Draft EA - San Diego International Airport

SAN DIEGO INTERNATIONAL AIRPORT – PROPOSED RUNWAY 9 DISPLACED THRESHOLD
4.5.2.1 Greenhouse Gases and Climate Change
Greenhouse Gases
Of growing concern is the impact of proposed projects on climate change. Greenhouse gases (GHGs) are
those that trap heat in the earth's atmosphere. Both naturally occurring and anthropogenic (man-made)
GHGs include water vapor (H 2 O), carbon dioxide (CO 2 ), 21 methane (CH 4 ), nitrous oxide (N 2 O), and O 3 . 22
Research has shown that there is a direct link between fuel combustion and GHG emissions. Therefore,
sources that require fuel or power at an airport are the primary sources that would generate GHGs. Aircraft
are probably the most often cited air pollutant source, but they produce the same types of emissions as cars.
Aircraft jet engines, like many other vehicle engines, produce CO 2 , H 2 O, NOx, CO, oxides of sulfur (SOx),
unburned or partially combusted hydrocarbons (also known as VOCs), particulates, and other trace
compounds.
In January 2012, the FAA released a memorandum providing guidance on the consideration and evaluation of
GHGs and climate under NEPA. 23
The guidance supplements FAA Order 1050.1E to identify climate as a
category of potential environmental impact that should be considered in EAs and Environmental Impact
Statements (EISs).
Although there are no federal standards for aviation-related GHG emissions, it is well-established that GHG
emissions can affect climate. 24
The CEQ has indicated that climate should be considered in NEPA analyses. As
noted by CEQ, however, "it is not currently useful for the NEPA analysis to attempt to link specific
climatological changes, or the environmental impacts thereof, to the particular project or emissions, as such
direct linkage is difficult to isolate and to understand." 25
Based on FAA data, operations activity at SDIA represents less than two percent of U.S. aviation activity.
Therefore, assuming that GHGs occur in proportion to the level of activity, GHG emissions associated with
existing and future aviation activity at SDIA would continue to be expected to represent far less than 0.003
percent of U.S.-based GHGs. Since the proposed relocation of the Runway 9 displaced threshold by 300 feet
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All GHG inventories measure carbon dioxide emissions, but beyond carbon dioxide different inventories include different GHGs.
Several classes of halogenated substances that contain fluorine, chlorine, or bromine are also GHGs, but they are, for the most part, solely
a product of industrial activities. For example, chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) are halocarbons that
contain chlorine, while halocarbons that contain bromine are referred to as bromofluorocarbons (i.e., halons) or sulfur (sulfur hexafluoride:
SF6).
U.S. Department of Transportation, Federal Aviation Administration, Order 1050.1E, Change 1, Guidance Memo #3, “Considering
Greenhouse Gases and Climate Under the National Environmental Policy Act (NEPA): Interim Guidance.” To: FAA Lines of Business and
Managers with NEPA Responsibilities. From: Julie Marks, Manager, Environmental Policy and Operations, prepared by Thomas W. Cuddy,
January 12, 2012.
See Massachusetts v. E.P.A., 549 U.S. 497, 508-10, 521-23 (2007).
U.S. Council on Environmental Quality, Draft NEPA Guidance on Consideration of the Effects of Climate Change and Greenhouse Gas
Emissions, http://ceq.hss.doe.gov/nepa/regs/Consideration of Effects_of GHG_Draft_NEPA_Guidance_FINAL_02182010.pdf, 2010.
Environmental Consequences
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Draft EA