“It’s now or never, if we want to limit global warming to 1.5°C (2.7°F); without immediate and deep emissions reductions across all sectors, it will be impossible.”1
– Jim Skea, co-chair of Working Group III of the Intergovernmental Panel on Climate Change
Introduction and summary
The world has a rapidly closing window of time to avoid the most catastrophic effects of climate change. Since 1990, global annual greenhouse gas (GHG) emissions have increased by 50 percent, rising from a little less than 40 gigatons of carbon dioxide equivalent (CO2e) to just under 60 gigatons of CO2e.2 Aviation is responsible for approximately 2.8 percent of global GHG emissions.3
In the United States, aviation accounts for just under 3 percent of total climate emissions.4 In 2019, prior to the onset of the COVID-19 pandemic, U.S. air carriers burned 12.2 billion gallons of aviation fuel on domestic flights.5 To put that number in perspective, it’s roughly equivalent to 18,460 Olympic swimming pools worth of fuel.6 As these facts illustrate, finding sustainable aviation fuels to replace petroleum-based products is both a huge challenge and an urgent need.
Often overlooked in the aviation decarbonization policy discussion is the role that airports must play. Commercial service airports are large landowners and major consumers of energy and water. Achieving economywide net-zero carbon emissions by 2050 will require airports to convert their ground fleets to electric vehicles (EVs); electrify building systems; generate renewable energy on-site; and dramatically improve energy and water efficiency, including through water reuse.
Unfortunately, federal aviation policy remains overwhelmingly focused on expanding airport and air space capacity and reducing system delays. For instance, 49 USC 47101(a)(7) states a main goal of federal airport development policy clearly and forcefully:
that airport construction and improvement projects that increase the capacity of facilities to accommodate passenger and cargo traffic be undertaken to the maximum feasible extent so that safety and efficiency increase and delays decrease.7
Additionally, Subsection 47101 states that airport development projects must “provide for the protection and enhancement of natural resources and the quality of the environment.”8 In practice, federal programs support maintaining and expanding airport capacity with a narrow focus on environmental compliance.
Congress should require commercial service airports to achieve net-zero GHG emissions by midcentury and reward those airports that make aggressive reductions with priority for discretionary grant awards. To accomplish this mandate, Congress should reform two important sources of airport revenue: the Airport Improvement Program (AIP) and the Passenger Facility Charge (PFC) Program. Airports should be allowed to use these revenues to support stand-alone climate change mitigation and adaptation projects as well as environmental sustainability projects more broadly.
Federal policy must push airports to move beyond simply mitigating the harms that stem from traditional construction activities to advancing a comprehensive program of climate mitigation and sustainability that governs capital projects and operations. Reforming the AIP and the PFC Program is a necessary first step.
Airport Improvement Program
Federal grants in support of civil airport development date back to 1946 when President Harry Truman signed the Federal Airport Act, which established the Federal-Aid Airport Program (FAAP).9 In 1970, Congress replaced the FAAP with the Airport Development Aid Program (ADAP) and the Planning Grant Program (PGP).10 Congress replaced and consolidated the ADAP and the PGP when it created the Airport Improvement Program (AIP) with the passage of the Airport and Airway Improvement Act of 1982.11
The handbook for the AIP—which is the largest federal grant program for airport development projects—states that the program is designed to advance “airport planning, airport development, noise compatibility planning, and noise compatibility projects.”12 Again, the program is principally about increasing aviation system capacity and reducing aviation noise.
In 2012, Congress passed the Federal Aviation Administration (FAA) Modernization and Reform Act, which allows airport project sponsors to improve “the energy efficiency of airport power sources” with AIP program funds.13 However, this eligibility comes with a big and unfortunate catch. According to the AIP Handbook:
For building projects, the cost [of an energy efficiency improvement] must be incurred on an otherwise eligible and justified airport building project (improving energy efficiency cannot be the justification). A project to improve a building’s energy efficiency is not eligible as a stand-alone project.14
The prohibition on using AIP funds for stand-alone efficiency projects makes it more difficult for airports to advance sustainability and climate mitigation goals. Airports—even large hubs—can go years or even decades between major reconstruction or expansion projects. Congress should amend the AIP to allow efficiency as a stand-alone project.
Additionally, Congress should amend how the FAA scores AIP projects to prioritize sustainability and climate mitigation, placing it on par with capacity expansion. Currently, every project that an airport sponsor would like to fund with AIP dollars is subject to a scoring formula called the National Priority Rating (NPR). Projects receive points based on four categories: airport size, project purpose, component, and type. Under the first category, airport size, the NPR scores larger airports higher than small and nonhub airports. The second category is project purpose, which includes capacity, safety, reconstruction, and environment, among others. The third category is component, which includes things such as runway, apron, terminal, or ground transportation. The fourth and final category is project type, which includes things such as lighting, snow removal equipment, construction, and mitigation, among others.15
According to the AIP Handbook, the “environment” category under project purpose is principally intended to support compliance with federal environmental statutes. The handbook states: “Environmental projects include studies and resulting actions required to comply with the National Environmental Policy Act (NEPA) and other federal environmental laws, regulations, and initiatives.”16 In other words, similar to the energy efficiency category, environmental projects are mostly those that are an outgrowth of airport capital projects as opposed to a stand-alone category. For instance, an airport could decide to construct a new runway or terminal building that involves the infill of wetlands on airport grounds. Under the Clean Water Act, the airport project sponsor would need to obtain a Section 404 permit, which would involve a commitment to carry out mitigation measures intended to offset the loss of wetlands. These mitigation efforts would be an eligible project expense under the AIP.
There are two exceptions to this overall approach to environmental projects: the Voluntary Airport Low Emissions Program (VALE) and the Airport Zero Emissions Vehicle and Infrastructure Pilot Program (ZEV). Created by Congress in 2004 through the Vision 100—Century of Aviation Reauthorization Act, VALE enables airports to use either AIP or PFC Program funds to undertake sustainability planning and to “finance low emission vehicles, refueling and recharging stations, gate electrification, and other airport air quality improvements.”17 Eligible VALE projects include everything from replacing conventionally fueled vehicles such as baggage loaders, bag tugs, and airplane pushback tractors to stationary geothermal or solar thermal systems. Airports must apply to the FAA to implement VALE projects, and project funds are a mixture of AIP discretionary and entitlement funding. The program is limited to airports located in nonattainment and maintenance areas under the National Ambient Air Quality Standards (NAAQS) as defined by the Clean Air Act.18
The benefits of building electrification
According to the Rocky Mountain Institute, approximately 70 million homes and businesses “burn natural gas, oil, or propane on site to heat their space and water.”19 The residential and commercial sectors, excluding agriculture and industrial activities, represent 13 percent of annual U.S. GHG emissions.20 The U.S. Environmental Protection Agency (EPA) states that, “Emissions from natural gas consumption represent 79% of the direct fossil fuel CO2 emissions from the residential and commercial sectors in 2020.”21
Rapidly electrifying all building systems—even when the electricity a building receives from the power grid is not yet decarbonized—is an essential component of reaching net-zero GHG emissions by midcentury. Electrical building systems—especially heat pumps—are more efficient than their fossil fuel counterparts.22 And as Columbia University professor Vijay Modi states, “It is much easier and affordable to make electricity green than to make a green fuel.”23
For instance, the FAA awarded a VALE grant to Louisville Muhammad Ali International Airport for a major geothermal project for heating and cooling of the Abramson Terminal building that involves drilling 648 vertical geothermal wells, each 500 feet deep, to facilitate thermal exchange. The geothermal system will be 40 percent more efficient than the systems it is replacing and is expected to cut carbon emissions by roughly 80 percent “through the reduction of pollutants such as ozone, carbon monoxide and particulate matter associated with the burning of natural gas.”24 Clean energy projects such as the one at Louisville International need to become the standard nationally.
The ZEV program, which Congress created through the FAA Air Transportation Modernization and Safety Improvement Act of 2012, allows airports to use AIP funds to “purchase ZEVs and to construct or modify infrastructure needed to use ZEVs.”25 FAA states that, “Airports in EPA-designated nonattainment areas are given first priority for consideration. Airports in EPA-designated maintenance areas will only be considered after all proposals from nonattainment areas are considered for funding.”26
Both the VALE and ZEV programs represent a congressional attempt to layer air quality and climate into a federal aviation policy structure that was not initially designed with either goal in mind. Yet these programs suffer from inadequate scale. According to FAA data, VALE program projects received $278 million in AIP funding—both discretionary and entitlement dollars—from fiscal year 2005 to fiscal year 2021.27 During the same period, the FAA provided airports with a total of $58 billion in AIP funds.28 The VALE program represented just 0.4 percent of AIP outlays during these years.29 The ZEV program has provided $47.6 million in AIP funding to date, representing an even smaller percentage of total AIP outlays.30
AIP funds should be eligible for use in the implementation of stand-alone climate mitigation, adaptation, and other sustainability projects. Beyond construction activities, airports generate significant environmental impacts. They should be free to use AIP funds for projects that would generate substantial climate and sustainability benefits without first being required to find a connection to capital construction or other expansion or modernization efforts.
Passenger Facility Charge Program
In 1990, Congress passed the Aviation Safety and Capacity Expansion Act, which authorized the PFC Program. The PFC is a charge levied by an airport on enplaning passengers. In its current form, an airport may only use PFC revenues for projects that: “(1) Preserve or enhance safety, security, or capacity of the national air transportation system; (2) Reduce noise or mitigate noise impacts resulting from an airport; or (3) Furnish opportunities for enhanced competition between or among air carriers.”31 Congress should reform the PFC Program to allow airport project sponsors to undertake stand-alone climate mitigation and other sustainability projects, regardless of their effect on safety, security, capacity, competition, or noise.
In its current form, an airport project sponsor may use PFC revenues for building systems that are part of a capital project that would expand air service. Again, the focus is on system capacity. Specifically, under 49 U.S.C 40117(a)(3)(F), a project for constructing gates and related areas may include “walls, windows, door and roof systems, building utilities (including heating, air conditioning, ventilation, plumbing, and electrical service),” provided that the project is required “to enable additional air service by an air carrier with less than 50 percent of the annual passenger boardings at an airport.”32
According to research by the RAND Corporation, “one of the goals of Congress in establishing the PFC Program was to make resources available to airports that could be used to enhance airline competition (e.g., by expanding terminals and offering gate slots to new entrants).”33 Expanding aviation competition is an important national policy goal that should be retained. Yet since the program’s original authorization in 1990, the need to address the climate crisis has grown to urgent proportions. Therefore, the PFC Program should be expanded to cover climate mitigation, adaptation, and other sustainability projects to advance the dual mandate of economic growth while also ensuring that the United States meets its global climate commitments.
To ensure that airports have the revenue necessary to implement comprehensive climate mitigation, adaptation, and other sustainability projects, Congress should increase the maximum allowable PFC charge from $4.50 to $8.00 per enplaning passenger, limited to the first two flight segments.34
Energy performance standards
The next step to achieving net-zero GHG emissions is for Congress to establish an airport performance management framework. Under such a framework, any airport receiving AIP funds would need to conduct an energy- and water-use audit to set a performance baseline. Each airport would then need to develop a plan for achieving net-zero emissions by 2050 with accelerating reductions in the years leading up to midcentury. The net-zero standard would apply to all Scope 1 and Scope 2 emissions as defined by the EPA. According to the EPA, Scope 1 emissions are “direct greenhouse (GHG) emissions that occur from sources that are controlled or owned by an organization (e.g., emissions associated with fuel combustion in boilers, furnaces, vehicles).”35 Scope 2 emissions are “indirect GHG emissions associated with the purchase of electricity, steam, heat, or cooling.”36 While Scope 2 emissions happen elsewhere, they are consumed by the airport in the course of its operations.
Importantly, the net-zero GHG performance framework would help guide both airport capital planning and operations. At a national level, the FAA could factor in an airport’s rate of progress on achieving net-zero GHG emissions when scoring applications for discretionary AIP funds. Additionally, Congress should authorize the FAA to require airports to set aside a certain minimum percentage of PFC funds—or bond proceeds to be repaid with future PFC revenues—for climate mitigation projects should an airport fail to make adequate progress on its GHG targets.
Renewable energy generation
Airports typically own large amounts of land and have substantial terminal and other support structures that could serve as foundations for renewable energy generation and energy storage.
Dulles International Airport (IAD) is an example of the potential for renewable energy generation on airport grounds. The airport sits on 11,150 acres of land and includes more than 1 million square feet of terminal space, serving 42 commercial airlines and 37 cargo airlines as of 2020.37 Additionally, two fixed-base operators serve general aviation customers. In 2019, Dulles consumed 221 kilowatt-hours of electricity and 3,720,000 therms of natural gas, which is equal to 372 million cubic feet of gas.38
The Metropolitan Washington Airports Authority (MWAA), which controls IAD, is moving forward with a plan to sublease roughly 800 acres of land to Dominion Energy for development as a utility-scale solar photovoltaic facility.39 The proposed installation would consist of 350,000 to 400,000 solar modules. The 100-megawatt installation is expected to generate more than 200,000 megawatt-hours of energy each year.40 The installation would feed power to the grid, delivering renewable energy to Dominion customers, including IAD.
In 2020, the Virginia state legislature passed the Virginia Clean Economy Act, which requires power producers such as Dominion Energy to achieve 100 percent renewable energy production by 2050.41 In response, Dominion Energy began looking for available locations to site renewable production. The airport offered an attractive location given its large footprint and its proximity to load centers, which includes IAD and other commercial businesses such as data centers. According to the environmental assessment produced by the MWAA, “Production of electricity near high demand centers is needed to support a stable and reliable electrical grid in northern Virginia.”42
In 2020, the MWAA released a sustainability plan focused on six goals: 1) to reduce its fuel use by electrifying its transportation systems; (2) to increase the efficiency of its built environment; 3) to increase the efficiency of its water use; 4) to reduce how much municipal solid waste it generates and sends to landfills; 5) to foster a “culture of sustainable administration”; and 6) to ensure public transportation can be used efficiently.43 The plan is an impressive and comprehensive assessment of the opportunities for and challenges in achieving sustainability targets.
As a part of this overarching effort, the MWAA determined that it made sense to make “land not needed for aeronautical uses available for development of infrastructure to produce electricity from renewable energy sources.”44 The MWAA’s choice to leverage idle land will deliver substantial environmental benefits. To put the 100-megawatt installation into perspective, it should generate enough energy to power the equivalent of 18,000 to 20,000 American homes for a year.45
Of course, not every airport has the same amount of nonaeronautical land. For instance, the MWAA also controls Reagan National Airport (DCA) along the Potomac River. The airport has a much tighter footprint and a limited ability to generate renewable energy. A 2020 study commissioned by the MWAA showed that DCA was a strong candidate for a smaller solar installation of around 1.2 megawatts paired with 200 kilowatts of battery storage.46
The solar project moving forward at IAD and the potential for solar and storage at DCA show that every airport has a mix of assets that can be leveraged to achieve climate goals. Yet IAD also shows the challenges remaining to achieve net-zero emissions by midcentury. For instance, ground and service vehicles used by IAD burned 950,000 gallons of fossil fuels in 2019.47 Additionally, buildings and vehicles consumed 372 million cubic feet of gas and 297 million gallons of water—roughly 12 gallons per passenger.48 According to the airport, at current passenger growth rates, IAD will use 446 million gallons of water by 2035 in the absence of efficiency upgrades or water reuse projects.49 The main sources of water use at both airports are “chiller plants, third-party commercial food preparation kitchens, and rental car companies.”50
For airports to rapidly eliminate their emissions, they must measure baseline conditions; set aggressive targets; and prioritize mitigation, adaptation, and sustainability projects. Federal programs such as the AIP and the PFC Program must be modernized to help airports implement aggressive climate actions.
A lot has changed since the AIP and the PFC Program were first authorized in 1982 and 1990, respectively. Decades of climate research have shown that rising GHG levels in the atmosphere pose an existential threat, leaving humanity with a brief window to achieve net-zero emissions. While air carriers search for truly sustainable aviation fuels, airports, which serve as the physical backbone of the U.S. air transportation system, must develop and rapidly implement plans for reducing their own emissions to net zero by midcentury. Ensuring airports achieve these targets will require Congress to modernize both the AIP and the PFC Program to allow—and prioritize—stand-alone mitigation, adaptation, and other sustainability projects. Furthermore, the FAA should prioritize discretionary grant awards to those airports that make rapid progress on decarbonization and efficiency—especially the elimination of all Scope 1 emissions within the shortest time horizon.