 

HC+NOx and 3.28 g/bhp-hr for CO. EPA-certified vehicles that meet Blue Sky 

Engine Program low-emission standards are eligible under the VALE program. 

Because the Blue Sky Engine Program does not set a PM standard, the on-road 

standard for PM was applied for consistency. 

Commercial Availability. Vehicles in this category include forklifts, electric 

generators, aircraft GSE, and various types of construction and industrial 

equipment. We are unaware of specific engine manufacturers with certified 

products under the Blue Sky Engine Program but many electric equipment 

manufacturers that produce battery-powered GSE and other electric non-road 

vehicles meet the Category 4 standards. Therefore, sponsors are encouraged to 

pursue electric and other AFVs certified to meet the Blue Sky Engine Program 

standards. 

Flexibility Provision. There may be non-road vehicle types that do not have a 

commercially available electric version or equivalent that meets the low-emission 

standards for all pollutants. In this case, the FAA provides the flexibility to 

acquire non-road vehicles (including hybrids) that are EPA-certified to meet the 

less stringent standard of VALE Vehicle Categories 4 and 5 for the applicable 

Level One pollutant(s) only. 

For example, if an airport is located in an ozone nonattainment area, the proposed 

vehicle only needs to meet the low-emission standards for NOx and HC. In a CO 

nonattainment area, the proposed vehicle only needs to meet the low-emission 

FAA VALE Program Technical Report Page 5-8 Version 7
standard for CO. In a PM nonattainment area, the proposed vehicle only needs to 

meet the low-emission standard for PM. 

The FAA provides this flexibility provision because of the shortage of vehicles in 

this category to meet the low-emission standards at this time. The sponsor may 

use this provision only when the VALE program application includes a 

demonstration that no reasonable commercial options are available for similar 

vehicle types that meet the VALE program low-emission standards for all 

pollutants. Sponsors should consult the EPA Green Vehicle Guide website, 

OEMs, and other information sources in making this demonstration. Once 

reasonable commercial availability exists for this category, then the flexibility 

provision will no longer be valid. 

FAA VALE Program Technical Report Page 5-9 Version 7
5.3.2 Vehicle Category 5 – Non-road Compression-Ignition Vehicles 

Vehicle Category 5 Program Low-Emission Standard 

Non-road 

CI Vehicles EPA Tier 4 standards 

EPA Tier 4 non-road diesel engine emission standards apply to Vehicle Category 

5. These stringent low-emission standards for non-road diesel engines, which 

began in 2008, are based on the use of ULSD fuel and the growing ability of nonroad engine manufacturers to incorporate advanced clean engine technologies to 

meet Tier 4 emission requirements. 

Commercial Availability. The FAA is aware of many electric equipment 

manufacturers that produce battery-powered GSE and other electric non-road 

vehicles that meet the low-emissions criteria for this vehicle category. Therefore, 

sponsors are encouraged to pursue electric and other AFVs certified to meet the 

Tier 4 Standards. 

Flexibility Provision. There may be non-road vehicle types that do not have a 

commercially available electric version or equivalent that meets the low-emission 

standards for all pollutants. In this case, the FAA provides the flexibility to 

acquire non-road vehicles (including hybrids) that are EPA-certified to meet the 

less stringent standard of VALE Vehicle Categories 4 and 5 for the applicable 

Level One pollutant(s) only. 

For example, if an airport is located in an ozone nonattainment area, the proposed 

vehicle only needs to meet the low-emission standards for NOx and HC. In a CO 

nonattainment area, the proposed vehicle only needs to meet the low-emission 

standard for CO. In a PM nonattainment area, the proposed vehicle only needs to 

meet the low-emission standard for PM. 

The FAA provides this flexibility provision because of the shortage of vehicles in 

this category to meet the low-emission standards at this time. The sponsor may 

use this provision only when the VALE application includes a demonstration that 

no reasonable commercial options are available for similar vehicle types that meet 

the VALE program low-emission standards for all pollutants. Sponsors should 

consult the EPA Green Vehicle Guide website, OEMs, and other information 

sources in making this demonstration. Once reasonable commercial availability 

exists for this category, then the flexibility provision will no longer be valid. 

FAA VALE Program Technical Report Page 5-10 Version 7
5.4 Summary of VALE Program Low-Emission Vehicle Standards 

The standards presented in Table 5-2 are currently in effect to ensure the best achievable 

program emission benefits. These standards will be reviewed annually and may be 

modified in the future, in consultation with the EPA, to reflect changing EPA standards, 

advances in vehicle, engine, and tailpipe technologies, and FAA program costeffectiveness considerations. 

FAA VALE Program Technical Report Page 5-11 Version 7
Table 5-2. Summary of VALE Low-Emission Standards for New Vehicles 

FAA VALE Program Technical Report Page 5-12 Version 7

On-road Vehicles: 

Vehicle Vehicle Best Achievable Low- NOx NMOG CO PM 

Category Classification Emission Standard (g/mile) (g/mile) (g/mile) (g/mile) 

Tier2-Bin2 

(and EPA Green 

Vehicle Score) 

1 LDV & LDT 0.02 0.01 2.1 0.01 

MDV1 2 Tier2-Bin5 0.07 0.09 4.2 0.01 

NOx NMHC CO PM

(g/bhp-hr) (g/bhp-hr) (g/bhp-hr) (g/bhp-hr) 

 Alternative, diesel, 

and gasoline engines 3 HDV 0.17 0.13 6.5 0.009 

1) EPA 120,000 mile certification level standards for this category (ref. www.epa.gov/otaq/standards/index.htm)

Non-road Vehicles: 

Vehicle 

Category 

Vehicle Maximum NOx HC NOx + HC CO PM Classification & Engine 

Standard Power (hp) (g/bhp-hr) (g/bhp-hr) (g/bhp-hr) (g/bhp-hr) (g/bhp-hr) 

Non-Road SparkIgnitition (SI) 

Blue Sky Engine 

Program Standards 

0.481 0.121 0.012 4 > 25 0.6 3.28 

for 

any engine/fuel 

type 

< 75.1 NA NA 3.50 3.73 0.02 

75.1 ≤ HP 

< 174.3 0.30 0.14 0.44 3.73 0.01 

Non-road 

 CompressionIgnition (CI) 

Based on EPA 

174.3 ≤ HP 

≤ 751 0.30 0.14 0.44 2.61 0.01 

Tier 4 standards 5 for 

0.503 0.143 0.64 2.613 0.023

any engine/fuel 

type 

HP > 751 2.61 0.14 2.74 2.61 0.03 

1) The voluntary EPA Blue Sky Engine Program only establishes a combined standard for HC+NOx for large SI non-road engines. Based 

on discussions with EPA, an 80/20 split is assumed between NOx and HC for purposes of certifying engines to meet program standards. 

2) There is no Blue Sky Engine Program standard for PM in this category. Consequently, the on-road standard for PM has been adopted. 

3) Emission standards apply to non-road diesel engines greater than 751 Hp that power generator sets only. 
CHAPTER 6 

INFRASTRUCTURE ELIGIBILITY AND FUEL 

FACILITY GUIDELINES

This chapter discusses the eligibility of infrastructure projects for VALE program 

funding, the useful life of such infrastructure, and fuel facility guidelines. 

6.1 Infrastructure Project Eligibility 

VALE program funding can be used to purchase, construct, and install many types of 

low-emission infrastructure systems. Activity in this area may include reducing airport 

emissions by displacing mobile equipment, increasing energy efficiency, or reducing the 

consumption of conventional fuels through the use of new, upgraded, or converted 

equipment or facilities. To be eligible for VALE program funding, the low-emission 

infrastructure improvements must be cost effective, use alternative fuels, and incorporate 

proven technology. Any infrastructure and equipment projects that are not discussed in 

this chapter but that might qualify under the VALE program should be discussed with the 

FAA early in the planning process. 

Infrastructure development funded under the VALE program must be located within the 

airport boundary. Airport sponsor ownership of equipment is required in most instances 

and generally preferred to ensure accountability and to avoid potential problems with 

tenants that relocate or experience financial difficulties (see Chapter 7). 

For any infrastructure project, the sponsor 

must demonstrate that the main purpose of the 

project is to reduce airport emissions. The 

sponsor must also show that the proposed 

activity is in compliance with all AIP, PFC, 

and VALE program funding conditions and 

requirements. 

Eligible infrastructure projects for 

the VALE program must be 

designed primarily for airport 

emission reductions. 

Program infrastructure funding through the VALE program is limited to the area within 

the airport boundary and further limited to the portion of an eligible airport project that is 

directly associated with the VALE program. For example, funding for electric power 

upgrades to support gate electrification or vehicle rechargers is limited to system 

elements within the airport boundary as well as to electrification demand that is directly 

related to eligible VALE activities, excluding other airport or facility electrification needs 

that may or may not be AIP or PFC eligible otherwise. Consequently, the FAA will not 

FAA VALE Program Technical Report Page 6-1 Version 7
award VALE AIP discretionary resources for measures that are indirectly related or 

incidental to VALE technology. 

6.1.1 Refueling and Recharging Stations 

AFV refueling and recharging stations are eligible for VALE program funding, 

including fast-chargers, on-site fuel storage tanks, and other stationary 

components needed for station operation. 

The size of the proposed refueling or recharging station(s) must match the 

planned and reasonably foreseeable fueling requirements of the airport. Sponsors 

may size the facility to the maximum size needed to service the anticipated level 

of project AFVs, plus some additional limited capacity for public fleets (see 

discussion of public access below). In applying for facility and equipment 

funding, the sponsor must clearly document the number of project AFVs, other 

airport-dedicated AFVs, and public AFVs that will access the facility. Sponsors 

must provide letters of commitment from non-airport AFV owners to support 

their proposed facility use plans. 

Specifically, sponsors may size the proposed VALE-funded fueling station so that 

the maximum intended airport use would consume 90 percent of the capacity of 

the station. No more than 10 percent of station capacity can be dedicated to 

public use. During the interim period between the operational start of the 

refueling and recharging station and the full 90-100 percent use of the station by 

airport AFVs, the sponsor may allow public access on a temporary basis up to the 

existing capacity of the station. 

Public Access

VALE funding is intended primarily for airport operations and vehicles. 

However, the sponsor may grant limited public access to airport refueling and 

recharging stations supported by the VALE program under certain conditions. If 

public access to these facilities is granted, 

the sponsor must guarantee security and 

public safety. This includes locating the 

airport refueling or recharging station at a 

reasonable distance from the airport 

terminal and outside of the main airport 

security areas. In addition, the sponsor 

should certify public users and track their 

use of the facility. If public access is granted, sponsor and airport vehicles are 

entitled to priority use of the facility, especially in the event of fuel shortages or 

emergencies. 

Public access to refueling and 

recharging stations is allowed if 

security and public safety are 

guaranteed. 

FAA VALE Program Technical Report Page 6-2 Version 7
FAA VALE Program Technical Report Page 6-3 Version 7

Sponsors may wish to coordinate with other operators of AFV refueling or 

recharging stations (e.g., freight depots, van shuttle services) in the area. 

Although these fleets are not eligible for funding under the VALE program, an 

informal arrangement to assist each other in case of equipment failure or 

emergency can provide a useful back-up plan for airport operations. 

Sponsors may be able to claim some of the emission reductions and AERCs from 

public use of airport refueling and recharging stations purchased with the 

assistance of the VALE program. 

6.1.2 Gate Electrification 

Gate electrification is the aircraft 

equivalent of vehicle idle emission 

reduction. Its purpose is to provide 

pre-conditioned air (PCA) and 

electrical power for aircraft parked 

at the gates. It reduces or eliminates 

the use of higher-emitting aircraft 

auxiliary power units (APUs) that use jet fuel and mobile ground generators that 

use diesel fuel. 

Aircraft gate electrification projects include directly related upgrades to the power 

supply from the airport boundary to the terminal building, electrical 

improvements at aircraft gates, and power improvements within gate areas that 

provide electricity for aircraft auxiliary power and for GSE recharging. 

For purposes of verification and compliance with VALE project tracking 

requirements, gate power and PCA projects must include the installation of meters 

that monitor and record electricity usage for each project gate and PCA unit. 

6.1.3 Power Plants, HVAC Systems, and Generators 

Airport sponsors may build or retrofit power plants and heating, ventilation, and 

air conditioning (HVAC) equipment located within the airport boundary if the 

proposed improvements use alternative fuels and result in cost effective airport 

emission reductions. Eligible power generation and HVAC systems, including 

emergency back-up power units, must be powered by eligible alternative fuels 

such as natural gas, solar photovoltaics28, hydrogen fuel cells, wind power, and 

geothermal systems. Airport sponsors may also develop cogeneration facilities, 

which are eligible to the extent that they directly displace fuel use and provide 

electricity and hot water/steam to the airport for power, heating, and other 

essential functions. 

 

28 See FAA Airports 2010 solar guidance report, available from the Airports website. 

Similar to electric vehicles, 

electric powered infrastructure 

improvements are considered zero 

emissions under the program. 
6.1.4 Underground Fuel Hydrant Systems 

Underground fuel hydrant systems deliver aviation fuels from the bulk storage 

tanks to aircraft gates. Construction and development of underground fuel 

hydrant systems within the airport boundary are eligible to the extent that the 

system directly reduces the number and use of fuel trucks at the airport. 

6.1.5 Public Transit Projects at Airports 

Airport projects that displace or remove vehicles from airport roadways, such as 

people mover systems, public transit lines (only sections at and within the airport 

boundary), and intermodal connection stations may qualify for VALE funding 

under the PFC program. PFC funds may be used to complement the main source 

of funding from other Federal transportation programs. The value of requesting 

PFC funding for transit-related projects through the VALE program is the 

opportunity for AERCs. 

6.2 Non-Eligible Activities 

Eligible infrastructure activities for the VALE program must be designed and 

implemented primarily for the purpose of reducing airport emissions. Among activities 

that are generally not eligible are projects that may reduce airport emissions but are 

designed primarily to meet other requirements, such as operating efficiency, public 

convenience, congestion mitigation, safety, and security (e.g., parking and cell phone 

lots, consolidated rental car facilities, automated vehicle management systems). Other 

projects that are not eligible are research-related projects and private revenue producing 

projects (e.g., fuel farms), unless specifically permitted under AIP, PFC, or VALE 

program guidelines. 

6.3 Cost-Sharing Factors

If VALE funding is requested as part of a large airport improvement project, the FAA 

may only be able to participate on a limited basis. In addition to the basic program 

eligibility requirements (see Chapters 4, 6, 7, and 8), the FAA will consider the following 

cost-sharing factors for projects that are large, provide reasonable payback periods, or 

exceed recommended program cost effectiveness ranges: 

 

 Is VALE funding critical to project feasibility or to the sponsor’s ability to 

earn needed AERCs for CAA purposes? 

 

FAA VALE Program Technical Report Page 6-4 Version 7
FAA VALE Program Technical Report Page 6-5 Version 7

 Is the VALE program enlisted early in the design process to confirm the 

emission reduction purpose of the project? 

 Is the sponsor willing to increase its local cost share to assume a 

reasonable portion of risk? 

 Is the sponsor willing to consider using its AIP entitlements as well as 

discretionary funding to underscore the importance of the project? 

 What is the participation level of other organizations (e.g., Federal and 

State agencies, private firms, utilities)? 

The level of VALE support may be subject to one or more of the following limitations: 

 The portion of the project representing non-revenue producing public-use 

areas that are directly related to the movement of passengers and 

baggage29

 The portion of the project directly related to VALE equipment (e.g., the 

portion of terminal electrical system upgrades dedicated to a gate 

electrification project) 

 The incremental cost of an alternative fuel system provided an equivalent 

conventional fuel system is an option. If no incremental cost comparison 

is applicable, funding may be limited to a “dollar per ton” limit based, for 

example, on the best cost effectiveness for ozone emission reductions.

Once VALE-eligible costs are determined, the standard AIP Federal cost share (see Table 

7-3, Infrastructure Funding) is applied to establish the VALE project funding level. 

6.4 Useful Life for Typical Airport Low-Emission Infrastructure 

Table 6-1 provides average useful life data for typical infrastructure projects that can 

reduce airport emissions effectively. These data should be used to calculate VALE 

project emission reductions unless the table does not contain a needed equipment type or 

the sponsor can document more refined data to support modification of the information 

provided. 

The average useful lives of certain types of stationary equipment and infrastructure 

projects can range from 13 to 40 years.30 

 

29 AIP Handbook (Order 5100.38C), Section 601 

30 See EPA AERC Report: Guidance on Airport Emission Reduction Credits for Early Measures through 

Voluntary Airport Low Emission Programs, Section 6.2: Life of the AERCs, September 2004. 
Table 6-1. Average Useful Life of Typical Airport Infrastructure 

Category/Type Average Useful Life 

(years) 

Gate ground power/electrification 20 

Gate pre-conditioned air unit (PCA) 13 

Electric vehicle recharger 13 

New CNG refueling station 30 

Underground fuel hydrant system 40 

People mover or transit connection 30 

New boilers or HVAC system 20 

6.5 Fuel Facility Guidelines 

Fuel facility considerations for each major alternative fuel type are discussed in this 

section. Following this discussion, Table 6-2 provides a summary that contains “fueling 

station footprint” data, for example, to compare the size of various alternative fuel 

stations with a conventional gasoline station. 

6.5.1 Electric 

Although electricity is considered an alternative fuel, it is technically not a fuel, 

but a pure energy source. Therefore, some considerations that apply to alternative 

fuels do not apply to electricity. 

Fuel Availability: An electric charging station may be installed where access is 

available to the local electric utility power distribution system. Electric vehicle 

rechargers may place a burden on the airport’s electrical system. Sponsors may 

consider using “bridge mounted interruptible power” to avoid the cost of 

upgrading the airport electrical system. These units prioritize power use for jet 

bridge movement over the rechargers. The limited movement of jet bridges 

provides nearly continuous power to the rechargers. 

Fueling Station Footprint: Because no fuel needs to be stored, electric vehicle 

charging stations are much smaller than conventional gasoline/diesel fueling 

stations. The space required to park vehicles at the rechargers must be 

considered. 

Fuel Storage and Special Handling Requirements: A variety of charging systems 

are available to best fit airport needs. Conventional charging systems offer the 

lowest cost option. These systems typically require 6 to 8 hours to charge a 

vehicle battery and may not be suitable for some busier airport operations. Some 

FAA VALE Program Technical Report Page 6-6 Version 7
conventional chargers can be mounted on-board the vehicle. Vehicles are then 

plugged into standard outlets at common voltages, such as 120 or 208 volts. 

Fast charging systems, in contrast, are capable of charging a large GSE battery 

from 20 percent to 80 percent of full charge in less than 2 hours. By "opportunity 

charging" during operator break periods, GSE can be operated continuously over 

several shifts without draining the battery to empty. These intelligent computer 

controlled systems extend battery life and store valuable vehicle operations data. 

Fast chargers automatically adjust the power they deliver to the battery to avoid 

over-charging and over-heating, which could cause damage. Installation costs are 

higher than for conventional chargers, as these systems typically require more 

electrical capacity. 

A variety of vehicle connectors are also available. Conductive systems are the 

lowest cost and most common. These systems are based on the mating of metallic 

contacts. Inductive systems, in contrast, have no metal contacts, thereby 

providing an additional layer of operator safety. A paddle-like connector is 

inserted into a slot on the vehicle. Magnetic induction is used to transfer energy 

from the charging station to the vehicle. 

6.5.2 Compressed Natural Gas (CNG) 

Fuel Availability: A CNG fueling station may be located wherever there is local 

access to a natural gas distribution or transmission system. The expense of 

extending the underground gas piping system significant distances may be a 

consideration. 

Fuel Storage: CNG is stored above ground in high-pressure steel vessels. This 

significantly increases the footprint of fueling stations that use storage banks. 

Fueling Station Footprint: Generally speaking, there are three approaches to 

fueling compressed gas into vehicles. Each has different footprint characteristics, 

and each is discussed separately below. 

The first CNG method, Time-Fill, requires that a vehicle remain connected to the 

dispenser for a period of hours. This is a very economical and small footprint 

approach that can be integrated into a vehicle storage facility or yard. In a typical 

application, vehicles are active during the day and then return to a central facility 

at night. A small, inexpensive compressor system is used to compress the natural 

gas onto the vehicle over several hours. 

The second method, Cascade Fast-Fill, allows a vehicle to be fueled within a few 

minutes, similar to gasoline or diesel fueling. To do this, the gas is compressed 

and stored in high-pressure steel tanks located at the fueling station. Because the 

gas must be pressurized and stored on site, these stations are typically 

FAA VALE Program Technical Report Page 6-7 Version 7
significantly larger in size, more complex, and more expensive to design and 

construct than a conventional gasoline or diesel fueling station. In a typical 

application, vehicles are fueled in high volume at peak times from the highpressure storage tanks. When the peak period is over, the compressor runs 

continuously for a period of time to return the storage tanks to maximum pressure 

and then shuts down. This approach is not suitable for continuous, high-volume 

fueling. 

The third method, Buffered Fast-Fill, is also very fast, and also supports 

continuous, high-volume fueling for fleets of heavy duty vehicles such as transit 

buses. Because buffered fast-fill systems use even larger and more powerful 

compressors, they are the largest and most complex of all natural gas fueling 

stations. 

Special Handling Requirements: Despite misperceptions to the contrary, natural 

gas is actually a safer fuel than gasoline because it is difficult to ignite (ignition 

temperature is about 1,100 0

F) and is lighter than air. Leaks do not pool beneath a 

vehicle as gasoline leaks do. Natural gas is non-toxic. The greatest safety 

concern with CNG is that the gas is stored at high pressure capable of projecting 

fittings and couplings at high velocity. Drivers can be trained to fuel their own 

vehicles safely. 

6.5.3 Liquefied Natural Gas (LNG) 

Fuel Availability: LNG is normally supplied by delivery trucks so LNG fueling 

stations may be located where there is sufficient roadway access. 

Above or Below Ground Storage: LNG is usually stored above ground in 

cryogenic tanks. However, LNG tanks may also be stored below grade in an open 

pit.

Fueling Station Footprint: LNG has a significantly greater energy density than 

natural gas at atmospheric pressure, but it is still lower in energy density than 

gasoline, requiring about 50 percent more volume than gasoline for a similar 

amount of energy. Because LNG is denser than CNG and does not need to be 

compressed, LNG stations require less area than CNG stations. Nevertheless, 

LNG fueling station footprints are usually larger than footprints of conventional 

gasoline stations. The use of vertical LNG storage tanks can reduce real estate 

requirements. 

Special Handling Requirements: Because LNG is a cryogenic liquid, it requires 

additional emergency and safety considerations, including the use of special 

fittings and protective clothing. Vehicle fueling is usually performed by a trained 

technician. 

FAA VALE Program Technical Report Page 6-8 Version 7
6.5.4 Liquefied Petroleum Gas (LPG or Propane) 

Fuel Availability: LPG is supplied by delivery trucks so fueling stations should 

be located where there is roadway access. 

Fuel Storage: LPG is stored above ground in low-pressure steel tanks.

Fueling Station Footprint: LPG contains more energy per unit of volume than 

natural gas at atmospheric pressure, but it is still less energy dense than gasoline, 

requiring about 33 percent more volume than gasoline for a similar amount of 

energy. Since LPG is a liquid fuel at low pressure, the station footprint is slightly 

larger than gasoline/diesel stations, mostly as a result of the need to store propane 

above ground. A skid-mounted system equipped with a vertical tank and 

dispenser requires about the same or less real estate as the retail propane 

dispensers found at many retail gasoline stations. 

Special Handling Requirements: Because LPG is heavier than air, leaks may pool 

beneath a vehicle. Propane is non-toxic. Drivers can be trained to fuel vehicles 

safely.

6.5.5 Ethanol (E85)/Methanol (M85) 

Fuel Availability: E85 is supplied by delivery truck. Distribution is limited but 

growing outside of the Midwest. M85 is not currently commercially available. 

Fuel Storage: Below ground storage is common.

Fueling Station Footprint: The fueling station footprint would be the same as for 

conventional gasoline or diesel fueling facilities. 

Special Handling Requirements: The dispensing technique of these fuels is 

similar to that for gasoline. Because of the corrosive solvent nature of ethanol 

and methanol, contact with skin and other materials should be avoided. 

6.5.6 Hydrogen 

Fuel Availability: At present, there is no underground pipeline system for 

hydrogen. Liquid hydrogen is currently distributed over the road by industrial gas 

vendors. Alternatively, hydrogen may be produced on-site by a variety of 

methods, which include steam reforming of natural gas and electrolysis. Where 

natural gas is reformed, access to the natural gas distribution or transmission 

system is necessary. 

FAA VALE Program Technical Report Page 6-9 Version 7
Fuel Storage: Compressed hydrogen is stored above ground in high-pressure 

steel tanks. Liquid hydrogen is stored above ground in cryogenic vessels. 

Fueling Station Footprint: On-site production of hydrogen by electrolysis or 

reforming increases the overall footprint of a hydrogen fueling station. The 

amount of equipment required to generate hydrogen fuel and store it makes 

hydrogen fueling stations real estate intensive. 

Special Handling Requirements: Even at 10,000 psi, hydrogen contains only twothirds the energy, by volume, of CNG at 3,000 psi. To achieve viable 

performance, vehicles will need to store hydrogen on board at pressures ranging 

from 5,000 to 10,000 psi, posing significant technical and safety challenges. 

6.5.7 Biodiesel (B85-B100) 

Fuel Availability: Biodiesel is delivered via truck. Distribution is limited but 

growing. 

Fuel Storage: Storage is the same as for conventional diesel fuel.

Fueling Station Footprint: With modest preparation, existing diesel fueling 

facilities may be used. 

Special Handling Requirements: Handling requirements for biodiesel are 

generally the same as for diesel fuel. However, biodiesel may require special 

additives or tank heating in cold climates to prevent gelling. Existing diesel tanks 

must be properly cleaned and retrofitted with solvent-resistant fittings and gaskets 

prior to the introduction of biodiesel. Dispensing of biodiesel is the same as for 

diesel fuel. 

FAA VALE Program Technical Report Page 6-10 Version 7
Table 6-2. Fueling Station Considerations 

Alternative Fuel Fuel 

Availability Fuel Storage

Fueling Station 

Footprint 

(compared to 

gasoline)

Gaseous vs. 

Liquid

Special 

Handling 

Considerations

Electric

Electrical 

Distribution 

System 

N/A Smaller N/A Inductive vs. 

Conductive 

Compressed 

Natural Gas 

(CNG)

Underground 

Pipeline 

Above 

Ground 

Smaller to 

Largest Gaseous High Pressure 

Liquefied 

Natural Gas 

(LNG

Delivery Truck Above 

Ground Larger Liquid Cryogenic 

Hybrid Electric 

(Gasoline) Delivery Truck Below 

Ground Same Liquid N/A 

Hybrid Electric 

(Diesel) Delivery Truck Below 

Ground Same Liquid N/A 

Propane (LPG) Delivery Truck Above 

Ground Smaller Liquid Heavier than Air 

Ethanol 

(E85) Delivery Truck Below 

Ground Same Liquid Avoid Skin Contact 

Methanol 

(M85) Delivery Truck Below 

Ground Same Liquid Avoid Skin Contact 

Hydrogen Underground 

Pipeline 

Above 

Ground Largest Gaseous High Pressure 

Biodiesel 

(B85-B100) Delivery Truck Above or Below 

Ground Same Liquid Cold Weather 

FAA VALE Program Technical Report Page 6-11 Version 7
FAA VALE Program Technical Report Page 6-12 Version 7

THIS PAGE INTENTIONALLY LEFT BLANK 
FAA VALE Program Technical Report Page 7-1 Version 7

CHAPTER 7 

AIP AND PFC PROJECT ELIGIBILITY

While most VALE program requirements are the same regardless of FAA funding, 

several eligibility factors depend on whether a project is funded through the Airport 

Improvement Program (AIP) or by Passenger Facility Charges (PFCs). It is important to 

consider these funding-related factors on all VALE projects, especially with regard to 

vehicle acquisition. 

Project eligibility for the PFC program is broader traditionally in comparison to AIP 

eligibility. AIP grants-in-aid are funded through the Federal Airport and Airway Trust 

Fund, while the revenue-based PFC program is funded by passenger airline ticket fees 

collected at the time of purchase. Because PFC revenues are considered local revenues, 

sponsors generally have more flexibility in the use of PFC revenues than AIP grants. 

This is true in the VALE program also. 

The major differences in VALE project eligibility between the AIP and PFC program are 

discussed in this chapter, including the use of alternative vs. conventional fuels, 

ownership of equipment, and funding timelines for project approval. Also, information 

on airport leases and enforceable agreements is presented and how these agreements are 

used in the management and financing of VALE projects. 

7.1 Funding 

The VALE program expands traditional AIP and PFC eligibility guidelines and enables 

earlier airport planning and implementation of low-emission projects. Because VALE 

projects are considered an eligible activity within AIP and the PFC program, there is no 

separate or dedicated VALE program budget. VALE projects are approved and funded 

on a case-by-case basis according to the project’s relative importance in relation to other 

eligible airport activities. 

7.1.1 AIP Funding 

VALE projects must adhere to all AIP rules and procedures contained in the AIP 

Handbook (FAA Order 5100.38C), and standard grant assurances (e.g., 

competitive bidding, buy American, use of airport revenues).31 The VALE 

Technical Report is considered supplemental guidance to the AIP Handbook for 

purposes of administering the VALE program. 

 

31 See FAA Order 5190.6B, Airport Compliance Manual, for detailed information about AIP standard 

assurances. 
FAA VALE Program Technical Report Page 7-2 Version 7

Sponsors may fund VALE projects through AIP entitlements or through the 

discretionary portion of the AIP budget, including the so-called “noise and air 

quality set-aside”.32 The set-aside offers greater opportunity for VALE funding 

because only noise and air quality projects are eligible for this portion of the AIP 

budget. VALE projects funded through the noise and air quality set-aside do not 

affect airport entitlements. 

Reimbursable costs for VALE AIP grants must conform to all AIP guidelines. 

Eligible AIP costs include those for project formulation and allowable capital 

equipment. 

Ineligible AIP costs include O&M costs (e.g., fuel), planning studies, public 

information, training, and project tracking and record-keeping. In addition, 

sponsors may not use AIP or PFC funds to pay for EPA, State, district, local, or 

Tribal reviews of VALE projects or AERC actions. 

7.1.2 AIP Matching Funds

Eligible sources for local matching funds are defined under current AIP 

guidelines (see FAA Order 5100.38C). These sources include eligible airport 

revenues and State or local grants that do not include other Federal funds. 

Sponsors may also use PFC revenues to 

fulfill local matching AIP requirements. 

Any use of PFCs by the sponsor as a 

local match for AIP projects means that 

the AIP grant assurances and 

compliance are extended to these PFC 

funds as well. It is important to 

emphasize that the base cost of a vehicle cannot be counted as part of the 

sponsor’s local matching requirements. 

Consistent with AIP procedures, sponsors are expected to finance their VALE 

project in advance of AIP reimbursement for the allowable Federal cost share (see 

Table 7-3 below). 

 

32 The VALE program under Vision 100 expanded the existing AIP eligibility for low-emission projects 

(§47102(3)(F)). The so-called “traditional” AIP eligibility applies when a proposed project to reduce 

emissions is not “surplus” (See Chapter 1 Section 1.5 and AERC Report Section 3.2) because of an existing 

commitment to airport emission reductions in support of the CAA (e.g., MOUs or EIS mitigation 

measures). Sponsors are encouraged to contact the FAA to discuss VALE vs. traditional AIP eligibility. 

Vehicle base costs 

 cannot be counted as part 

 of the AIP local match. 
FAA VALE Program Technical Report Page 7-3 Version 7

7.1.3 PFC Funding 

FAA management of the PFC program generally follows AIP rules and 

procedures unless differentiated by legislation or by agency PFC regulations and 

orders. Similarly, PFC eligibility requirements for the VALE program adhere to 

AIP guidance unless otherwise specified in this report. 

 

While the FAA manages and oversees the PFC program, sponsors are granted 

local authority to collect and use PFC revenues on approved projects.33 Because 

PFCs are considered local airport revenues, they can be used to finance 100 

percent of eligible project costs and do not require a local match. 

Similar to the AIP, sponsors participating in the VALE program using PFC funds 

must adhere to the established general eligibility requirements and procedures of 

the PFC program. Such participation may require sponsors to finance VALE 

projects initially from existing airport revenues prior to approved cost 

reimbursement of PFC funds. 

7.2 Timelines 

The AIP and PFC program funding timelines, which differ substantially with regard to 

the fiscal year, review periods, and other requirements, are described below. 

7.2.1 AIP Funding Timeline 

VALE applications for AIP funding should follow the FAA Airport Capital 

Improvement Program (ACIP) timetable for AIP planning and programming (see 

Table 7-1). Based on this timetable, the best time for a sponsor to submit a 

VALE application to the FAA and State air quality agency is in the spring prior to 

the fiscal year in which AIP funding is sought. By meeting this schedule, the 

sponsor can expect AIP approval of its proposed VALE project in the DecemberFebruary timeframe of the new fiscal year, which begins October 1. 

It is important to note that State air quality agencies have a 45-day approval 

period to review a VALE application and to provide a required AERC Letter of 

Assurance to the FAA (see AERC Report). Sponsors should incorporate this 

State review period into their project planning and application development so 

that their VALE applications coincide with AIP annual programming. 

 

33 Airport “sponsors” are planning agencies, public agencies, or private airport owners/operators that have 

the legal and financial ability to carry out the requirements of the AIP program. With regard to the PFC 

program, airport sponsors are restricted to “public agencies.” 
Table 7-1. General Timeline of the AIP Funding Approval Process 

Period Action 

Spring 

Previous FY 

Office of Airport Planning and Programming, Financial Assistance 

Division (APP-500) submits ACIP guidance memorandum to FAA 

regions 

Summer 

Previous FY 

FAA regions submit 3-year ACIP to Airports AIP Branch (APP-520) 

Summer 

Previous FY 

APP-520 performs national review of regional ACIPs and coordinates 

corrections with regional offices 

Summer 

Previous FY 

APP-520 performs national analysis to create national priority rating 

thresholds (final candidate list is determined) 

Fall 

Current FY 

Regional offices submit proposals to add/delete projects to/from the 

final candidate list 

Fall 

Current FY 

APP-520 prepares and submits regional budgets to regional offices 

Fall 

Current FY 

Regional offices recommend funding plans and submit plans to APP520 

Winter 

Current FY 

Associate Administrator for Airports (ARP-1) selects/approves projects 

for implementation of regional programming actions 

Spring/Summer 

Current FY 

Unfunded candidate list projects will be considered as priority projects 

to receive any remaining converted “carryover” funding 

7.2.2 PFC Funding Timeline 

Sponsors (i.e., public agencies for PFCs) have no fiscal year filing deadlines for 

PFC applications and may apply at any time based on project plans. However, it 

should be noted that PFC-funded VALE activities that are combined with annual 

AIP funding may need to be organized on a fiscal year basis. 

To assist sponsors in coordinating their VALE application submittals, a general 

outline of the PFC planning and programming timeline is presented below in 

Table 7-2. This process requires the sponsor to meet several statutory deadlines, 

including some prior to submitting a VALE project application to the FAA. 

FAA VALE Program Technical Report Page 7-4 Version 7
Table 7-2. General Timeline of the PFC Funding Approval Process for Use 

Duration 

in Days Action 

Public agency develops PFC application data for VALE project(s) and 

notifies carriers of pending application, projects, financing, and timeframes. 

30-45 Public agency schedules consultation meeting with carriers and publishes a 

notice in the local newspaper. 

30 

Carriers have 30 days following consultation meeting to respond in writing. 

Upon receipt of carrier comments, public agency completes and submits 

application to the FAA. 

120 

HUB AIRPORTS*

Upon receipt of completed PFC 

application, the FAA has 30 days to 

review the application for 

completeness. 

If the application is found to be 

substantially complete, the 120 day 

FAA statutory review timeframe 

continues from the receipt date. 

If the application is not found to be 

substantially complete, the 120-day 

clock is suspended until the public 

agency submits supplemental 

information, at which time the clock 

resets to 120 days. The public agency 

has the option to not supplement the 

application, in which case the 120-

day clock continues from the 

submittal date and the FAA has to 

issue a decision. 

During the 120-day review period, the 

FAA completes a full review and 

issues a decision on the PFC 

application. 

30 

NON-HUB AIRPORTS

Upon receipt of completed 

PFC application, the FAA 

has 30 days to review and 

issue a decision on the 

PFC application. 

180-195

CUMULATIVE DAYS 

FOLLOWING PFC APPLICATION 

DEVELOPMENT.

90-105 

CUMULATIVE DAYS 

FOLLOWING PFC 

APPLICATION 

DEVELOPMENT.

* Hub airports are commercial service airports with at least 0.05 percent of U.S. passengers (FAA Order 5100.38C, 

Chapter 1, Table 3, Definition of Airport Categories. 

FAA VALE Program Technical Report Page 7-5 Version 7
7.3 Fuels 

Eligible new vehicles and fuel systems funded under the AIP may only be powered by 

alternative fuels (including hybrid systems) as defined by the DOE (see Chapter 3). In 

comparison, eligible vehicles and equipment funded under the PFC program may use 

clean conventional fuels (e.g., ULSD fuel or super efficient gasoline engines) in addition 

to alternative fuels, provided that all new vehicle applications meet VALE program lowemission standards. 

Retrofitting existing vehicles with verified alternative fuel systems to achieve lower 

emissions is currently eligible under both AIP and PFC programs (see Chapter 4). 

7.4 Ownership 

Another major variable in AIP and PFC program eligibility is airport ownership of lowemission vehicles and equipment. Under the AIP, all vehicles and equipment must be 

airport-owned. The PFC program is similar but also allows sponsors to assist in the 

purchase of tenant-owned airport vehicles and supporting equipment. Regardless of who 

owns VALE-funded vehicles and equipment or the FAA funding source (AIP and/or 

PFCs), sponsors are responsible for meeting all VALE program requirements and special 

conditions (see Chapter 8 and Appendix C). 

7.4.1 AIP Ownership Requirements 

New vehicles and equipment purchased through the AIP must be airport-owned. AIP 

funding cannot be used to help purchase new tenant-owned vehicles or equipment (e.g., 

airline GSE). It is permissible, however, for 

sponsors to lease VALE vehicles and 

equipment purchased under AIP to airport 

tenants (see “Lease Agreements for Program 

Vehicles and Equipment” below). Under 

AIP funding, sponsors must hold title to all 

VALE vehicles and equipment until they 

have outlived their useful lives. Sponsors may not sell or transfer title to program 

vehicles and equipment without prior notification to and approval by the FAA. 

All new vehicles and equipment 

 purchased with AIP funds must 

be owned by the sponsor. 

FAA VALE Program Technical Report Page 7-6 Version 7
Table 7-3. Comparison of AIP and PFC Program Eligibility 

VALE Program 

Elements AIP PFC 

Eligible Airport-dedicated on-road and non-road vehicles 

Vehicles New vehicles and retrofits 

 Airport-owned or leased  Airport-owned or leased, or tenantowned with enforceable agreement 

Program 

Criteria 

Must remain at airport for useful life 

New vehicles must be certified to meet program low-emission vehicle standards 

Must be monitored and tracked 

Must be labeled with VALE program logo 

Must replace equipment with low-emission equivalent 

New Vehicle 

Funding 

 75% incremental cost for large and 

medium hub airports 

 95% incremental cost for smaller 

commercial service airports 

 100% incremental cost 

 May be used as AIP matching funds 

Retrofit Funding Full cost of retrofit technology for existing airport vehicles 

Vehicles

Funding Limitations No base vehicles costs 

No O&M costs including fuel 

Eligible 

Infrastructure 

Eligible infrastructure project must contribute directly to airport emission reductions. 

Examples: 

- AFV refueling and recharging stations 

- Aircraft gate electrification 

- Power plant, generator, and HVAC conversions to cleaner alternative fuels 

 Airport-owned or leased  Airport-owned or leased, or tenantowned recharging and refueling 

equip. with enforceable agreement 

Program 

Criteria Must be labeled with VALE identification logo 

Cannot extend beyond airport boundary 

Limited public access to refueling and recharging stations if airport safety and security 

Infrastructure 

are guaranteed and if airport sponsors and vehicles have priority use 

Funding 

 75% cost for large and medium 

hub airports 

 95% cost for smaller commercial 

service airports 

 100% cost 

 May be used as AIP matching funds 

Eligible 

Alternative 

Fuels 

Electricity 

CNG, LNG,LPG 

Blended fuels 85 percent or greater such as E85, M85, and biodiesel (B85-100) 

Hydrogen 

Coal-derived liquid fuels 

P-series fuels 

Hybrid technology 

Fuels 

Program 

Criteria 

 Must operate exclusively on 

alternative fuels that are 

substantially non-petroleum based 

and domestically produced 

 May operate on alternative fuels, 

blended fuels, or clean conventional 

fuels provided that applicable program 

low-emission standards are met 

FAA VALE Program Technical Report Page 7-7 Version 7
FAA VALE Program Technical Report Page 7-8 Version 7

7.4.2 PFC Ownership Requirements 

PFC eligibility extends beyond airport ownership and leasing to non-airport 

owned vehicles including airline-owned GSE. 34 This PFC allowance is important 

to the low-emission goals of the VALE program because airlines own and operate 

approximately 75 percent of the GSE at domestic airports. Owners of the other 

25 percent of GSE are primarily cargo handlers, fixed based operators (FBOs), 

and other third party operators. 

Tenant-owned infrastructure or equipment that is PFC-eligible includes standalone recharging and refueling stations that support low-emission program 

vehicles. Low-emission infrastructure or equipment that must be airport-owned if 

purchased with PFCs includes gate power equipment, underground fuel hydrant 

systems, building HVAC systems, and stand-alone power generating facilities. 

7.4.3 Combined Project Funding and Ownership 

Projects that combine AIP and PFC funding or that mix airport-owned and tenantowned vehicles and equipment are permitted under the VALE program, provided 

that: 

1) The sponsor verifies that all aspects of the project meet all AIP grant 

assurances and PFC program requirements, notwithstanding the 

differences in project eligibility described in this report. 

2) The sponsor takes responsibility for successfully managing all VALE 

program requirements and special conditions whether the vehicles and 

equipment are airport-owned or tenant-owned. 

3) The sponsor executes enforceable agreements with tenants that cover 

airport-leased or tenant-owned vehicles and equipment (see below).

 

Example 1: The sponsor wants to combine AIP and PFC funding to purchase 

new CNG buses and to upgrade an existing CNG refueling station. 

In this example, the CNG vehicles and refueling station are airport-owned and 

leased by the sponsor to two companies, one operating the buses and the other 

operating the refueling station. AIP funding is used for the vehicles while PFC 

funding is used for the station upgrade. As long as the two lease agreements are 

FAA approved, there is no problem combining AIP and PFC funding for this 

project. 

 

34 PFC “approvals” include “acknowledgments” under Vision 100. 
FAA VALE Program Technical Report Page 7-9 Version 7

Example 2: The sponsor wants to use AIP funding to buy new rechargers in 

combination with an airline that wants to operate electric GSE. 

In this example, AIP funding may be used to pay for new recharging stations even 

if the project emission savings and cost-effectiveness depend on new tenantowned vehicles that may or may not involve the use of PFC funds to offset 

incremental vehicle costs. Tenant stipulations are as follows: 

1) The airline must purchase new electric GSE and provide the sponsor 

and the FAA with manufacturer specifications for the proposed 

vehicles.35

2) The airline must purchase the number of compatible electric GSE that 

match the capacity of the recharger(s). 

3) The airline must sign an enforceable agreement with the sponsor that 

addresses all VALE program requirements and special conditions (see 

below). The agreement must include an airline commitment to 

provide the sponsor with vehicle usage information on a regular 

schedule to meet the sponsor’s project tracking responsibilities. 

7.5 Enforceable Agreements 

Enforceable agreements between the sponsor and the tenant are discussed in this section. 

Airport leases and other agreements discussed below should be reviewed by the FAA 

Region prior to the sponsor’s signing. (As discussed in Chapter 2, a signed agreement or 

letter of assurance from the participating tenant stating that the tenant will abide by all 

VALE special conditions must be included in Appendix D of the VALE application prior 

to FAA funding approval). 

 

35 Used tenant-owned electric GSE, even if deemed “surplus” from an emissions standpoint, cannot be 

applied to the VALE project in this example because of mixed funding sources and the possibility that the 

FAA long-term investment in new rechargers could be affected by the shorter useful life of used vehicles. 
FAA VALE Program Technical Report Page 7-10 Version 7

7.5.1 Lease Agreements for Program Vehicles and Equipment 

Sponsors are allowed to lease VALE-funded vehicles and equipment for use by 

airport tenants. For example, sponsors may lease electric GSE and recharging 

equipment to an air carrier or lease the operation of a CNG refueling station to a 

fuel provider.36

VALE program goals must be reflected in project lease arrangements, especially 

the requirement to keep VALE vehicles and equipment at the airport to ensure 

CAA and AERC permanent emission reductions. 

 

The sponsor should structure the lease as simply as possible for efficient project 

oversight and compliance. The criteria for a qualified lease arrangement include: 

 A term that reflects the useful life of project vehicles or equipment (e.g., 

13 years or 156 months for an electric bag tug). This period ensures that 

project emission reductions are permanent over the life of the project and 

that AERCs will be fully available to the sponsor. 

 Rental charges for non-AIP/PFC expenses (e.g., base vehicle costs) should 

be amortized over the useful life of the project to keep rental costs at or 

below market rates.37 Such amortization provides a financial incentive to 

tenants/lessees in addition to other possible project funding for 

infrastructure improvements. 

 Restrictions on modifying the lease except under the following 

circumstances: 

1. The tenant ceases operations at the airport, or 

2. The tenant demonstrates a significant reduction in VALE-related 

operations with clear data and documentation 

The FAA must approve all requests for lease modifications. Sponsors are 

expected to forward the request and documentation to the FAA ADO and 

FAA Region for their review and approval prior to the modification. 

Example. The sponsor leases electric GSE to an air carrier to support 

scheduled operations and the air carrier subsequently seeks to reduce the 

 

36 The sponsor should consult with the FAA ADO or Region Office if a VALE project proposal includes a 

lease agreement or tenant-owned vehicles or equipment. Regarding active lease agreements in a VALE 

project, proposed modifications to the required structure of the lease must be reviewed and approved by 

FAA ADO and Region. 

37 The sponsor cannot amortize by lease any portion of the vehicle, equipment, or facility cost that is paid 

for with AIP or PFC funding. 
number of GSE in the lease. In this case, the request for lease 

modification requires: 

- A demonstration by the air carrier that GSE operations have been or 

will be reduced during the remaining years of the lease. Evidence to 

support the request must include a revised schedule in the Official 

Airline Guide (OAG) or a signed agreement with the sponsor for 

reduced aircraft gate use. 

- Certification by the air carrier that all similar types of GSE have 

been or will be removed from the airport first, beginning with 

conventionally fueled GSE and then non-VALE alternative fuel 

GSE. 

With regard to a lease for managing and operating an airport refueling or 

recharging station, the sponsor must include the following provisions in the lease: 

 The facility complies with all airport safety and security standards, 

including the safe handling and transportation of alternative fuels. 

 The facility guarantees that the sponsor and airport-owned vehicles will 

have priority regarding facility use and fueling in all cases, including 

periods of high demand or in the event of fuel shortages. Public access to 

the facility cannot impede the use of the facility for airport needs and the 

efficient delivery of airport services. 

 The facility may offer limited public access, as approved by the sponsor. 

 The facility may co-locate non-VALE equipment, as approved by the 

sponsor. 

For all leases, the sponsor should clearly specify the range of options in the event 

of a violation or default on the lease (e.g., total rent due, penalties, immediate 

possession, legal remedies). Accordingly, the FAA reserves the right to recover 

funding provided through the AIP and the PFC program for VALE acquisitions. 

In the event of a lease modification or default, the sponsor is also responsible for 

adjusting its actual or estimated project emission reductions and communicating 

this information to the FAA, EPA, and State air quality agency as soon as 

possible. 

FAA VALE Program Technical Report Page 7-11 Version 7
FAA VALE Program Technical Report Page 7-12 Version 7

7.5.2 Agreements for Tenant-Owned Vehicles and Equipment 

The sponsor must establish an enforceable agreement with the tenant or 

purchasing party when non-airport owned vehicles and equipment are part of a 

proposed VALE project. This agreement is required to meet the special 

conditions of the VALE program (see Chapter 8 and Appendix C), as well as the 

PFC determination paragraph or acknowledgement letter in PFC approvals. 

This agreement should include actions that the sponsor and the airport tenant will 

take in the event that the tenant is unable to fulfill the special conditions of the 

VALE program for any reason. Tenants have two basic options: 

1. The tenant may sell its VALE program-funded or committed vehicles and 

equipment to the sponsor or to another tenant at the same airport with 

approval of the sponsor. New tenant owners must likewise accept and abide 

by the special conditions of the program. 

2. The tenant may reimburse the FAA and the sponsor for AIP or PFC funds 

used to purchase project vehicles and equipment. Whether tenant-owned 

project vehicles and equipment are PFC-supported or not, the tenant 

obligation extends beyond its own vehicles and equipment to other system 

equipment purchased as part of the VALE project. For example, if a tenant 

removes electric GSE that are supported by an AIP-funded recharging 

station, the tenant is responsible for reimbursing the FAA for the remaining 

useful life of the recharger. The sponsor and the FAA shall determine the 

appropriate level of reimbursement for related AIP and PFC project 

investments.38

The tenant must notify the sponsor and the FAA prior to taking action on either 

option. Regardless of the option selected, if the tenant moves, sells, or disposes of 

VALE program-funded vehicles, the sponsor is responsible for adjusting its actual 

or estimated program emission reductions and communicating this information to 

the FAA, EPA, and State air quality agency as soon as possible.

 

38 Depreciation and other cost factors may be considered by the FAA. The sponsor must deposit any PFC 

reimbursement in the sponsor’s PFC account for use on other PFC-eligible projects. 
FAA VALE Program Technical Report Page 8-1 Version 7

CHAPTER 8 

AIRPORT PROGRAM RESPONSIBILITIES

Sponsors that participate in the VALE program must adhere to standard AIP and PFC 

conditions and assurances.39 In addition, the VALE program includes several “special 

conditions” for sponsors (see Appendix C), including the requirement that program 

vehicles and equipment must be airport-dedicated and remain at the airport throughout 

their useful lives. The sponsor is also responsible for labeling, tracking, and maintaining 

all of the low-emission vehicles and equipment purchased under the VALE program. 

FAA Regional Airports Division Offices and Airports District Offices oversee VALE 

projects by monitoring grant assurances and conducting periodic on-site inspections. The 

Airports Financial Assistance Division (APP-500) at FAA Headquarters monitors project 

activity and ensures that grant funds are expended in a timely manner for the appropriate 

purpose. 

The FAA may impose sanctions if a sponsor fails to comply with AIP grant assurances or 

program requirements as described in FAA Order 5100.38C, AIP Handbook, 

Chapter 11, Section 6 on “Suspension and Termination of the Grant.” If vehicles are 

removed from the airport or are not used as prescribed, a “Termination for Cause” will 

become effective and the sponsor will be required to reimburse the FAA for related grant 

funds and make appropriate revisions to its project emission reduction estimates. In 

addition, if circumstances arise after the grant funds have been authorized and/or 

distributed that prevent the sponsor from continuing or completing the commitments of 

the VALE program, the FAA may issue a “Termination for Convenience” by which the 

sponsor is required to return unspent grant funds to the FAA, thereby voiding project 

commitments and related AERCs. 

The four “special conditions” for sponsors participating in the VALE program are 

discussed below. Using language provided in Appendix C, the FAA will insert these 

conditions into AIP grants and PFC approvals for the VALE program. With acceptance 

of funding, sponsors agree to fulfill these special conditions for the VALE program, as 

well as the standard assurances, to ensure ongoing program compliance. In addition, the 

sponsor should acknowledge the special conditions and requirements of the VALE 

program in all sponsor-tenant agreements and leases involving program vehicles and 

equipment. 

 

39 See the AIP Handbook (FAA Order 5100.38) and Airport Compliance Manual (FAA Order 5190.6B) for 

more information about standard assurances. 
8.1 Vehicles to Remain at Airport for Useful Life 

In accordance with the CAA, the low-emission benefits of the VALE program for the 

airport and surrounding area must be permanent. Therefore, the sponsor must certify to 

the FAA that vehicles and other assets acquired or contracted through the VALE program 

will remain in operation at the airport for their useful lives. Program vehicles or 

equipment may not be transferred to, taken to, or used at another airport without the 

consent of the FAA in consultation with the EPA and State air quality agency. 

The sponsor must also certify as practicable that any vehicles or equipment replaced 

under the program, whether airport or privately owned, will not be transferred to another 

airport or location within the same or any other nonattainment or maintenance area. This 

requirement protects regional air quality, avoids adverse effects on other sensitive 

locations, and prevents the possibility of duplication of VALE program funding for the 

same vehicles or equipment at other airports. 

In the event that the sponsor uses VALE program funding to assist a tenant or third-party, 

the sponsor shall enter into an enforceable agreement with this party to ensure that all 

project vehicles and equipment remain at the airport for their useful lives. The agreement 

should specify the steps that would be taken by the tenant to re-sell vehicles or equipment 

or to reimburse the FAA if VALE-funded, tenant-owned vehicles and equipment are 

removed or abandoned, including some or all of associated project costs for refueling and 

recharging stations. 

8.2 Equipment Labeling 

All vehicles and equipment that are acquired or upgraded as part of the VALE program, 

including vehicles and equipment that are non-airport owned such as airline GSE must be 

clearly labeled with the VALE program logo (see Figure 8-1). The main purpose of 

labeling is to enable easier identification and tracking of VALE vehicles and equipment 

and to ensure that vehicle use is airport-dedicated. The VALE label also provides a 

visible reminder of the agency’s commitment to low-emission airport technology. 

Manufacturing of the labels is the responsibility of the airport sponsor or participating 

airport parties and is an eligible project cost. The size of the rectangular VALE program 

label must be a minimum of 11 inches (horizontal) by 6 inches (vertical) so as to be 

clearly legible at 50 feet. An acceptable high-resolution graphic is provided on the FAA 

VALE website: http://www.faa.gov/airports/environmental/vale. 

FAA VALE Program Technical Report Page 8-2 Version 7
Figure 8-1. Label for VALE Program-Funded Vehicles and Equipment 

8.3 Tracking and Monitoring Requirements 

The sponsor is responsible for the tracking and monitoring of all vehicles and equipment 

at the airport that are acquired or upgraded under the VALE program, including vehicles 

that are non-airport owned such as airline GSE. Tracking and monitoring of vehicles and 

equipment are necessary for identification purposes and for improving the accuracy of 

estimated emission reductions. 

The sponsor must keep detailed annual records of VALE vehicles and equipment and 

must maintain these records so that they are readily available for FAA inspection, public 

review, or auditing. In addition, the sponsor 

has an affirmative responsibility to notify 

the FAA in writing as early as possible of 

major changes to VALE vehicles and 

equipment or their use. 

To standardize the monitoring process, the 

FAA recommends using the project tracking 

worksheets provided in Appendix E and 

available electronically from the VALE website. Airport identification and use records 

for project vehicles and equipment must include ownership, confirmation of program 

labeling, and individual identifiers, such as make, model, and vehicle identification 

numbers (VINs/serial numbers). Annual use data should be collected and maintained by 

individual vehicle or piece of equipment, as well as at an aggregate level by 

vehicle/equipment type and ownership. Vehicle use is typically estimated or measured 

by annual hours of operation, fuel use, and/or miles traveled. Additional information 

must include financial records, including the dates of vehicle and equipment orders, 

deployment, and major maintenance or repair. 

Airport sponsors are required to 

monitor the usage of all vehicles 

acquired through the VALE 

program and to keep up-to-date 

usage records. 

FAA VALE Program Technical Report Page 8-3 Version 7
FAA VALE Program Technical Report Page 8-4 Version 7

The sponsor must also maintain annual emissions data by criteria pollutant (in tons/year). 

This information is important for purposes of ongoing cost effectiveness calculations and 

AERC verification with State air quality agencies and the EPA. The sponsor must 

provide current/updated emission reduction estimates to its State air quality agency, the 

EPA, and the FAA at three different times: 

1) When applying for the program. 

2) When applying to the State air quality agency for issuance of AERCs during or 

following project implementation. 

3) When using the AERCs to meet regulatory requirements. 

Project information should be readily available if requested because the sponsor must 

maintain annual usage records, including the remaining estimated useful life of vehicles 

and equipment. Updated emission reduction estimates should be based on as much actual 

and historical information as possible. If local resources permit, sponsors are encouraged 

to partner with vehicle and engine manufacturers, universities, and industry to monitor 

vehicle emissions, which would supplement emission estimates obtained from 

certification data, manufacturer specifications, or computer models. 

8.4 Replacement of Low-Emission Vehicles and Equipment for the Useful Life of 

the Project and AERCs 

In the event that VALE vehicles or equipment are disabled before the end of their useful 

lives (e.g., accidents or breakdowns), the sponsor agrees to replace such vehicles or 

equipment with equivalent units that produce equal or lower levels of emissions. The 

financial responsibility for vehicle or equipment replacement under these circumstances 

is with the sponsor. While replacement vehicles may be eligible for AIP or PFC funding, 

the FAA offers no guarantee that further funding will be available or approved in the 

future to meet the sponsor’s commitment regarding replacement of these vehicles. 

The agreement discussed above assures that actual emission reductions from the VALE 

program are consistent with the underlying emission reduction estimates used for 

granting AERCs.40 This consistency fulfills CAA requirements by ensuring that VALE 

benefits for the airport and surrounding area are permanent for the duration of the 

AERCs. 

The sponsor may commit to replacing vehicles and equipment with useful lives of less 

than 20 years with equivalent or cleaner technology. This “option” allows the sponsor to 

obtain AERCs for an extended period of up to 20 years. The sponsor must elect the 

option in the VALE project application (see Appendix D, Project Application 

 

40 See EPA Guidance of Airport Emission Reduction Credits for Early Measures through Voluntary Airport 

Low Emission Programs, Chapter 6, Section 6.2, “Life of the AERCs”, 2004. 
FAA VALE Program Technical Report Page 8-5 Version 7

Worksheet, page 1).41 Moreover, this decision must be reflected in the emission 

reduction calculations at the time the proposal is submitted to the State air quality agency. 

 

41 Stationary equipment with a longer useful life than 20 years may be eligible for AERCs up to 40 years. 

See EPA Guidance of Airport Emission Reduction Credits for Early Measures through Voluntary Airport 

Low Emission Programs, Chapter 6, Section 6.2, “Life of the AERCs”, 2004. 
FAA VALE Program Technical Report Page 8-6 Version 7

THIS PAGE INTENTIONALLY LEFT BLANK 
FAA VALE Program Technical Report Page 9-1 Version 7

Chapter 9 

ASSESSMENT METHODOLOGY

This chapter discusses the required methodology for quantifying project emission 

reductions, using AERCs, and determining project cost effectiveness. The discussion 

includes data development for EDMS modeling and the presentation of EDMS project 

emission results to the FAA, EPA, and State air quality agencies. 

9.1 Baseline and Project Conditions 

The sponsor’s analysis for VALE projects is limited in scope to specific information 

about the proposed low-emission project. The sponsor is not required to conduct an 

analysis or inventory of non-project or total airport emissions. 

The emissions assessment for the 

project application must be conducted 

using the latest version of the FAA 

Emissions and Dispersion Modeling 

System (EDMS) and VALE Project 

Application Worksheets (see 

Appendix D). The most recent 

versions of these documents are 

available on the VALE website.42

Consistent with domestic convention and general conformity thresholds, emission 

reductions must be calculated in short tons (2,000 pounds) and not pounds or metric or 

long tons. In addition, the calculations must include estimates for all criteria pollutants 

and their precursors, with the general exception of lead (Pb), ammonia (NH3), and 

nitrogen dioxide (NO2). 

The emissions reduction assessment process involves a step-by-step progression that 

accounts for the baseline conditions and the proposed VALE project(s) intended to 

reduce emissions, with each step requiring documentation and verification.

Step 1: Collect and document data. The analysis begins with the collection of 

data for proposed low-emission vehicles and equipment. This information 

is used to compare baseline and VALE low-emission operating conditions, 

which are defined as follows: 

 

42 http://www.faa.gov/airports/environmental/vale 

The sponsor only needs to evaluate VALE 

project emissions. Inventory of airport 

emission sources unrelated to the VALE 

program is not required. 
FAA VALE Program Technical Report Page 9-2 Version 7

 The baseline condition reflects the operation of existing or new 

conventional-fuel vehicles and equipment that would occur if no 

VALE project were implemented.43

 The project condition reflects operating changes that result from 

implementation of the VALE low-emission project. 

Step 2: Calculate project emission reductions. The FAA requires sponsors to use 

EDMS to calculate emissions reductions for VALE projects. 

Step 3: Document emissions analysis. Results of emission reduction calculations 

are an integral part of the sponsor’s proposal to the FAA for funding and 

to the State air quality agency for AERCs. 

The emissions calculations are intended to support the sponsor’s request for AERCs from 

the State air quality agency. Before planning a VALE project, sponsors should read the 

EPA AERC Report, Guidance on Airport Emission Reduction Credits for Early 

Measures through Voluntary Airport Low-Emission Programs. The AERC Report 

provides general guidance to State air quality agencies on AERC methodology and how 

AERCs should be granted to sponsors under the VALE program. 

9.1.1 Current Year Basis and Examples 

The sponsor calculates estimated project emission reductions (and AERCs) on the 

basis of the latest EPA and VALE program low-emission standards in effect 

during the current year (i.e., fiscal year of AIP and/or PFC funding).44 These 

emission factors in AERC calculations are valid for the entire life of the project 

provided that AIP and/or PFC funding is approved in the same fiscal year. 

Moreover, the sponsor is not required to adjust these emission reduction factors 

during the project life as EPA new vehicle standards become cleaner over time.45 

Three examples of the “current year” basis are provided below for clarification: 

 

43 EPA 452/R-01-001, Section 16.3.4.a(1). 

44 The FAA and EPA agreed to use existing standards in the “current year” (i.e., the fiscal year of funding) 

as the basis for all annual emissions reduction and AERC calculations over the life of the project (see 

AERC Report, Chapter 4, Section 4.1). This approach is intended to give sponsors added incentive for 

early action and to simplify emission reduction methodology. 

45 Emission reduction calculations for the useful life of the project (current and future years) are based on 

the existing EPA and VALE emission standards for the current year. With each new year, the current year

reflects the progression of cleaner EPA and VALE vehicle emission standards. However, while the 

sponsor’s initial calculations during project application may need to be updated to reflect actual operations 

(e.g., approved funding, deployment, monitored use), the sponsor’s emission calculations and AERCs are 

not subject to the established annual changes in future EPA or VALE emission standards for new vehicles. 

In effect, the VALE projects are “grandfathered” for the life of the project based on the standards in place 

when the project starts. Nevertheless, VALE projects may be subject to new regulations that EPA may 

establish in the future that affect existing emission sources and surplus status. 
FAA VALE Program Technical Report Page 9-3 Version 7

Example 1: A sponsor proposes a project in FY ‘11 that is funded in FY 

‘11. In this case, the sponsor’s annual emission calculations over the 

estimated life of the project are based on EPA and VALE standards for FY 

’11 (current year). This is intended to simplify the calculations and to 

provide an incentive for early action as emission standards improve over 

time. 

Example 2: A sponsor prepares a proposal in FY ‘11 for funding in FY 

’12, or for some reason does not receive project funding until FY ‘12. In 

this case, the sponsor must develop or revise the emission calculations 

based on EPA and VALE standards that are in place for FY ‘12. Since the 

FAA will review VALE standards annually, the sponsor is encouraged to 

contact the FAA to discuss possible modifications to the standards for the 

coming year. 

Example 3: A sponsor submits a proposal, obtains funding, and 

implements a VALE project in FY ‘11. The sponsor waits 3 years before 

submitting an updated report to the State air quality agency for AERCs. 

During this time, EPA new vehicle standards and VALE low-emission 

program standards change. Regardless of this fact, the vehicle standards 

for FY ’11 that were used in the sponsor’s original application are valid 

and continue to be valid for the life of the project. 

9.1.2 Timeframe 

The timeframe for emissions reduction calculations generally corresponds to the 

useful life of project vehicles and equipment. Useful life estimates range from 10 

years for various airport vehicles to 40 years for underground fuel hydrant 

systems (see Table 4-1 and Table 6-1). Emission reductions over the estimated 

useful life of VALE-funded vehicles and equipment are used to determine project 

cost effectiveness and AERCs. 

Project life and the timeframe for emissions reduction calculations may be 

extended if a sponsor selects the “AERC Option” and agrees to replace VALEfunded vehicles and equipment with equivalent or cleaner low-emission 

technology (see page 1 of the sample Project Application Worksheet and 

Instructions in Appendix D).46 By invoking the AERC Option, sponsors can 

obtain up to 20 years of AERCs for vehicles and equipment that have an 

estimated useful life of less than 20 years. However, it is important to note that 

the AERC Option has two major restrictions: 1) it does not pertain to equipment 

with a useful life of 20 years or more; and 2) it cannot be used to determine 

project cost effectiveness, which is based solely on the initial useful life of 

VALE-funded vehicles and equipment. 

 

46 AERC Report (EPA Guidance on Airport Emission Reduction Credits for Early Measures through 

Voluntary Airport Low Emission Programs), Section 6.2, “Life of the AERCs”. 
9.1.3 Baseline Comparisons and Factors 

Emission calculations and AERCs are based on the net emission reductions 

between the baseline and project conditions. Vehicle projects, for example, 

usually involve the net difference in emissions between baseline vehicles powered 

by diesel fuel or gasoline and project vehicles powered by cleaner alternative 

fuels. The net (surplus) reductions translate into an equal amount of AERCs for 

general conformity purposes. Emission reductions for the VALE program are 

rate-based and should be presented in tons of pollutants per calendar year (tpy) to 

one decimal place or to a maximum of three decimal places if the project is 

extremely small. Examples of how to calculate emission reductions based on 

either “old vs. new” or “new vs. new” baseline comparisons are provided below. 

“Old vs. New” Comparisons

“Old vs. new” applies when existing vehicles or equipment are being replaced or 

retrofitted with new low-emission vehicles or engines prior to the end of their 

useful lives. The sponsor should rely on EDMS (which includes MOBILE onroad and NONROAD emission factors) to assess existing (old) conventional fuel 

vehicles that are being retired or replaced. The sponsor must identify each vehicle 

being retired or replaced. EDMS emission factors represent the basic historical 

averages for the national fleet, and use the study year to correlate the emission 

factors with the model year of the existing vehicle. 

The important aspect of “old vs. new” comparisons is that the old equipment 

could have some remaining useful life at the time of replacement or retrofit. 

Therefore, the sponsor must calculate the emission reduction using the old 

equipment as the baseline condition. 

Example of “old vs. new”: A sponsor wishes to purchase a new 

electric baggage tug to replace an existing diesel baggage tug. At 

the time of replacement, the old diesel tug has 3 more years of 

useful life. The new electric baggage tug has an estimated useful 

life of 13 years. The emission comparison for the first 3 years is 

the difference between the old diesel tug and the new electric tug. 

Starting in year 4, the comparison becomes “new vs. new” because 

the old tug would be replaced at that time, presumably with 

another diesel unit. For “new vs. new,” the emission comparison is 

the difference between the new electric tug and a new diesel tug 

that meets the EPA vehicle standards in effect for the current year

(i.e., the fiscal year of AIP and/or PFC funding). This comparison 

is extended for the remaining useful life of the new electric tug. 

FAA VALE Program Technical Report Page 9-4 Version 7
“New vs. New” Comparisons and Baseline Tables

“New vs. new” comparisons are used when a sponsor is adding new vehicles or 

equipment to airport operations. It applies: (1) when old vehicles or equipment 

are not being replaced; or (2) for the years of new vehicle or equipment life 

beyond the remaining useful life of the replaced units. 

While EDMS offers emission factors for existing conventional fuel vehicles 

(NONROAD and MOBILE6 interfaces), the model does not provide sufficient 

new vehicle data. Therefore, sponsors have the following options for new vehicle 

emission factors (in order of preference): 

1) EPA-certified data (or verified data for retrofit technology) 

2) Manufacturer’s emissions data with appropriate documentation 

3) New vehicle VALE standards 

4) Default EDMS emission factors with documented substitutions 

An important aspect of “new vs. new” comparisons is that the sponsor has greater 

incentive to purchase low-emission vehicles now rather than later. This incentive 

for early action is based on the fact that the longer the sponsor waits to purchase a 

new vehicle, the cleaner EPA vehicle emission standards and the new baseline for 

the current year become. 

Example of “new vs. new”: A sponsor seeks to purchase a new 

40-foot shuttle bus powered by a CNG engine. Baseline emissions 

are for a new diesel bus engine, with emission factors based on 

EPA emission standards in place for the current year (the fiscal 

year of AIP and/or PFC funding). The baseline emissions are 

compared to emissions from the new CNG bus, which must have 

an engine certified to meet VALE standards. The difference 

between each set of emissions would equal the project emission 

reductions (and AERCs). 

New vehicle baseline emission factors are provided below in Tables 9-1 through 

9-5 for “new vs. new” comparisons. These factors are helpful and save time 

because EDMS does not contain EPA emission standards or calculated midpoints. 

Baseline emission factors for new Category 3, 4, and 5 vehicles (Tables 9.3 to 9-

5) are the applicable EPA minimum emission standards. Because EPA standards 

for new light and medium-duty vehicles (Tables 9-1 and 9-2) offer a range of 

certification levels in support of national fleet averaging, the FAA has calculated 

the “midpoint” of emission standards to represent the average or typical baseline 

condition. 

Emission factors shown in the tables for the current fiscal year (shaded) should be 

entered into EDMS as the baseline level for new vehicles and used for analysis (in 

FAA VALE Program Technical Report Page 9-5 Version 7
tpy) of vehicle projects to be funded. The EDMS input screens for entering the 

data are as follows: 

 For GAV, where emissions are expressed in grams per mile (g/mile), 

emission factors are entered under “Emissions” and “Roadways...” 

 For GAV Category 3, users should reference Table 30 in the EPA 

“Update of Heavy-Duty Engine Emission Conversion Factors for 

MOBILE6” (EPA420-R-02-005, 2002) to find (bhp-hr/mi) conversion 

factors for diesel and gasoline transit buses. 

 For GSE, where emissions are expressed in grams per brake 

horsepower hour (g/bhp-hr), the emission factors are entered under 

“User Created” GSE. 

Future year (non-shaded) information is provided below only for reference if 

sponsors choose to plan ahead and explore airport emission reduction options for 

the future. 

Table 9-1. “New vs. New” Baseline Emission Factors for Vehicle Category 1 

Fiscal Year of 

AIP/PFC Funding 

Request 

NOx 

(g/mile) 

VOC 

(g/mile) 

CO 

(g/mile) 

PM2.5 

(g/mile) 

2011 0.11 0.083 3.15 0.015 

2012 0.11 0.083 3.15 0.015 

2013 0.11 0.083 3.15 0.015 

2014 0.11 0.083 3.15 0.015 

Note: Baseline emission factors for Vehicle Category 1 are the midpoint between the current VALE lowemission standard (Tier2-Bin2) and the dirtiest available standard in this category (Tier2-Bin8/in-use). 

Emission factors for this category could be higher (i.e., greater project emission reductions) if proposed vehicles 

are certified EPA Tier2-Bin1 level or California PZEV. 

VOC emission factors were generated by multiplying NMOG emission factors by 0.999 based on guidance 

provided by EPA A420-P-04-001 “Conversion Factors for Hydrocarbon Emission Components.” 

 

Table 9-2. “New vs. New” Baseline Emission Factors for Vehicle Category 2 

Fiscal Year of 

AIP/PFC Funding 

Request 

NOx 

(g/mile) 

VOC 

(g/mile) 

CO 

(g/mile) 

PM2.5 

(g/mile) 

2011 0.135 0.123 4.2 0.015 

2012 0.135 0.123 4.2 0.015 

2013 0.135 0.123 4.2 0.015 

2014 0.135 0.123 4.2 0.015 

Note: Baseline emission factors for Vehicle Category 2 are the midpoint between the current VALE lowemission standard (Tier2-Bin5) and the dirtiest available standard in this category (Tier2-Bin8/in-use). 

Emission factors for this category could higher (i.e., greater project emission reductions) if proposed vehicles 

are certified cleaner than Tier2-Bin5. 

VOC emission factors were generated by multiplying NMOG emission factors by 0.999 based on guidance 

provided by EPA A420-P-04-001 “Conversion Factors for Hydrocarbon Emission Components.” 

FAA VALE Program Technical Report Page 9-6 Version 7
Table 9-3. “New vs. New” Baseline Emission Factors for Vehicle Category 3 

Fiscal Year of 

AIP/PFC 

Funding 

Request 

Diesel (CI) & 

Gasoline (SI) 

Engines 

NOx 

(g/bhp-hr)

VOC 

(g/bhp-hr)

CO 

(g/bhp-hr) 

PM2.5 

(g/bhp-hr) 

CI 0.15 11.25 

2011 

SI 0.2 

0.146 10.7 0.01 

CI 0.15 11.25 

2012 

SI 0.2 

0.146 10.7 0.01 

CI 0.15 11.25 

2013 

SI 0.2 0.146 10.7 0.01 

CI 0.15 11.25 2014 SI 0.2 0.146 10.7 0.01 

Notes: Baseline emission factors for Vehicle Category 3 are based on the EPA national emission standards for on-road, 

heavy-duty compression ignition (CI) and spark ignition (SI) engines. 

 

The current on-road HD standards for CO are 15.5 g/bhp-hr for diesel engines and 14.4 g/bhp-hr for gasoline 

engines. Therefore, the baseline emission factor for CO is the midpoint of 11.25 for diesel engines (15.5 + 7.0 

program standard/2) and 10.7 for gasoline engines (14.4 + 7.0/2).

VOC emission factors were generated by multiplying NMHC emission factors by 1.04 for two- and four-stroke 

SI engines and by 1.07 for CI engines based on guidance provided by EPA A420-P-04-001 “Conversion Factors 

for Hydrocarbon Emission Components.”

Table 9-4. “New vs. New” Baseline Emission Factors for Vehicle Category 4 

Fiscal Year of 

AIP/PFC Funding 

Request 

NOx 

(g/bhp-hr) 

VOC 

(g/bhp-hr) 

CO 

(g/bhp-hr) 

PM2.5 

(g/bhp-hr) 

2011 1.61 0.373 3.28 0.01 

2012 1.61 0.373 3.28 0.01 

2013 1.61 0.373 3.28 0.01 

2014 1.61 0.373 3.28 0.01 

Notes: Baseline emission factors for Vehicle Category 4 are based on the EPA Tier 2 emission standards for 

large (>25 hp) non-road SI engines (40 CFR Parts 89, 1048, et al.). 

Based on discussions with EPA, the combined standard of 2.01 g/bhp-hr for HC+NOx can be assumed to be a 

20/80 split, respectively. 

VOC emission factors were generated by multiplying HC emission factors by 0.933 for four-stroke SI engines 

based on guidance provided by EPA A420-P-04-001 “Conversion Factors for Hydrocarbon Emission 

Components.”

FAA VALE Program Technical Report Page 9-7 Version 7
Table 9-5. “New vs. New” Baseline Emission Factors for Vehicle Category 5 

Fiscal Year of 

AIP/PFC 

Funding Request 

Maximum 

Engine 

(hp) 

NOx 

(g/bhp-hr) 

VOC 

(g/bhp-hr) 

CO 

(g/bhp-hr) 

PM2.5 

(g/bhp-hr) 

< 11 5.0 0.63 6.0 0.3 

11 to 25 5.0 0.63 4.9 0.3 

26 to 49 5.0 0.63 4.1 0.22 

50 to 99 3.3 0.21 3.7 0.22 

100 to 174 0.3 0.11 3.7 0.22 

175 to 749 0.3 0.11 2.6 0.01 

2011 

 750 2.6 0.32 2.6 0.075 

< 11 5.0 0.63 6.0 0.3 

11 to 25 5.0 0.63 4.9 0.3 

26 to 49 5.0 0.63 4.1 0.22 

50 to 74 3.3 0.21 3.7 0.22 

75 to 99 3.3 0.21 3.7 0.01 

100 to 174 0.3 0.11 3.7 0.01 

175 to 749 0.3 0.11 2.6 0.01 

2012 

 750 2.6 0.32 2.6 0.075 

< 11 5.0 0.63 6.0 0.3 

11 to 25 5.0 0.63 4.9 0.3 

26 to 49 2.8 0.63 4.1 0.02 

50 to 74 2.8 0.21 3.7 0.02 

75 to 99 3.3 0.15 3.7 0.01 

100 to 174 0.3 0.15 3.7 0.01 

175 to 749 0.3 0.15 2.6 0.01 

2013 

 750 2.6 0.32 2.6 0.075 

< 11 5.0 0.63 6.0 0.3 

11 to 25 5.0 0.63 4.9 0.3 

26 to 49 2.8 0.63 4.1 0.02 

50 to 74 2.8 0.21 3.7 0.02 

75 to 99 3.3 0.15 3.7 0.01 

100 to 174 0.3 0.15 3.7 0.01 

175 to 749 0.3 0.15 2.6 0.01 

2014 

 750 2.6 0.32 2.6 0.075 

Notes: Baseline emission factors for Vehicle Category 5 are based on the EPA Tier Rule emission standards for 

non-road compression engines (40 CFR Parts 9, 69, 89, et al.). 

For diesel engines, the HC to NMHC conversion factor is 0.984 (EPA, Conversion Factors for Hydrocarbon 

Emission Components, 420-P-04-001, April 2004). 

VOC emission factors were generated by multiplying HC emission factors by 1.053 for CI engines based on 

guidance provided by EPA A420-P-04-001 “Conversion Factors for Hydrocarbon Emission Components.”

FAA VALE Program Technical Report Page 9-8 Version 7
9.2 EDMS Data Collection, Modeling and Reporting 

9.2.1 EDMS 

EDMS contains many capabilities that contribute to more efficient vehicle and 

equipment emission calculations for the VALE program. These capabilities 

include: 

 A stand-alone post-processor for VALE applications called the 

Emissions Reduction Report, which standardizes and displays model 

results (see Figure 9-1). 

 A direct interface to EPA MOBILE6 for on-road vehicle emissions. 

Designating the study year in EDMS will automatically retrieve the 

proper emission factors from MOBILE. 

 The option of entering data through the EDMS graphical user interface 

or by using an external spreadsheet and importing those files into the 

model. 

The EDMS User’s Manual and other technical documents are available from the 

FAA Office of Environment and Energy (AEE) on the Internet at: 

www.faa.gov/about/office_org/headquarters_offices/aep/models/edms_model/. 

Following VALE project approval and implementation, sponsors are encouraged 

to use the newest version of EDMS to update estimated project emission 

reductions for AERC Statements and use. Sponsors should weigh the value of 

additional or more refined modeling against the costs of reanalysis using a new 

version of the model. 

9.2.2 Data and Analysis 

The scope of data collection is limited to the airport operations and emission 

sources that are part of the VALE project. With regard to operations data, 

sponsors are encouraged to use actual historical data for vehicles and equipment if 

possible rather than EDMS default data. 

Important usage factors include the number and type of units, rates of operation, 

useful life, and EPA-certified/verified emission levels as applicable. In the event 

that the sponsor lacks adequate historical records to determine hours of operation, 

a conservative estimate of existing operations should be developed using typical 

operating data for similar vehicles and equipment at the airport. A brief 

description of data requirements is provided below. 

FAA VALE Program Technical Report Page 9-9 Version 7
Vehicles 

Data Development: The following information is needed to evaluate emissions 

from existing and proposed project vehicles: 

 Number of units, by type 

 Manufacturer 

 Engine size 

 Model and model year 

 Fuel type 

 Certification documentation 

Additional GSE information includes: 

 Annual average fuel consumption 

 Annual average operating hours, by type 

Additional GAV information includes: 

 Average speed 

 Average annual miles traveled 

Sponsors may be able to count emission reductions and receive AERCs if nonairport vehicles (e.g., on-road regional fleets or private cars) use VALE-funded 

airport refueling and recharging stations. Emission reductions from non-project 

vehicles should be based on the proportion of reductions directly related to the 

VALE program. Except for this allowance, sponsors may not claim emission 

reductions for on-road vehicles that are considered part of metropolitan 

transportation plans and transportation improvement programs reflected in the 

transportation conformity process. 

The sponsor should work with the State air quality agency to determine the level 

of emission reductions claimed for non-VALE vehicles. Documentation should 

include: 

 Historical fueling records if available 

 Planned vehicle use of VALE facilities 

Emission Factors: For Vehicle Categories 1 and 2, where emission factors are 

expressed in grams per mile, the user should enter vehicle information into EDMS 

through a series of “Roadway” segments. For Vehicle Categories 4 and 5, where 

emission factors are expressed in grams per brake horsepower hour, the user 

should enter vehicle information into EDMS through a series of “User-Created 

GSE.” For Vehicle Category 3, the user should determine equivalent grams per 

mile ratio and enter a “Roadway” segment. 

 

The baselines should be developed with “user-defined” emission factors that are 

based on methodology and data presented in Section 9.1 above. For a new 

vehicle baseline, emission factors should be obtained from Tables 9-1 through 9-

5. For an existing or old vehicle baseline, the emission factors should be 

FAA VALE Program Technical Report Page 9-10 Version 7
determined using EPA NONROAD or MOBILE. Users can generate MOBILE 

emission factors directly within EDMS (defaults using national averages) or by 

running MOBILE and importing its emission factors into EDMS (for more local 

specificity). 

Emission factors for VALE project vehicles should be certified levels, which meet 

or exceed the VALE program low-emission standards (see Chapter 5). 

For proposed retrofits, the EDMS methodology should follow the appropriate 

vehicle category. Retrofit emission savings are generally expressed as a 

percentage reduction by pollutant. Project emission factors are determined by 

applying the percentage reduction to the EDMS-generated baseline emission 

factor. 

Criteria Pollutants: Volatile Organic Compounds (VOCs), an ozone precursor, 

are the most relevant category of organic gases and hydrocarbons for assessing 

VALE project cost-effectiveness. If VOC emission factors are not available, 

VOCs can be estimated from related levels for non-methane organic gases 

(NMOG), total hydrocarbons (HC), or non-methane hydrocarbons (NMHC). 

EDMS factors and supporting EPA/FAA guidance should be used for VOC 

conversions. 

On-road vehicle emission factors for PM10 should be determined by the ratio of 

PM10/PM2.5 default emission factors in MOBILE for the vehicle type and 

applying this percentage to the PM2.5 values listed in Tables 5-2 and Tables 9-1 

through 9-5 above. 

Sulfur dioxide (SO2) emission factors for conventionally-fueled on-road vehicles 

should be generated from MOBILE as the emission factors are fuel-based. 

Gate Electrification 

 

Gate electrification projects are the most popular VALE project type. These 

projects are among the most cost effective airport low-emission strategies and 

they provide direct cost savings to the airlines. 

Gate electrification projects consist of gate power (400 Hz converters) and/or 

preconditioned air units (PCA). Power is needed for aircraft (e.g., lighting, 

avionics, maintenance) when passengers or employees are present. PCA units are 

used to pump heated or cooled air into an aircraft to keep the aircraft at a 

comfortable temperature for passengers and employees. 

When used at the gate simultaneously, gate power and PCA enable parked aircraft 

to completely forego the use of APUs, resulting in reduced fuel consumption and 

emissions. However, gate power and PCA are independent systems that may be 

FAA VALE Program Technical Report Page 9-11 Version 7
FAA VALE Program Technical Report Page 9-12 Version 7

used differently. Among the factors that influence airline policy and pilot 

discretion on gate services are temperature and humidity, aircraft size, ground 

crew workload, and turnaround time. 

The three situations for gate electrification projects are as follows: 

 APU emissions eliminated (except for the default of 7 minutes needed 

on average to connect and disconnect gate services). In this situation, 

gate power and PCA are both provided to parked aircraft. 

 APU emissions avoided 5-30 percent of the time, depending on 

location. In this situation, gate power is available and used 100 

percent of the time while PCA is unavailable. As a result, APUs are 

still needed most of the time for heating and cooling the aircraft. 

 No APU emission reductions. In this situation, PCA is provided but 

gate power is not. Since the use of gate power is assumed 100 percent 

of the time, APU usage is not reduced. 

 

In the second situation above, where a gate is equipped with power but no PCA, 

the reduction in APU use depends upon the ambient temperature and/or humidity. 

For purposes of VALE calculations, APU are not used when the ambient 

temperature is between 45o F and 50o F and no external heating or cooling of the 

cabin is needed.47 

To determine the amount of time that the temperature is between 45O F and 50O F 

at a given airport, the sponsor should obtain and average local temperature data 

for the most recent 5-year period. The recommended source of information is the 

National Climatic Data Center (NCDC) at http://www.ncdc.noaa.gov. 

The recommended steps in preparing operational baseline and project scenarios 

for gate electrification projects are as follows: 

1. Analyze the most recent and representative year of arrival and departure 

data at the airport to locate the most “representative” day of the year for 

numbers of operations and fleet mix (aircraft type and APU type). 

2. Match arrivals with departures to obtain the number of aircraft turns and 

average gate times (i.e., departure times minus arrival times) at each of the 

proposed gates. 

3. Cap gate time for long aircraft turnarounds at 60 minutes for narrow body 

aircraft and 90 minutes for wide body aircraft unless the APU is required 

to run for more time than it takes to load and unload passengers. 

4. Once the “representative daily schedule” has been determined, re-scale 

operations into a “representative year” (multiply times 365 days in a year). 

 

47 Ambient temperature range based on conversations with airport and industry officials. 
FAA VALE Program Technical Report Page 9-13 Version 7

5. Build a full schedule for the project life, which may often involve a 

proportional increase in operations using an approved growth rate.48 

In addition, the following assumptions may be used for the baseline scenario: 

 All power and heating/cooling needs met via the use of APUs 

 Aircraft are equipped with default APU units as identified in EDMS 

And for the low-emission project scenario: 

 Most power and heating/cooling needs met via the use of PCA and 

gate power 

 A default of 7 minutes of APU time for connecting and disconnecting 

the PCA and gate power 

 Aircraft are equipped with default APU units as identified in EDMS 

EDMS users should take special note that aircraft must be entered in gate 

electrification projects to estimate APU emissions. 

It is also recommended that users separate data inputs for gate power and PCA on 

combined projects. The reason is that the estimated useful life of gate power is 20 

years, while the useful life of a PCA unit is 13 years. 

With both gate power and PCA in the first 13 years of the project, APU emissions 

are avoided 100 percent of the time. In the last 7 years of the project, with only 

gate power, APU emissions are avoided only when the ambient temperature is 

between 45O F and 50O F. A simple way to set up modeling inputs for the last 7 

years is to multiply the projected number of operations for years 14-20 by the 

percent of the year that the temperature is between 45O F and 50O F. 

 

Boiler/HVAC Systems 

Below are required data for each new boiler acquired for an airport heating plant 

or HVAC improvement. Typically, boilers are used for heating individual 

terminal buildings, hangars, or air traffic control towers. A separate analysis 

outside of EDMS may be required to determine annual fuel throughput for 

proposed HVAC systems and/or terminal boilers. 

 Type of boiler 

 Heat capacity 

 Fuel type 

 Fuel throughput 

 Percentage of project serving non-revenue producing public-use areas 

 

48 DOT/FAA Terminal Area Forecast for the itinerant air carriers, the airport’s approved Master Plan, or a 

recent Environmental Impact Statement, 
User-defined emissions factors, sulfur/ash content, and pollutant control factors 

may be applied, if available. Otherwise, the EDMS default emission parameter 

values may be used. 

9.2.3 Emissions Reduction Report 

The EDMS Emissions Reduction (ER) Report is a required element in all VALE 

proposals. An example of the new ER Report format is shown in Figure 9-1. 

This version of the report will be available in EDMS 5.1.3, which the FAA 

expects to release in November 2010. 

The ER Report provides a concise annual listing of estimated net emissions 

reductions for the proposed project. The emission results from the report are used 

to determine project cost effectiveness and the number of AERCs generated by 

the project, including extra AERCs if the sponsor makes a replacement 

commitment (option) to extend the useful life of vehicles and equipment up to 20 

years. 

To produce the ER Report, the user begins by selecting the VALE option in the 

EDMS “Study Properties” window and entering the number of project years. 

Next, the user goes to the “VALE Settings” window (see Emissions tab) to select 

project source groups and to match equipment for the baseline and project 

scenarios. EDMS source groups include: Aircraft, APU, GSE Population, 

Parking Facility, Roadway, Training Fire, and Stationary Source. The ER Report 

only presents the source groups that are selected for the VALE project analysis. 

Results shown in the ER Report include baseline emissions, project emissions, 

and the net savings from the project for each year of the project. Values are 

presented for all of the major criteria pollutants, including ozone precursors. 

Summaries of emission levels by pollutant are presented at the bottom of the 

report. 

FAA VALE Program Technical Report Page 9-14 Version 7
Figure 9-1. Format of EDMS ER Report 

FAA VALE Program Technical Report Page 9-15 Version 7
9.3 Project Cost Effectiveness 

This section presents information and methodology that the sponsor must use to calculate 

the cost effectiveness of the project. Cost effectiveness is a parameter that allows the 

FAA to assess whether the sponsor’s proposed use of Federal dollars to reduce airport 

emissions will be accomplished in a fiscally responsible manner. 

The FAA evaluates cost effectiveness on the basis of the project’s total costs versus 

estimated emission reductions. Cost effectiveness is defined simply as the total amount 

of dollars spent on the project, as determined by the Federal share and the required local 

match if AIP funded, divided by project emission reductions (tons) over the estimated 

useful life of vehicles and equipment. This calculation is performed for each criteria 

pollutant (see Appendix D, Page 6 of the Project Application Worksheets). 

The emphasis of the VALE program is on airport 

capital improvement projects using proven lowemission technologies that are commercially 

viable. Because the emphasis of AIP and PFC 

programs is construction and deployment, R&D 

activities are not eligible. For proposed airport 

demonstration projects of commercially ready 

technology, sponsors should refer to the AIP Handbook (FAA Order 5100.38C, Chapter 

5, Section 504(b)). 

Funding emphasis is on 

deployment – 

R&D is not eligible. 

9.3.1 Cost Considerations 

The sponsor must indicate the requested amount of AIP and/or PFC funding on 

the project application. If the sponsor is requesting AIP funding, the source of 

local matching funds must also be identified. 

The sponsor is required to show due diligence by competitively bidding and 

assessing low-emissions technology and cost information prior to submitting a 

project application to the FAA. 

On vehicles, cost information should always distinguish between eligible 

incremental costs, which are included in the cost effectiveness calculations, and 

base costs, which are not eligible project costs and are not included in the cost 

effectiveness calculations. 

On infrastructure, cost information should include project formulation, 

engineering and design, and construction. Costs that are not allowed or assessed 

include feasibility studies, O&M, fuel, and separate facilities to store lowemission vehicles or equipment. 

FAA VALE Program Technical Report Page 9-16 Version 7
FAA VALE Program Technical Report Page 9-17 Version 7

While the basis for project cost effectiveness is the initial capital investment, the 

sponsor is encouraged to develop supplemental life-cycle cost information and to 

submit this information in the VALE application. For example, electric vehicles 

generally cost less to operate and maintain than conventional fuel vehicles, even 

when accounting for battery replacement costs before the end of the vehicle’s 

useful life. 

For many categories of eligible projects, particularly large infrastructure projects, 

the agency will give additional consideration to projects that improve project costeffectiveness through cost-sharing arrangements with airport tenants, local 

utilities, State and local governments, equipment manufacturers, and other 

stakeholders (see Chapter 6). 

9.3.2 Cost Effectiveness Ranges 

The cost effectiveness ranges provided in Table 9-7 apply to all VALE program

vehicle and infrastructure projects above $200,00049. The cost effectiveness 

ranges are reviewed annually and updated as needed based on VALE project 

experience and discussions with airport operators and equipment manufacturers. 

Although the ranges are recommended levels, they represent an important factor 

in VALE project approvals along with other budget and program considerations. 

The FAA evaluates project cost effectiveness on the basis of total project costs50

versus emission reductions over the useful life of vehicles and equipment. The 

emphasis of this evaluation will be on Level One pollutants.

Table 9-6. Cost Effectiveness Ranges 

Pollutant Cost Effectiveness Ranges 

($/ton) 

Ozone (NOx + VOC) $10,000 to $30,000 

CO $10,000 to $15,000 

PM10 $100,000 to $175,000 

PM2.5 To Be Determined 

 

49 Cost effectiveness for projects with a total cost below $200,000 are unduly affected by project 

formulation and related expenses. 

50 For AIP-funded projects, “total project costs” is the sum of the grant amount and the required local 

match. 
FAA VALE Program Technical Report Page 9-18 Version 7

The FAA gains more experience each year in evaluating low-emission projects 

and recognizes that cost effectiveness varies by project type, project engineering 

requirements, local factors, and airport size. For example, the cost effectiveness 

of VALE vehicle projects is affected by increasingly cleaner EPA minimum fleet 

standards. With respect to infrastructure, a small project involving a refueling 

station may yield lower cost effectiveness (i.e., showing higher dollar values than 

the ranges listed above) because of the greater investment in supporting 

infrastructure versus emission savings.51 Another example is gate electrification 

projects, for which cost effectiveness will vary by the amount of work required to 

upgrade electric lines and subsystems at the terminal. 

9.4 Use of AERCs

As described in the AERC Report, sponsors are allowed to use earned AERCs to meet 

their CAA requirements for general conformity and new source review (NSR).52 For 

demonstrating general conformity, sponsors are allowed to apply AERCs as “design 

measures” against the annual de minimis levels established in the CAA. For NSR permit 

requirements, AERCs are applied as emission “offsets.” Notwithstanding differences in 

how AERCs may be allocated and applied for general conformity and NSR, AERCs 

earned by a sponsor for a particular year can only be counted towards the regulatory 

requirements of that same year. Once AERCs are used from the available “pool” of 

yearly AERCs, these AERCs are no longer available that year for either regulation. 

The following example for general conformity illustrates how AERCs might be applied 

to an airport development project that exceeds the de minimis thresholds. Suppose a 

sponsor successfully completes two separate projects under the VALE program and 

receives AERCs for NOx emissions. VALE Project 1 is the conversion of employee 

transport buses to new alternative fuel engines, with a total useful life of 12 years. VALE 

Project 2 is the conversion of aircraft tugs to CNG fuel, with an expected useful life of 13 

years. At some future time, an improvement project proposed for the same airport is 

estimated to cause construction emissions above the de minimis levels for NOx. In this 

scenario, the 5-year construction period overlaps with year 3 through year 7 of the VALE 

projects. This construction causes annual emissions of NOx that exceed the de minimis

threshold by 1 ton to 5 tons each year. The annual assignment of AERCs for NOx and 

the use of the credits that will allow the airport project to conform are illustrated in Table 

9-6. 

 

51 Information on the cost effectiveness of various emissions reduction programs eligible under the Federal 

Highways Congestion Mitigation and Air Quality Improvement Program (CMAQ) can be found at the 

website: www.dieselforum.org/retrofit-tool-kit-homepage/cost-effectiveness-comparisons. 

52 Participating airport sponsors must comply with VALE program requirements and AIP grant assurances 

(FAA Orders 5100.38C and 5190.6B, and Federal Register Notice Vol. 64, No. 30, February 16, 1999, on 

“Policy and Procedures Concerning the Use of Airport Revenue”) if additional emission credits (e.g., CO2) 

from VALE projects are possible to obtain. 
Table 9-7. Example Application of NOx AERCs 

Calendar Year of VALE Project Operations 

Grant/Action (tons per year) 

1 2 3 4 5 6 7 8 9 

CAAA de minimis threshold 

for NOx

50 50 50 50 50 50 50 50 50 

Direct and indirect NOx emissions 

from airport improvement project 53 54 48 51 50 

VALE Project 1 AERCs 1 2 2 2 2 2 2 2 2 

VALE Project 2 AERCs 0 0 4 4 4 4 4 4 4 

Total AERCs available 1 2 6 6 6 6 6 6 6 

AERCs used for 

General Conformity 4 5 0 2 1 

Annual balance of available 

AERCs after General Conformity 1 2 2 1 6 4 5 6 6 

Annual NOx emissions from 

construction with AERC use 49 49 48 49 49 

In this example, VALE Project 1 is initiated in the middle of year 1 and initially 

generates 1 tpy of (NOx) AERCs. The project’s full emission reduction potential of 2 tpy 

of AERCs is generated for the following years. VALE Project 2 generates 4 tpy of 

AERCs each year beginning in year 3. The construction-related emissions of NOx 

resulting from the proposed improvement project are expected to exceed the de minimis

threshold of 50 tpy in four of the construction years, beginning in year 3. In year 3, 4 tpy 

of AERCs would be used to bring the construction emissions down to 49 tons, which is 

below the de minimis threshold. Similarly, in year 4, 5 tpy of AERCs would be 

consumed; in year 5, no AERCs are needed; in year 6, 2 tpy of AERCs would be 

consumed; and in year 7, only 1 tpy of AERCs would be required. Each year, the balance 

of AERCs is equal to the total assigned from Project 1 and Project 2, minus the number 

of AERCs consumed to bring the construction emissions below the de minimis

thresholds. After construction, since AERCs are permanent for the lifetime of the VALE 

project, the full value of Project 1 and Project 2 AERCs returns each year to their full 

emission reduction potential. 

FAA VALE Program Technical Report Page 9-19 Version 7
FAA VALE Program Technical Report Page 9-20 Version 7

THIS PAGE INTENTIONALLY LEFT BLANK 
APPENDIX A 

GLOSSARY OF TERMS

Aftertreatment Device Engine pollutant emissions are generally reduced by engine 

modifications, fuel specifications or exhaust gas 

aftertreatment. An aftertreatment device is a component used 

to reduce engine pollutant emissions downstream of the 

combustion chamber. Catalytic converters and particulate 

traps are examples of aftertreatment devices. 

Airport-Dedicated Located of primarily used at the airport. 

Airport Owned Owned directly by the sponsor. 

Alternative Fuel Consistent with the Energy Policy Act (EPAct), nonconventional fuels including: compressed natural gas (CNG), 

liquefied petroleum gas (LPG), hydrogen, electricity, and any 

liquid at least 85 percent of the volume of which consists of 

methanol (M85) or ethanol (E85). 

Alternative Fuel Vehicle 

(AFV) 

A vehicle that is powered by an alternative fuel. 

Attainment Area A geographic area in which levels of a criteria air pollutant 

meet the health-based primary standard (national ambient air 

quality standard, or NAAQS) for the pollutant. An area may 

have an acceptable level for one criteria air pollutant, but may 

have unacceptable levels for others. Thus, an area could be 

both attainment and nonattainment at the same time. 

Attainment areas are defined using federal pollutant limits set 

by EPA. 

Base Cost The cost of a conventional-fueled vehicle. 

Bi-Fuel Vehicle A vehicle that can operate on either an alternative fuel or 

conventional fuel, but not both simultaneously. Typically, the 

operator can manually choose which fuel to operate the 

vehicle. 

Bio Fuel Fuel that is produced from biomass, including corn, soybeans, 

and other grains. Bio-fuel is often part of a blend (e.g., “B5” 

represents 5 percent bio-fuel). 

Brake Horsepower (bhp) This value is determined experimentally with the use of a 

band brake, as the name implies, or more modernly, with an 

absorption dynamometer. Horsepower is the rate of doing 

work, measured in units equal to lifting 33,000 pounds a 

distance of one foot in one minute (1 hp = 0.746 kwh). As 

applied to an internal combustion engine, it is the amount of 

work done per minute by the torque developed by the engine. 

 BHP = T x RPM / 5252 where, 

T = torque expressed in foot-pounds 

FAA VALE Program Technical Report Page A-1 Version 7
RPM = engine revolutions/minute 

Carbon Monoxide (CO) A criteria pollutant that is colorless, odorless, poisonous gas, 

and is produced by incomplete burning of carbon-based fuels, 

including gasoline, oil, and wood. Carbon monoxide is also 

produced from incomplete combustion of many natural and 

synthetic products (e.g., cigarette smoke). When carbon 

monoxide gets into the body, it combines with chemicals in 

the blood and prevents the blood from bringing oxygen to 

cells, tissues and organs. The body's parts need oxygen for 

energy, so high-level exposures to carbon monoxide can cause 

serious health effects, with death possible from massive 

exposures. Symptoms of exposure to carbon monoxide can 

include vision problems, reduced alertness, and general 

reduction in mental and physical functions. Carbon monoxide 

exposures are especially harmful to people with heart, lung 

and circulatory system diseases. 

Catalytic Converter A catalytic converter consists of a metal housing filled with a 

hard material that is covered with a catalytic compound. The 

presence of the catalytic converter in the engine exhaust 

system breaks down the chemicals in the exhaust and reduces 

harmful pollutant emissions. 

Certified Certification means, with respect to new highway and nonroad engines, obtaining a certificate of conformity from the 

EPA for an engine family that complies with the highway or 

non-road engine emission standards and requirements. 

Clean Air Act (CAA) The original Clean Air Act was passed in 1963, but the 

national air pollution control program is actually based on the 

1970 version of the law. The 1990 Clean Air Act 

Amendments are the most far-reaching revisions of the 1970 

law. The 1990 amendments are routinely referred to as the 

1990 Clean Air Act. 

Clean Diesel (ULSD) Ultra low-sulfur diesel fuel that has 15 ppm or less of sulfur 

Clean Fuels Low-pollution fuels that can replace ordinary gasoline. These 

are alternative fuels, such as electricity, gasohol (gasolinealcohol mixtures), natural gas and LPG (liquefied petroleum 

gas). 

Conventional Fuel Petroleum-based fuels, primarily gasoline and diesel 

Commercial Service 

Airport 

A publicly owned airport in a State that the Secretary 

determines has at least 2,500 passenger boardings each year 

and is receiving scheduled passenger aircraft service. The 

airport must also be listed in the FAA’s NPIAS. 

Cost Effectiveness The greatest air quality benefits measured by the amount of 

emissions reduced per dollar of funds expended. 

Criteria Air Pollutants A group of very common air pollutants regulated by EPA on 

the basis of health and/or environmental effects of pollution. 

FAA VALE Program Technical Report Page A-2 Version 7
Criteria air pollutants are widely distributed all over the 

country. They are CO, NO2, SO2, PM10, PM2.5, O3, and lead. 

Diesel Engine An engine that operates on diesel fuel and principally relies on 

compression-ignition for engine operation. The non-use of a 

throttle during normal operation is indicative of a diesel 

engine. 

Electric Vehicle (EV) Vehicles that derive 100 percent of their motive energy from 

the electric grid via batteries. 

Engine Family Each group of engines with similar emission characteristics is 

defined as a separate engine family. Vehicles or engines in an 

engine family are expected to have similar emission 

characteristics. A permanent label is affixed to the engine, 

which lists the engine family designation as well as other 

important information. 

Flexible-Fuel Vehicles 

(FFV) 

Vehicles that automatically detect the blended fuel 

composition in the fuel tank, and adjust the combustion 

parameters accordingly for optimum engine performance. 

Typically, FFVs operate on an alcohol-gasoline blend such as 

ethanol/gasoline or methanol/gasoline. 

Fuel Cells Energy released by the oxidation of hydrogen to water is 

directly converted to an electrical current. 

Fuel Cell Vehicle An electric vehicle powered by a chemical hydrogen fuel cell 

battery. These vehicles may or may not be capable of 

capturing regenerative braking energy. 

Gross Vehicle Weight 

Rate (GVWR) 

The manufacturer’s specified maximum design loaded weight 

for a single vehicle (40 CFR 86.1803-01). 

Ground Access Vehicles 

(GAV) 

Vehicles licensed for on-road use. 

Ground Support 

Equipment (GSE) 

Non-road vehicles used on the airport tarmac to service 

aircraft and other airport-specific duties. 

Highway Engine Any engine which is designed to transport people or property 

on a street or highway. 

Hybrid Vehicle As defined in Subpart R – General Provisions for the 

Voluntary National Low-emission Vehicle Program for LightDuty Vehicles and Light-Duty Trucks (62 FR 31242, June 6, 

1997), any vehicle defined as a series hybrid electric vehicle

that delivers power to the wheels by battery-powered electric 

motor, but which also incorporates the use of a combustion 

engine to provide power to the battery and/or electric motor; a 

parallel hybrid electric vehicle that delivers power to the 

wheels by either a combustion engine and/or by a batterypowered electric motor, or a battery assisted combustion 

engine vehicle that uses stored battery packs to propel the 

vehicle. 

Hydrocarbons (HC) An exhaust and evaporative pollutant of hydrogen and carbon 

atoms resulting from unburned fuel. The volatile portion of 

FAA VALE Program Technical Report Page A-3 Version 7
HCs contribute to the formation of ozone which is responsible 

for the choking, coughing, and stinging eyes associated with 

ozone smog. Ozone damages lung tissue, aggravates 

respiratory disease, and makes people more susceptible to 

respiratory infections. 

Incremental Cost The cost difference between a low-emissions vehicle typically 

powered by an alternative fuel, and the conventional-fueled 

equivalent 

Large Hub Airport A commercial service airport that has 1 percent or more of the 

annual passenger boardings. 

Level One Pollutants The criteria pollutant(s) that is causing the area nonattainment 

or maintenance status. 

Level Two Pollutants The remaining criteria pollutants that are not Level One 

Pollutants. 

Low-Emission 

Technology 

Technology for vehicles and equipment whose emission 

performance is the best achievable under emission standards 

established by the EPA and that relies exclusively on 

alternative fuels that are substantially non-petroleum based, as 

defined by the Department of Energy, but not excluding 

hybrid systems or natural gas powered vehicles. 

Low-Emission Vehicle 

(LEV) 

Any vehicle certified to the low-emission vehicle standards 

specified in this program. 

Low Sulfur Diesel Fuel Current EPA regulations specify that diesel test fuel contain 

300-500 ppm sulfur for highway engines and 300-4,000 ppm 

sulfur for non-road engines. Significant reductions from these 

current sulfur levels are necessary in order for many retrofit 

technologies to provide meaningful, lasting emissions 

reductions. The manufacturers of these retrofit technologies 

will specify the maximum allowable sulfur level for effective 

operation of its products. In addition to enabling a wide array 

of emissions control technologies, the use of low sulfur alone 

reduces emissions of particulate matter. Sulfate, a major 

constituent of particulate matter, is produced as a byproduct of 

burning diesel fuel containing sulfur. Reducing the sulfur 

content of fuel in turn reduces sulfate byproducts of 

combustion and therefore particulate matter emissions. 

Maintenance Area (MA) A geographic area that was formerly nonattainment for one or 

more criteria pollutants, but has experienced three or more 

years of no violations of the NAAQS. Maintenance status 

typically lasts for two consecutive decades to ensure air 

quality has improved adequately. 

Medium-Duty Passenger 

Vehicle (MDPV) 

Federal definition for vehicles between 8,501-10,000 GVWR 

designed primarily for the transport of persons, including 

conversion vans. Not included are: any vehicle that has a 

capacity of more than 12 persons total, any vehicle designed 

to accommodate more than 9 persons in seating rearward of 

FAA VALE Program Technical Report Page A-4 Version 7
the driver’s seat, and any vehicles that has a cargo box of six 

feet or more in interior length. 

Medium Hub Airport A commercial service airport that has at least 0.25 percent but 

less than 1 percent of the annual passenger boardings. 

Model Year (MY) The manufacturer's annual new model production period 

which includes January 1 of the calendar year, ends no later 

than December 31 of the calendar year, and does not begin 

earlier than January 2 of the previous calendar year. Where a 

manufacturer has no annual new model production period, 

model year means calendar year. 

National Ambient Air 

Quality Standards 

(NAAQS) 

The Clean Air Act (amended in 1990), requires EPA to set 

National Ambient Air Quality Standards for pollutants 

considered harmful to public health and the environment. The 

Clean Air Act established two types of national air quality 

standards. Primary standards set limits to protect public 

health, including the health of "sensitive" populations such as 

asthmatics, children, and the elderly. Secondary standards set 

limits to protect public welfare, including protection against 

decreased visibility, damage to animals, crops, vegetation, and 

buildings. 

The EPA has set NAAQS for six principal pollutants, which 

are called "criteria" pollutants. They are O3, CO, NO2, SO2, 

PM10, PM2.5, and lead. 

Natural Gas Either compressed natural gas (CNG) or liquefied natural gas 

(LNG). 

Neofit A pre-market modification of a vehicle with control 

equipment directly from an OEM and before delivering the 

vehicle to the purchaser. 

New Vehicle Vehicle purchased from an OEM that essentially has no miles 

on it. This definition does not include reprogrammed or reengined vehicles. 

Nitrogen Oxides (NOx) Nitrogen oxides are a family of reactive gaseous compounds 

that contribute to air pollution in both urban and rural 

environments. NOx emissions are produced during the 

combustion of fuels at high temperatures. The primary 

sources of atmospheric NOx include highway sources (such as 

light-duty and heavy-duty vehicles), non-road sources (such 

as construction and agricultural equipment, and locomotives) 

and stationary sources (such as power plants and industrial 

boilers). NOx can irritate the lungs, cause bronchitis and 

pneumonia, and lower resistance to respiratory infections. 

Nitrogen oxides are an important precursor both to ozone and 

acid rain, and may affect both terrestrial and aquatic 

ecosystems. 

Nonattainment Area A locality where air pollution levels persistently exceed 

FAA VALE Program Technical Report Page A-5 Version 7
(NA) National Ambient Air Quality Standards. Designating an area 

as nonattainment is a formal rulemaking process and EPA 

normally takes this action only after air quality standards have 

been exceeded for several consecutive years. 

Non Methane 

Hydrocarbons (NMHC) 

Same as the definition of non-methane organic gases 

(NMOG), but excludes oxygenated hydrocarbons such as 

alcohols and aldehydes. 

Non Methane Organic 

Gases (NMOG) 

Organic compounds in the atmosphere that contain the 

element carbon (C) and are reactive with nitrogen oxides in 

the presence of sunlight to produce ozone in the troposphere. 

This includes oxygenated hydrocarbons such as alcohols and 

aldehydes, but does not include less reactive hydrocarbons 

such as methane. 

Non-road Engine Although non-road engines can be self-propelled vehicles that 

are not licensed to travel on streets and highways, their 

primary function is to perform a particular task. Examples of 

non-road engines include ground support equipment, garden 

tractors, lawnmowers, bulldozers, and cranes. 

Oxidation Catalyst A type of catalyst (e.g., catalytic converter) which chemically 

converts HC (hydrocarbons) and CO (carbon monoxide) to 

water vapor and carbon dioxide. 

Oxygenated fuel Special type of gasoline, which burns more completely than 

regular gasoline in cold start conditions; more complete 

burning results in reduced production of CO. In some parts of 

the country, CO release from cars starting up in cold weather 

makes a major contribution to pollution. In these areas, 

gasoline refiners must market oxygenated fuels, which contain 

higher oxygen content than regular unleaded gasoline. 

Ozone (O3) Ozone is a photochemical oxidant and the major component 

of smog. While O3 in the upper atmosphere shields the earth 

from harmful ultraviolet radiation that comes from the sun, 

high concentrations of O3 at ground level are a major health 

and environmental concern. O3 is not emitted directly into the 

air but is formed through complex chemical reactions between 

emissions of volatile organic compounds (VOC) and nitrogen 

oxides (NOx) in the presence of sunlight. These reactions are 

stimulated by sunlight and temperature so that peak O3 levels 

occur typically during the warmer times of the year. Both 

VOCs and NOx are emitted by transportation and industrial 

sources such as vehicles, chemical manufacturing, dry 

cleaners and paint shops. 

O3 causes health problems because it damages lung tissue, 

reduces lung function and sensitizes the lungs to other 

irritants. Scientific evidence indicates that ambient levels of 

O3 not only affect people with impaired respiratory systems, 

FAA VALE Program Technical Report Page A-6 Version 7
such as asthmatics, but healthy adults and children as well. 

Exposure to O3 for several hours at relatively low 

concentrations has been found to significantly reduce lung 

function and induce respiratory inflammation in normal, 

healthy people during exercise. This decrease in lung 

function generally is accompanied by symptoms including 

chest pain, coughing, sneezing, and pulmonary congestion. 

Particulate Matter (PM) PM includes dust, dirt, soot, smoke and liquid droplets 

directly emitted into the air by sources such as factories, 

power plants, cars, engines, construction activity, fires and 

natural windblown dust. Particles formed in the atmosphere 

by condensation or by transformation of emitted gases are 

also considered particulate matter. 

Exposure to PM include effects on breathing and respiratory 

symptoms, aggravation of existing respiratory and 

cardiovascular disease, alterations in the body's defense 

systems against foreign materials, damage to lung tissue, as 

well as premature death. The major subgroups of the 

population that appear to be most sensitive to the effects of 

PM include individuals with chronic obstructive pulmonary or 

cardiovascular disease or influenza, asthmatics, the elderly 

and children. Particulate matter is a cause of impaired 

visibility in the United States. 

The EPA has established NAAQS for PM with aerodynamic 

diameters less than or equal to 10 micrometers (PM10) and 

PM with aerodynamic diameters less than or equal to 2.5 

micrometers (PM2.5). 

Particulate Trap/Filter An aftertreatment device which filters or traps diesel 

particulate matter from engine exhaust until the trap becomes 

loaded to the point that a regeneration cycle is implemented to 

burn off the trapped particulate matter. 

Program Low-Emission 

Standards 

Low-emission EPA standards that are more stringent than 

existing vehicle emission standards, with the goal of 

generating early voluntary emission reductions. 

Project Life The number of years that a project lasts based on the longest 

useful life of vehicles or equipment or alternatively up to 20 

years if the sponsor makes a replacement commitment (AERC 

Option). 

Public Access The use of VALE-funded low-emission technology by 

persons not affiliated with the airport or related operations. 

Retrofit Refers to aftermarket vehicle improvements that reduce 

emissions, including vehicle re-engining or repowering, the 

addition of pollution control aftertreatment equipment to 

certified engines, and engine conversions to cleaner fuels.

FAA VALE Program Technical Report Page A-7 Version 7
FAA VALE Program Technical Report Page A-8 Version 7

Small Hub Airport A commercial service airport that has at least 0.05 percent but 

less than 0.25 percent of the annual passenger boardings. 

Sponsor Also known as “Airport sponsors” that are planning agencies, 

public agencies, or private airport owners/operators that have 

the legal and financial ability to carry out the requirements of 

the AIP program. The term is also used in this document to 

refer to the PFC program, which is restricted to “public 

agencies.” 

State Implementation 

Plan (SIP) 

A State Implementation Plan (SIP) is a written plan that 

describes a state's strategy for achieving and maintaining the 

National Ambient Air Quality Standards. Section 110 of the 

Clean Air Act requires states with areas that do not meet the 

air standards to develop a written SIP outlining steps they will 

take to reduce air pollution. The purpose of a SIP is to ensure 

the implementation of programs that will reduce emissions. 

Sulfur Dioxide (SO2) A criteria air pollutant. SO2 is a gas produced by burning fuels 

containing sulfur. Some industrial processes, such as 

production of paper and smelting of metals, produce sulfur 

dioxide. SO2 is closely related to sulfuric acid, a strong acid. 

SO2 plays an important role in the production of acid rain. 

Ultra Low-emission 

Vehicle (ULEV) 

Defined in 40 CFR 88.302, either conventionally or 

alternatively fueled. 

Ultra Low Sulfur Diesel 

(ULSD) 

Current EPA regulations specify that ultra low sulfur diesel 

fuel contain 15 ppm sulfur. 

Useful Life The number of years that a vehicle or piece of equipment 

generally functions as originally manufactured, without 

catastrophic breakdown or major repair. 

Verified Retrofit 

Technology List 

This is a list that EPA prepares of Heavy Duty Diesel (HDD) 

emission control technologies that are suitable for use with 

HDD engines. If a control technology appears on EPA's list, 

the manufacturer’s emission reduction claims have been 

confirmed through EPA’s Environmental Technology 

Verification Program. For more information see 

http://www.epa.gov/etv/centers/center5.html. 

Volatile Organic 

Compounds (VOC) 

Generally, all organic compounds in the atmosphere that 

contain the element carbon (C) and that are reactive to drive 

the formation of ozone in the presence of sunlight. This 

includes oxygenated compounds such as alcohols and 

aldehydes. Some hydrocarbons are less ozone-forming than 

other hydrocarbons, so EPA has officially excluded them 

from the definition of regulated hydrocarbons or VOCs. 

These compounds include methane, ethane, and compounds 

not commonly found in large quantities in engine exhaust like 

chlorohydrocarbons. Many VOCs are also hazardous air 

pollutants. 
APPENDIX B 

VISION 100 – CENTURY OF AVIATION 

REAUTHORIZATION ACT

This Appendix provides the applicable Vision 100 Legislative Sections that support the 

FAA VALE program: 

 Section 121 – Low-emission airport vehicles and ground support equipment 

 Section 151 – Increase in apportionment for, and flexibility of, noise compatibility 

planning programs 

 Section 158 – Emission credits for air quality projects 

 Section 159 – Low-emission airport vehicles and infrastructure 

They are as follows: 

Subtitle B – Passenger Facility Fees 

SEC. 121. LOW-EMISSION AIRPORT VEHICLES AND GROUND SUPPORT 

EQUIPMENT. 

(a) IN GENERAL. – Section 40117(a)(3) is amended by inserting at the end the 

following: 

“(G) A project for converting vehicles and ground support equipment used 

at a commercial service airport to low-emission technology (as defined in 

section 47102) or to use cleaner burning conventional fuels, retrofitting of 

any such vehicles or equipment that are powered by a diesel or gasoline 

engine with emission control technologies certified or verified by the 

Environmental Protection Agency to reduce emissions, or acquiring for 

use at a commercial service airport vehicles and ground support equipment 

that include low-emission technology or use cleaner burning fuels if the 

airport is located in an air quality nonattainment area (as defined in section 

171(2) of the Clean Air Act (42 U.S.C. 7501(2))) or a maintenance area 

referred to in section 175A of such Act (42 U.S.C. 7505a) and if such 

project will result in an airport receiving appropriate emission credits as 

described in section 47139.”. 

(b) MAXIMUM COST FOR CERTAIN LOW-EMISSION TECHNOLOGY PROJECTS. – Section 

40117(b) is amended by adding at the end the following: 

“(5) MAXIMUM COST FOR CERTAIN LOW-EMISSION TECHNOLOGY PROJECTS. 

– The maximum cost that may be financed by imposition of a passenger 

facility fee under this section for a project described in subsection 

FAA VALE Program Technical Report Page B-1 Version 7
(a)(3)(G) with respect to a vehicle or ground support equipment may not 

exceed the incremental amount of the project cost that is greater than the 

cost of acquiring a vehicle or equipment that is not low-emission and 

would be used for the same purpose, or the cost of low-emission 

retrofitting, as determined by the Secretary.”. 

(c) GROUND SUPPORT EQUIPMENT DEFINED. – Section 40117(a) is amended – 

(1) by redesignating paragraphs (4) and (5) as paragraphs (5) and (6), 

respectively; and 

(2) by inserting after paragraph (3) the following: “(4) GROUND SUPPORT 

EQUIPMENT. – The term ‘ground support equipment’ means service and 

maintenance equipment used at an airport to support aeronautical 

operations and related activities.”. 

(d) GUIDANCE. – The Secretary, in consultation with the Administrator of the 

Environmental Protection Agency, shall issue guidance determining eligibility of 

projects, and how benefits to air quality must be demonstrated, under the 

amendments made by this section. 

Subtitle C – AIP Modifications 

SEC. 151. INCREASE IN APPORTIONMENT FOR, AND FLEXIBILITY OF, 

NOISE COMPATIBILITY PLANNING PROGRAMS. 

Section 47117(e)(1)(A) is amended – 

(1) by striking “At least 34 percent” and inserting “At least 35 percent”; 

(2) by striking “of this title and” and inserting a comma; 

(3) by striking “of this title.” And inserting “, for noise mitigation projects 

approved in an environmental record of decision for an airport development 

project under this title, for compatible land use planning and projects carried 

out by State and local governments under section 47141, and for airport 

development described in section 47102(3)(F), 47102(3)(K), or 47102(3)(L) 

to comply with the Clean Air Act (42 U.S.C. 7401 et seq.)”; and 

(4) by striking “34 percent requirement” and inserting “35 percent requirement”. 

SEC. 158. EMISSION CREDITS FOR AIR QUALITY PROJECTS. 

(a) EMISSIONS CREDIT. – Subchapter I of chapter 471 is further amended by 

adding at the end the following: 

“§ 47139. Emission credits for air quality projects 

“(a) IN GENERAL. – The Administrator of the Environmental Protection 

Agency, in consultation with the Secretary of Transportation, shall issue guidance 

on how to ensure that airport sponsors receive appropriate emission reduction 

FAA VALE Program Technical Report Page B-2 Version 7
credits for carrying out projects described in sections 40117(a)(3)(G), 

47102(3)(F), 47102(3)(L). Such guidance shall include, at a minimum, the 

following conditions: 

“(1) The provision of credits is consistent with the Clean Air Act (42 U.S. 

C. 7402 et seq.). 

“(2) Credits generated by the emission reductions are kept by the airport 

sponsor and may only be used for purposes of any current or future 

general conformity determination under the Clean Air Act or as 

offsets under the Environmental Protection Agency’s new source 

review program for projects on the airport or associated with the 

airport. 

“(3) Credits are calculated and provided to airports on a consistent basis 

nationwide. 

“(4) Credits are provided to airport sponsors in a timely manner. 

“(5) The establishment of a method to assure the Secretary that, for any 

specific airport project for which funding is being requested, the 

appropriate credits will be granted. 

“(b) ASSURANCE OF RECEIPT OF CREDITS. – As a condition for making a 

grant for a project described in section 47102(3)(F), 47102(3)(K), 47102(3)(L), or 

47140 or as a condition for granting approval to collect or use a passenger facility 

fee for a project described in section 40117(a)(3)(G), 47102(3)(K), 47102(3)(L), 

or 47140, the Secretary must receive assurance from the State in which the project 

is located, or from the administrator of the Environmental Protection Agency 

where there is a Federal implementation plan, that the airport sponsor will receive 

appropriate emission credits in accordance with the conditions of this section. 

“(c) PREVIOUSLY APPROVED PROJECTS. – The Administrator of the 

Environmental Protection Agency, in consultation with the Secretary, shall 

determine how to provide appropriate emissions credits to airport projects 

previously approved under section 47136 consistent with the guidance and 

conditions specified in subsection (a). 

“(d) STATE AUTHORITY UNDER CAA. – Nothing in this section shall be 

construed as overriding existing State law or regulation pursuant to section 116 of 

the Clean Air Act (42 U.S.C. 7416).”. 

(b) CONFORMING AMENDMENT. – The analysis for chapter 471 is further 

amended by inserting after the item relating to section 47138 the following: 

“47139. Emission credits for air quality projects.”. 

FAA VALE Program Technical Report Page B-3 Version 7
SEC. 159. LOW-EMISSION AIRPORT VEHICLES AND INFRASTRUCTURE. 

(a) AIRPORT GROUND SUPPORT EQUIPMENT EMISSIONS RETROFIT PILOT PROGRAM. – 

(1) IN GENERAL. – Subchapter I of chapter 471 is further amended by adding at 

the end the following: 

“§ 47140. Airport ground support equipment emissions retrofit pilot 

program 

“(a) IN GENERAL. – The Secretary of Transportation shall carry out a pilot 

program at not more than 10 commercial service airports under which the 

sponsors of such airports may use an amount made available under section 48103 

to retrofit existing eligible airport ground support equipment that burns 

conventional fuels to achieve lower emissions utilizing emission control 

technologies certified or verified by the Environmental Protection Agency. 

“(b) LOCATION IN AIR QUALITY NONATTAINMENT OR MAINTENANCE AREAS. – A 

commercial service airport shall be eligible for participation in the pilot program 

only if the airport is located in an air quality nonattainment area (as defined in 

section 171(2) of the Clean Air Act (42 U.S.C. 7501(2))) or a maintenance area 

referred to in section 175A of such Act (42 U.S.C. 7505a). 

“(c) SELECTION CRITERIA. – In selecting from among applicants for participation 

in the pilot program, the Secretary shall give priority consideration to applicants 

that will achieve the greatest air quality benefits measured by the amount of 

emissions reduced per dollar of funds expended under the pilot program. 

“(d) MAXIMUM AMOUNT. – Not more than $500,000 may be expended under the 

pilot program at any single commercial service airport. 

“(e) GUIDELINES. – The Secretary, in consultation with the Administrator of the 

Environmental Protection Agency, shall establish guidelines regarding the types 

of retrofit projects eligible under the pilot program by considering remaining 

equipment useful life, amount of emission reduction in relation to the cost of 

projects, and other factors necessary to carry out this section. The Secretary may 

give priority to ground support equipment owned by the airport and used for 

airport purposes. 

“(f) ELIGIBLE EQUIPMENT DEFINED. – In this section, the term ‘eligible 

equipment’ means ground service or maintenance equipment that is located at the 

airport, is used to support aeronautical and related activities at the airport, and will 

remain in operation at the airport for the life or useful life of the equipment, 

whichever is earlier.”. 

(2) CONFORMING AMENDMENT. – The analysis for chapter 471 is further 

amended by inserting after the item relating to section 47139 the following: 

FAA VALE Program Technical Report Page B-4 Version 7
“47140. Airport ground support equipment emissions retrofit pilot 

program.”. 

(b) ACTIVITIES ADDED TO DEFINITION OF AIRPORT DEVELOPMENT. – 

(1) IN GENERAL. – Section 47102(3) is amended – 

(A) by striking subparagraphs (J), (K), and (L) and redesignating 

subparagraph (M) as subparagraph (J); and 

(B) by adding at the end the following: 

“(K) work necessary to construct or modify airport facilities to 

provide low-emission fuel systems, gate electrification, and other 

related air quality improvements at a commercial service airport 

if the airport is located in an air quality nonattainment or 

maintenance area (as defined in sections 171(2) and 175A of the 

Clean Air Act (42 U.S.C. 7501(2); 7505a) and if such project 

will result in an airport receiving appropriate emission credits, as 

described in section 47139. 

“(L) a project for the acquisition or conversion of vehicles and 

ground support equipment, owned by a commercial service 

airport, to low-emission technology, if the airport is located in a 

air quality nonattainment or maintenance area (as defined in 

sections 171(2) and 175A of the Clean Air Act (42 U.S.C. 

7501(2) ; 7505a) and if such project will result in an airport 

receiving appropriate emission credits as described in section 

47139.”. 

(2) GUIDANCE. – 

(A) ELIGIBLE LOW-EMISSION MODIFICATIONS AND IMPROVEMENTS. – The 

Secretary of Transportation, in consultation with the Administrator of 

the Environmental Protection Agency, shall issue guidance describing 

eligible low-emission modifications and improvements, and stating how 

airport sponsors will demonstrate benefits, under section 47102(3)(K) of 

title 49, United States Code, as added by this subsection. 

(B) ELIGIBLE LOW-EMISSION VEHICLE TECHNOLOGY. – The Secretary, in 

consultation with the Administrator, shall issue guidance describing 

eligible low-emission vehicle technology, and stating how airport 

sponsors will demonstrate benefits, under section 47102(3)(L) of title 

49, United States Code, as added by this subsection. 

FAA VALE Program Technical Report Page B-5 Version 7
FAA VALE Program Technical Report Page B-6 Version 7

(c) ALLOWABLE PROJECT COST. – Section 47110(b) is amended – 

(1) by striking “and” at the end of paragraph (4); 

(2) by striking the period at the end of paragraph (5) and inserting “; and”; and 

(3) by adding at the end the following: 

“(6) if the cost is for a project not described in section 47102(3) for acquiring for 

use at a commercial service airport vehicles and ground support equipment owned 

by an airport that include low-emission technology, but only to the extent of the 

incremental cost of equipping such vehicles or equipment with low-emission 

technology, as determined by the Secretary.”. 

(d) LOW-EMISSION TECHNOLOGY EQUIPMENT. – Section 47102 (as amended by section 

801 of this Act) is further amended by inserting after paragraph (10) the following: 

“(11) ‘low-emission technology’ means technology for vehicles and equipment 

whose emission performance is the best achievable under emission standards 

established by the Environmental Protection Agency and that relies exclusively on 

alternative fuels that are substantially nonpetroleum based, as defined by the 

Department of Energy, but not excluding hybrid systems or natural gas powered 

vehicles.”. 
APPENDIX C 

SPECIAL CONDITIONS FOR AIP GRANTS 

AND PFC APPROVALS

The following language should be inserted as “special conditions” in all AIP grant 

agreements and as a part of the determination paragraph or acknowledgement letter in 

PFC approvals for this program. 

1. “Vehicles and equipment purchased with assistance from this [grant/approval] 

shall be maintained and used for their useful life at the airport for which they were 

purchased. Moreover, any vehicles or equipment replaced under this program 

shall not be transferred to another airport or location within the same or any other 

nonattainment or maintenance area. No airport-owned vehicles or equipment may 

be transferred to, taken to, or used at another airport without the consent of the 

Federal Aviation Administration, in consultation with the U.S. Environmental 

Protection Agency and State air quality agency.” 

 “In the event that funds from this approval are used to assist parties other than the 

[airport sponsor /public agency], the [airport sponsor/public agency] shall 

establish enforceable agreements with the purchasing or leasing party. These 

signed agreements, provided to the Federal Aviation Administration prior to 

project approval, shall require all vehicles and equipment to remain at the airport 

for their useful life in accordance with the program and leasing requirements 

specified in the VALE Technical Report.” 

2. “All vehicles and equipment purchased with assistance from this action shall be 

clearly labeled using the VALE program emblem designed and specified by the 

Federal Aviation Administration.” 

3. “The [airport sponsor/public agency] shall maintain annual reporting records of 

all vehicles and equipment purchased with assistance from this action. These 

public records shall contain detailed information involving individual vehicles 

and equipment, project expenditures, cost effectiveness, and emission reductions.” 

4. “The [airport sponsor/public agency] certifies that it shall replace any disabled or 

seriously damaged vehicle or equipment purchased with assistance from this 

action, at any time during its useful life, with an equivalent vehicle or unit that 

produces an equal or lower level of emissions. The [airport sponsor/public 

agency] assumes all financial responsibility for replacement costs. 

The [airport sponsor/public agency] also certifies that it shall fulfill this 

replacement obligation, beyond the useful life of the affected vehicle or 

FAA VALE Program Technical Report Page C-1 Version 7
FAA VALE Program Technical Report Page C-2 Version 7

equipment, if the [airport sponsor/public agency] has opted for an extended period 

of AERCs in its project application or subsequently.”
APPENDIX D 

PROJECT APPLICATION WORKSHEETS

For use in project applications, the application workbook contains six worksheets 

(spreadsheets) that are intended to standardize project applications, to automate the 

process for more convenience and quality control, and to simplify the process for 

sponsors and reviewing agencies alike. The worksheets are required with the submittal of 

each VALE project application to the FAA and State air quality agency. The most 

current version of the worksheets must be used. 

The FAA prefers the electronic use of the program application worksheets. Electronic 

versions of these worksheets can be downloaded at: http://www.faa.gov/

airports/environmental/vale. Sponsors should copy worksheets for vehicles (Page 2) and 

infrastructure (Page 3) as many times as needed to represent the total number of project 

vehicles and all elements of the project infrastructure. 

 

Below are page-by-page instructions for completing the worksheets as part of the overall 

project application. CAUTION: The workbook contains equations embedded into some 

cells of the worksheets. These equations automatically calculate parameters and 

determine the distribution of requested funds from available sources. The workbook 

requires careful use because it is not locked or secure. 

Page 1 – General Information

The sponsor fills out this general information page with contact information, airport 

characteristics, the status of air quality at the airport, and the timeframe for emission 

reduction calculations and AERCs. The Air Quality Proposal Date should be entered 

into cell L7, and it will automatically repeat at the top of each subsequent page in the 

workbook. 

Page 1 also includes the “AERC Option”, which the sponsor may choose if they want to 

obtain AERCs for up to 20 years and are willing to replace VALE-funded vehicles and 

equipment over that period of time. If this option is selected, place an “X” in cell F29 of 

Page 1. 

Page 2 and Page 3 – Individual Vehicle Information

Sponsors seeking to purchase low-emission vehicles should complete the Page 2 

worksheet(s) for AIP funding and the Page 3 worksheet(s) for PFC funding. Both AIP 

and PFC vehicle worksheets are designed to accommodate only one vehicle type per 

page. Therefore, additional copies of Page 2 and Page 3 are required for applications that 

FAA VALE Program Technical Report Page D-1 Version 7
involve the purchase of multiple vehicle types. For instance, a VALE program that is 

seeking AIP funds to purchase 20 identical CNG-powered buses, 30 identical hybrid 

LDVs, and 10 identical electric fork lifts would need to complete Page 2 three separate 

times. 

Completion of all eight sections on Page 2 and/or Page 3 is mandatory. 

Vehicle Identification – Provide the anticipated date (mm-yyyy) of deployment 

for new vehicles, which should coincide with schedule information provided in 

the air quality proposal. In addition, the vehicle owner, model, model year, and 

manufacturer are required. 

Vehicle Class – Check boxes to indicate if the new vehicle(s) is GSE or GAV. 

This information determines the technique used for emissions quantification. In 

general, any vehicle with a registered license plate to travel on-road is GAV. For 

instance, a catering truck typically found on the airfield supplying aircraft with 

provisions is usually GSE. However, many catering trucks travel on public 

roadways to get to/from the flight kitchen. This requires license plates and, in 

turn, an on-road engine. In this case, the catering truck would be considered an 

on-road vehicle and the GAV box should be checked. Other possible transitional 

vehicles are fuel trucks and deicer trucks. 

Alternative Fuel Type – Place an “X” next to the alternative fuel that is being used 

for the proposed vehicle type. 

Replacement Conventional Fuel Type – Place an “X” next to the conventional fuel 

that is being replaced or displaced, and used for the quantification of baseline 

emissions. 

Unit Cost Per Vehicle – Provide the unit cost and useful life information for the 

proposed low-emission vehicle(s). Vehicle useful life estimates are provided in 

Chapter 4 of this Technical Report. If Chapter 4 does not provide an estimate for 

a particular project vehicle type, and no documentation is available from the 

manufacturer, then use a default value of 10 years. The vehicle base cost is the 

purchase price of the same or equivalent new conventional fuel vehicle. The 

incremental cost is the difference in total purchase price between the proposed 

VALE low-emission vehicle and the same or equivalent new conventional fuel 

vehicle. Finally, on Page 2 only, place a “Y” in the box if PFCs will be used as 

the required local match for AIP funding, or place an “N” in the box if other local 

revenue sources are used as the AIP match. 

Airport Vehicle Type – Place the number of proposed VALE vehicles in the 

appropriate box next to the listed vehicle type. If a particular vehicle type is not 

available, use the “Other” line (Page 2 cell Q26; Page 3 cell Q27) to provide a 

descriptive label of the proposed vehicle type. As a reminder, there should be 

only one proposed VALE vehicle type identified in this section. For projects that 

FAA VALE Program Technical Report Page D-2 Version 7
propose multiple vehicle types, Page 2 (AIP) and Page 3 (PFC) must be repeated 

for each unique vehicle type. 

Replacement of Old Vehicles – If funds are being used to purchase new vehicles 

that will replace/retire existing old vehicles, then supply information about the 

existing older vehicle(s) in this section. Such information should include: make, 

model, unique airport vehicle identification number, model year, horsepower size 

of the engine, average miles per year or hours per year vehicle usage, the method 

of disposal of the old vehicle, and the remaining useful life (RUL) of the vehicle 

at the time of anticipated retirement. 

Summary – The worksheet will automatically summarize the financial project 

costs and grant cost share for the unique VALE vehicle type. Failure to provide 

complete information in the prior sections will result in an inaccurate automated 

summary. 

Page 4 – VALE Infrastructure Summary Sheet

Sponsors should complete this worksheet if the project proposal involves low-emission 

infrastructure. 

 

Begin entry to this worksheet by entering the “Total Cost” of the infrastructure item in 

the last column. Depending on the size of the airport, the worksheet will then 

automatically enter values for “AIP Funding” and “Required Local Matching Funds”. 

These values may need to be modified for a few selected airports (see AIP Handbook, 

5100.38C Appendix 23). Next, enter any direct PFC funding used for the project. Direct 

PFC funding does not include PFC funding used for “Required Local Matching Funds”. 

Finally, add any “Additional Matching Funds” used for the AIP-eligible portion of the 

project. Other column information includes: 

Description – Provide a brief description of the individual low-emission 

infrastructure projects. If possible, provide important size parameters, major 

components, fuel types, and other information that matches the description in the 

air quality proposal. 

Start-up Date – Provide the anticipated time for the infrastructure project to 

become fully functional. The dates should be in the format of (mm-yyyy) and 

coincide with the project schedule provided in the air quality proposal. 

Estimated Operating Life – Provide the estimate operating (useful) life in years 

for each low-emission infrastructure project proposed. 

Number of Units – Provide the number of identical or similar equipment. 

Use of PFCs for matching funds (Y/N) – Indicate if this is true (Y) or not (N). 

FAA VALE Program Technical Report Page D-3 Version 7
FAA VALE Program Technical Report Page D-4 Version 7

Page 5 – Project Funding Summary Sheet

This worksheet summarizes the total low-emissions project costs by AIP, PFC, and other 

airport funds. Each cell in this worksheet is automatically populated per the entries of 

Pages 1 through 4. 

AIP Requested Funding for Vehicles should be the sum of cell Q35 for each Page 

2 worksheet used in the project application. 

AIP Requested Funding for Infrastructure should be the sum of cell G18 for each 

Page 4 worksheet used in the project application. 

PFC Requested Funding for Vehicles should be the sum of cell Q36 for each Page 

2 worksheet and cell Q39 for each Page 3 worksheet used in the project 

application. 

PFC Requested Funding for Infrastructure should be the sum of cell H18 for each 

Page 4 worksheet used in the project application. 

Other Local Funds for Vehicles should be the sum of cell Q37 for each Page 2 

worksheet used in the project application. 

Other Local Funds for Infrastructure should be the sum of cell I18 for each Page 

4 worksheet used in the project application. 

Page 6 – Project Cost Effectiveness Summary Sheet

This worksheet summarizes the total cost effectiveness of the proposed VALE project. 

The sponsor should enter the cumulative emission reductions for the total project lifetime 

indicated on Page 1, as calculated in the EDMS analysis. The cost effectiveness will 

automatically appear per pollutant. 
FAA Voluntary Airport Low Emission Program

PAGE 1. GENERAL INFORMATION

Airport Name: 3-Letter Airport ID: 

Contact Person: Air Quality Proposal Date: 

Mailing Address: Phone: 

Email Address: Fax: 

What is the air quality status of the region?

(Place an "X" for all designations that apply) Large Medium Small Non-hub

Ozone (O3) Nonattainment

8-hour standard Maintenance 1/ Per the criteria in FAA Order 5100.38B and subsequent updates.

Particulate Matter (PM) AERC Option on Project LifePM10 Nonattainment

Maintenance

PM2.5 Nonattainment

Maintenance

Carbon Monoxide (CO) Nonattainment

Maintenance

(Check for AERC Option)

Nitrogen Dioxide (NO2) Nonattainment

Maintenance

(Check below if AERC Option above does not include all project vehicles an

Sulfur Dioxide (SO2) Nonattainment

Maintenance

AERC Option applies only to some VALE-funded vehicles detailed explanation)AERC Option: Sponsor commits to replacing VALE-fundwith equivalent or cleaner low-emission technology.

Hub Designation (place "X" in one)1

AERC Option: The sponsor may obtain AERCs up to 20 year

equipment with shorter useful lives. The AERC Option requirthat includes the VALE-funded years plus the additional option evaluation of project cost effectiveness does not include emisextra AERC Option years.)

FAA VALE Program Technical Report Page D-5 
Anticipated Ground Support Equipment (GSE) Electric Diesel

Vehicle(s) Deployment Date: (nonroad & unlicensed) CNG (compressed natural gas) Gasolin

LNG (liquified natural gas)

Owner: LPG (liquified petroleum gas/propane) Other

Ground Access Vehicle (GAV) Hybrid Technology(licensed for onroad use) Hydrogen (Fuel Cell)

Model and Model Year: Ethanol 85

Methanol 85Coal-derived liquid fuels

Manufacturer: Biodiesel (100%)

Other ____________________ 

Avg. Useful Life (years):2 Air Conditioning Unit Fuel Truck Passeng

Vehicle Base Cost ($):3 Baggage Tug Generator PassengIncremental Cost ($):4 Belt Loader Ground Power Unit Service 

Cargo Loader Fire Truck Pickup T

AIP Funding Share per Cargo Tractor Lavatory Truck 22' Shut

Vehicle/Incremental Cost: Catering Truck Pushback Tractor 30-35' B

Matching Funds Required: Deicer Truck Sweeper 40' Bus

Use PFCs for matching funds (Y/N)? Fork Lift Sport Utility Vehicle (SUV) Other _

Make/Model/Vehicle ID Model Year Hp Method of Disposal of old vehicle

1 Total Number of Proposed Vehicles:23456 Total Request for AIP Funding Share:7 Total PFC Matching Funds Requested: +8 Total Other Matching Funds: +9 Total Incremental Cost: =

1/ Multiple vehicles can be listed only if they're IDENTICAL vehicle types (i.e., same model, year etc.) Otherwise, a separate vehicle information sheet (this page) must be prepared.2/ Refer to Table 4-1 in the VALE program Technical Report.3/ "Vehicle Base Cost" is the purchase price of the same or equivalent new conventional-fuel (gas/diesel) vehicle. This is not eligible for AIP funding, except for emergency and safety vehicles (FAA Order 5100.34/ The "Incremental Cost" is the difference in total purchase price between the proposed VALE vehicle and the same, or closely similar, new conventionally fueled (gas/diesel) vehicle (Base Cost).5/ RUL = Remaining Useful Life (see Technical Report, Chapter 4).

Repeat this page as needed for each proposed vehicle type.

Avg. miles/year 

or hours/year

Summary

Airport Vehicle Type

(place number of proposed vehicles in box next to type - choose only one vehicle type per work

PAGE 2. AIP-funded - INDIVIDUAL VEHICLE INFORMATION

(Repeat the completion of this sheet for each VALE vehicle type to be acquired using AIP funds)1

Vehicle Class

(check one)

Alternative Fuel Type

(check one)

Rep

Conventio

(che

Vehicle Identification

Air Quality Proposal Date: 

If proposed VALE program includes the replacement of old vehicles, 

provide old vehicle info below:

RUL5

(yr)

Unit Cost Per Vehicle

FAA VALE Program Technical Report Page D-6 
Anticipated Ground Support Equipment (GSE) Electric Diesel

Vehicle(s) Deployment Date: nonroad, unlicensed CNG (compressed natural gas) Gasoline

LNG (liquified natural gas)

Owner: LPG (liquified petroleum gas/propane) Other

Ground Access Vehicle (GAV) Hybrid Technologylicensed for onroad use Hydrogen (Fuel Cell)

Model and Model Year: Ethanol 85

Methanol 85Coal-derived liquid fuelsBiodiesel (100%)

Manufacturer: Retrofit/Rebuild

Other ____________________ 

Avg. Useful Life (years):2 Air Conditioning Unit Fuel Truck Passenge

Vehicle Base Cost ($):3 Baggage Tug Generator Passenge

Incremental Cost ($):4 Belt Loader Ground Power Unit Service V

Cargo Loader Fire Truck Pickup Tr

Cargo Tractor Lavatory Truck 22' Shuttl

Catering Truck Pushback Tractor 30-35' Bu

Incremental Funding/Vehicle: Deicer Truck Sweeper 40' Bus

Fork Lift Sport Utility Vehicle (SUV) Other __

Make/Model/Vehicle ID Model Year Hp Method of Disposal of old vehicle

1 Total Number of Proposed Vehicles:23456789 Total Requested PFC Funding for Incremental Cost:

1/ Multiple vehicles can be listed only if they're IDENTICAL vehicle types (i.e., same model, year etc.) Otherwise, a separate vehicle information sheet (this page) must be prepared.2/ Refer to Table 4-1 in the VALE program Technical Report.3/ "Vehicle Base Cost" is the purchase price of the same or equivalent new conventional-fuel (gas/diesel) vehicle. This is not eligible for AIP funding, except for emergency and safety vehicles (FAA Order 5100.384/ The "Incremental Cost" is the difference in total purchase price between the proposed VALE vehicle and the same, or closely similar, new conventionally fueled (gas/diesel) vehicle (Base Cost).5/ RUL = Remaining Useful Life (see Technical Report, Chapter 4).

Repeat this page as needed for each proposed vehicle type.

Unit Cost Per Vehicle Airport Vehicle Type (place number of proposed vehicles in box next to type - choose only one vehicle type per works

Summary

Avg. miles/year 

or hours/year

RUL5

(yr)

PAGE 3. PFC-funded - INDIVIDUAL VEHICLE INFORMATION

(Repeat the completion of this sheet for each VALE vehicle type to be acquired using PFC funds)1

Vehicle Class

(check one)

Alternative Fuel Type

(check one)

Repla

Convention

(chec

Vehicle Identification

Air Quality Proposal Date: 

If proposed VALE program includes the replacement of old vehicles, 

provide old vehicle info below:

FAA VALE Program Technical Report Page D-7 
FAA VALE Program Technical Report Page D-8 
FAA VALE Program Technical Report Page D-9 
FAA VALE Program Technical Report Page D-10 

Pollutant

Projected

Emission Reductions

over Useful Life of Project 

Vehicles and Equipment

(tons)

Cost

Effectiveness

over Useful Life of Project 

Vehicles and Equipment 

($/ton)

NOx

VOC

Ozone

(NOx + VOC)

CO

PM10

PM2.5

SO2

PAGE 6.

PROJECT COST EFFECTIVENESS SUMMARY SHEET

Air Quality Proposal Date: 
APPENDIX E 

PROJECT TRACKING WORKSHEETS

The FAA recommends that sponsors use the following worksheets to meet their 

project tracking requirements. The FAA prefers the electronic use of the tracking 

worksheets. Electronic versions of these worksheets can be downloaded at: 

http://www.faa.gov/airports/environmental/vale. 

FAA VALE Program Technical Report Page E-1 Version 7
FAA Voluntary Airport Low Emission 

PAGE 1. TRACKING FORMS - GENERAL 

Airport Name: 3-Letter Airport ID: 

Contact Person: Calendar Year

Mailing Address: Phone: 

Email Address: Fax: 

DESCRIPTION OF TRACKING WORKSHEETSThe FAA provides these VALE project tracking worksheets to help sponsors monitor the emissions performance and cost effectiveness of VALE projects. Following a calendar yeoperations, the sponsor should complete these forms and keep them on file for purposes of updating reports to the State air quality agency for AERCs, facilitating FAA review, and information to the public upon request.PAGE 1 - General InformationThis sheet should be updated as needed to reflect changes in contact information.PAGE 2 - Vehicle TrackingAnnual operational data and maintenance costs should be kept for each VALE-funded vehicle. Copies of PAGE 2 should be made as necessary. The annual emissions should be 

calculated for each VALE-funded vehicle and recorded in the lower right corner. This information, as well as supporting EDMS documentation, will need to be comunicated to the quality agency for AERC issuance and use.PAGE 3 - Infrastructure Tracking

Annual operating data and maintenance costs should be kept for VALE-funded infrastructure.

PAGE 4- Emissions Tracking Worksheet

Total project emissions (vehicles + infrastructure use) should be calculated on an annual basis. Total emissions should be entered into the "project" columns. The baseline emissshould be identical or consistent with what was calculated in the initial project application. Emission reductions (ERs) for each project year are automatically calculated as thedifference between "baseline" and "project." A running cumulative emissions reduction will automatically appear at the top of the page.

FAA VALE Program Technical Report Page E-2 
Calendar Year:

Vehicle Airport Ground Support Equipment (GSE) Electric Unique Airport V

Deployment Date: nonroad, unlicensed CNG (compressed natural gas)

<OR> LNG (liquified natural gas)

Make, Model, & Model Year: Ground Access Vehicle (GAV) LPG (liquefied petroleum gas/propane)

licensed for onroad use Hybrid Technology License Plate (i

Hydrogen (Fuel Cell)

Vehicle Owner: Hp: Ethanol 85

Methanol 85

Vehicle leased to a Tenant (Y/N)? Coal-derived liquid fuels Does ve

Biodiesel (85-100%) required 

VIN or Serial Number: If yes, to whom? Retrofit/Rebuild label affi

Other ____________________ 

Avg. Useful Life (years):1 Air Conditioning Unit Fuel Truck Passeng

Baggage Tug Generator Passeng

Original Vehicle Purchase Price: Belt Loader Ground Power Unit Service 

Cargo Loader Fire Truck Pickup T

Miles traveled: Cargo Tractor Lavatory Truck 22' ShutHours operated: Catering Truck Pushback Tractor 30-35' B

Annual Fuel Use: Deicer Truck Sweeper 40' Bus

Fuel use units: Fork Lift Sport Utility Vehicle (SUV) Other __

Maintenance

Cost ($)

1 An

2 Pollutant (to3 NOx

4 VOC5 CO6 PM107 PM2.58 SOx

$ -

Repeat this page as needed for each VALE vehicle type.

1/ Refer to Tables 7-1 and 8-1 in the VALE program Technical Report.

Annual Vehicle Usage

Maintenance Records Annual Emissions Summary

PAGE 2. INDIVIDUAL VEHICLE INFORMATION

(Repeat the completion of this sheet for each VALE vehicle)

Vehicle Class

Information

Alternative Fuel Type

(check one)

Prog

Infor

Vehicle Identification

For this calendar year, complete all that apply:

Airport Vehicle Type

(choose only one vehicle type per worksheet)

Calculate annual emission based on the operating parameters of 

on this worksheet. Description of Maintenance Service Date

FAA VALE Program Technical Report Page E-3 
Repeat this page as needed. 

FAA VALE Program Technical Report Page E-4 
FAA VALE Program Technical Report Page E-5 

NOx VOC CO PM10 PM2.5 SOx

0.0 0.0 0.0 0.0 0.0 0.0

All values are in tons per yearProject Year #1 Project Year #2 Project Year #3 Project Year #4 Project Year 

Baseline Project ER Baseline Project ER Baseline Project ER Baseline Project ER Baseline P

NOx 0.0 0.0 0.0 0.0 

VOC 0.0 0.0 0.0 0.0 

CO 0.0 0.0 0.0 0.0 

PM10 0.0 0.0 0.0 0.0 

PM2.5 0.0 0.0 0.0 0.0 

SOx 0.0 0.0 0.0 0.0 

Project Year #6 Project Year #7 Project Year #8 Project Year #9 Project Year 

Baseline Project ER Baseline Project ER Baseline Project ER Baseline Project ER Baseline P

NOx 0.0 0.0 0.0 0.0 

VOC 0.0 0.0 0.0 0.0 

CO 0.0 0.0 0.0 0.0 

PM10 0.0 0.0 0.0 0.0 

PM2.5 0.0 0.0 0.0 0.0 

SOx 0.0 0.0 0.0 0.0 

Project Year #11 Project Year #12 Project Year #13 Project Year #14 Project Year 

Baseline Project ER Baseline Project ER Baseline Project ER Baseline Project ER Baseline P

NOx 0.0 0.0 0.0 0.0 

VOC 0.0 0.0 0.0 0.0 

CO 0.0 0.0 0.0 0.0 

PM10 0.0 0.0 0.0 0.0 

PM2.5 0.0 0.0 0.0 0.0 

SOx 0.0 0.0 0.0 0.0 

Project Year #16 Project Year #17 Project Year #18 Project Year #19 Project Year 

Baseline Project ER Baseline Project ER Baseline Project ER Baseline Project ER Baseline P

NOx 0.0 0.0 0.0 0.0 

VOC 0.0 0.0 0.0 0.0 

CO 0.0 0.0 0.0 0.0 

PM10 0.0 0.0 0.0 0.0 

PM2.5 0.0 0.0 0.0 0.0 

SOx 0.0 0.0 0.0 0.0 

PAGE 4. VALE EMISSION REDUCTIONS (ER) TRACKING 

Project Cumulative Emission Reductions Summary
THIS PAGE INTENTIONALLY LEFT BLANK

FAA VALE Program Technical Report Page E-6 Version 7
APPENDIX F 

FAA VALE APPLICATION CHECKLIST

FAA staff in the Regions or Airport District Offices (ADO) will use the following 

checklist to evaluate and review VALE applications for completeness. This checklist 

should be used prior to the FAA receiving the AERC Letter of Assurance from the State 

air quality agency. 

The goal is to have each element of the checklist answered in the affirmative. A 

complete checklist with all positive responses does not guarantee funding approval for 

the VALE application. 

FAA VALE Program Technical Report Page F-1 Version 7
VALE Program Checklist for 

FAA Airports Environmental Specialists 

Airport Name: 3-Letter Airport ID: 

Contact Person: VALE Proposal Date: 

Mailing Address: Phone: 

Email Address: Fax: 

All checklist answers should be “Yes” 

Determine Airport Eligibility Circle One 

1. Is the airport a commercial service airport in the 

National Plan of Integrated Airport Systems (NPIAS)? Yes No 

2. Is the airport located in an EPA-designated 

nonattainment or maintenance area for any criteria 

pollutant? (see airports list on VALE website) 

Yes No 

3. Is the State air quality agency willing to issue airport 

emission reduction credits (AERCs) to the airport for a 

qualified project in accordance with FAA and EPA 

national program guidance? 

Yes No 

Coordinate with Airport Sponsor on Project Planning Circle One 

1. Is the sponsor informed about low-emission technology 

options? Sources of information include other airports 

with VALE projects or experience, local chapters of the 

DOE Clean Cities Program, and vehicle and engine 

manufacturers. 

Yes No 

2. Does the proposed project focus on the “Level 1” 

criteria pollutant(s) causing nonattainment or 

maintenance status? 

Yes No 

3. Is the FAA participating in early meetings between the 

sponsor, the State air quality agency, and the regional 

EPA to discuss project ideas and the use of national 

AERC guidance? 

Yes No 

4. Is the sponsor aware of program application procedures 

for AIP and PFC funding? For instance, a PFC proposal 

is only an “information copy” pending receipt of the 

State’s AERC “Letter of Assurance” to the FAA. 

Yes No 

FAA VALE Program Technical Report Page F-2 Version 7
Review the Sponsor’s Project Application Circle One 

1. Did the sponsor simultaneously submit 2 copies of the 

application each to the FAA, State air quality agency, 

and the EPA? 

Yes No 

2. Is the project application complete, with the following 

elements detailed in the VALE Technical Report (TR)? 

⁭ Main narrative (Sections 1-9) 

⁭ Appendix A: ER Report(s) and project application 

worksheets 

⁭ Appendix B: EDMS inputs, outputs, and analysis 

⁭ Appendix C: Required AERC “Letter of Assurance” 

from State air quality agency (see Appendix G) 

⁭ Appendix D: Additional certification, technical and 

cost information 

⁭ Appendix E: (If applicable) Draft lease agreement or 

tenant letter of assurance for leased (AIP or PFC) or 

tenant-owned vehicles and equipment (PFC only) 

Yes No 

3. Is the latest version of EDMS used in this application to 

estimate emission reductions? Yes No 

4. Does the sponsor agree to the “Special Conditions” of 

the program? (see Chapter 8) Yes No 

Verify General Project Requirements Circle One 

1. Does the proposed use of low-emission technology seem 

to be reasonable technically? Yes No 

2. Are proposed infrastructure improvements located 

within the airport boundary? Yes No 

3. Are proposed vehicles airport-dedicated? Yes No 

4. Are requests for vehicle funding limited to the eligible 

portion of vehicle incremental costs? Yes No 

5. Do estimated levels of vehicle usage seem reasonable? Yes No 

6. Are new project vehicles EPA-certified to program lowemission standards or, if retrofits, EPA-verified? Yes No 

7. Is the project cost effective for “Level 1” pollutants? 

(see Chapter 9) Yes No 

8. Has the FAA received an acceptable AERC “Letter of 

Assurance” from the State air quality agency prior to 

project approval? 

Yes No 

9. Has the project been assessed under NEPA and General 

Conformity? (See Section 1.5). Yes No 

10. Has the sponsor included an acceptable letter of 

assurance or draft lease agreement for any VALE 

vehicles and equipment that are tenant-owned or leased? 

Yes No 

FAA VALE Program Technical Report Page F-3 Version 7
FAA VALE Program Technical Report Page F-4 Version 7

Verify Additional AIP Requirements Circle One 

1. Do all project vehicles and systems operate using 

eligible alternative fuels? (see Chapter 3) Yes No 

2. Are all project vehicles and equipment airport-owned? Yes No 

3. Have competitive bids been completed satisfactorily? Yes No 

4. Have “Buy American” requirements been met? Yes No 

Verify Additional PFC Requirements Circle One 

1. Has the sponsor included a letter of assurance from the 

tenant that VALE special conditions will be met for all 

VALE tenant-owned vehicles and equipment? 

Yes No 

Monitor Project Implementation Circle One 

1. Confirm that AIP grant agreements and/or PFC 

approvals contain the following “Special Conditions” 

for the VALE program (per Appendix C): 

⁭ All vehicles and equipment remain at the airport for 

their useful life. 

⁭ All vehicles and equipment are clearly labeled with 

the VALE logo (sponsor produces labels). 

⁭ An annual record-keeping system is established to 

track all project vehicles and equipment (see 

Appendix E, tracking worksheets). 

⁭ All vehicles and equipment are replaced during their 

useful life with equivalent low-emission systems. 

Yes No 

2. Is the sponsor meeting their schedule of 

vehicle/equipment acquisition and deployment? Yes No 

3. Has the FAA received a copy of the sponsor’s updated 

emission reduction estimates when they are submitted to 

the State air quality agency for issuance of AERCs? 

Yes No 

4. Has the FAA received a copy of the “AERC Statement” 

issued by the State air quality agency to the sponsor? Yes No 

5. Has the sponsor identified airport development projects 

for which it will apply its documented AERCs? Yes No 

6. Has the FAA received a copy of the sponsor’s updated 

project emission reduction estimates at the time of 

AERC use? 

Yes No 
APPENDIX G 

STATE AIR QUALITY AGENCY AERC

LETTER OF ASSURANCE TO THE FAA 

***The following model Letter of Assurance is required by the FAA*** 

Name 

Manager, Airports Division 

Regional Airports Division and Airport District Office, Federal Aviation Administration 

Local Address 

To [Manager Name]: 

The ______________________(Name of State Air Quality Agency hereafter “Agency”) 

has reviewed the application for airport emission reduction credits (AERCs) received 

from the _______________________(Name of Airport Sponsor hereafter “Sponsor”) on 

_____________(date by month, day, year). The [Agency] has determined that the 

proposed low-emission project described in the [Sponsor’s] application meets the 

requirements of the Clean Air Act and is consistent with Vision 100 (P.L. 108-176) as 

implemented by the Federal Aviation Administration (FAA) Voluntary Airport Low 

Emission (VALE) “Technical Report” and associated U.S. Environmental Protection 

Agency (EPA) “Guidance on Airport Emission Reduction Credits for Early Measures 

through Voluntary Airport Low Emission Programs.” 

The preliminary review of the [Sponsor’s] VALE project application indicates that the 

emission reduction estimates are reasonable and accurate. Based on this review, the 

[Agency] accepts [Sponsor’s] application and will make a timely future determination of 

AERCs based solely on VALE and AERC program guidance in relation to general 

conformity and new source review (NSR) regulations. Approved AERCs for general 

conformity will be granted by the [Agency] on a one-to-one basis (project emission 

reductions to AERCs by pollutant), while AERCs for NSR will be granted, if eligible, on 

a similar basis or according to [Agency] NSR regulations and procedures. 

The [Agency] will grant AERCs to the [Sponsor] following FAA project funding and its 

receipt of updated [Sponsor] emission reduction estimates. The AERCs for this project 

may only be used at [Airport Name]. The [Sponsor] is responsible for project tracking 

and record-keeping and for making this information available to the [Agency] and public 

as requested. 

Sincerely, 

Director of the State Air Quality Agency 

FAA VALE Program Technical Report Page G-1 Version 7
FAA VALE Program Technical Report Page G-2 Version 7

cc: VALE Program, Office of Airports, Planning and Environmental Division, APP400, 800 Independence Ave., SW, Washington, DC 20591 

 EPA Region 
APPENDIX H 

SAMPLE STATE AIR QUALITY AGENCY 

AERC STATEMENT WITH SPONSOR 

LETTER OF REQUEST: 

AERC STATEMENT

ISSUED APRIL 28, 2008 

BY

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

TO

HOUSTON AIRPORT SYSTEM

FOR EMISSION REDUCTIONS ACHIEVED THROUGH THE 

VALE PROGRAM AT

GEORGE BUSH INTERCONTINENTAL AIRPORT

FAA VALE Program Technical Report H-1 Version 7
FAA VALE Program Technical Report H-2 Version 7
FAA VALE Program Technical Report H-3 Version 7
FAA VALE Program Technical Report H-4 Version 7
FAA VALE Program Technical Report FAA VALE Program Technical Report H-5 H-5 Version 6 Version 7
FAA VALE Program Technical Report H-6 Version 7
FAA VALE Program Technical Report H-7 Version 7
FAA VALE Program Technical Report H-8 Version 7
FAA VALE Program Technical Report H-9 Version 7
FAA VALE Program Technical Report H-10 Version 7

THIS PAGE INTENTIONALLY LEFT BLANK