Regulatory Alert: FAA Launches Airport Climate Challenge
April 22, 2022
The Federal Aviation Administration (FAA) launched what the agency is calling the Airport Climate Challenge on April 22,t an effort to encourage U.S. airports to reduce greenhouse gas (GHG) emissions with the goal of achieving net-zero emissions by 2050. In an accompanying announcement, FAA emphasized that airports can take advantage of several FAA funding programs to meet this goal, including the Voluntary Airport Low Emissions (VALE) Program and Zero Emissions Vehicle (ZEV) Program, among others. As part of this challenge, FAA has indicated that the agency will make funding available for specific projects that reduce GHG emissions at airports. 
While AAAE supports the aspirational goal of net-zero emissions by 2050 and the specific programs highlighted by FAA as part of the challenge, we opted not to sign on to the press release after concerns arose this week from members that FAA “ as noted in Wednesday's notice of funding opportunity (NOFO) “ could be planning to use fiscal year 2022 (FY22) discretionary grants under the Airport Improvement Program (AIP) to prioritize and fund projects that reduce GHG emissions potentially at the expense of other high priority projects. The establishment of new criteria for project evaluation and the prioritization of projects that are aligned with the goals of a particular Administration “ even worthy and strongly supported goals “ would alter a well-established process on how AIP discretionary funds have been distributed historically and represents a significant change in policy that necessitates public comment and further discussion. We have raised these concerns with FAA leadership, although we have emphasized that we are supportive of encouraging airports to meet net-zero emissions by 2050. 
Over the next few months, FAA will be working to expand and optimize existing environmental programs and direct additional funding opportunities to airports to help them meet the net-zero emissions goal. AAAE has provided some additional information below to help airports understand what this challenge means, especially in light of the various funding programs already available.
What Is the Airport Climate Challenge? According to FAA, the challenge is an initiative to encourage U.S. airports to reduce GHG emissions with the goal of achieving net-zero emissions by 2050. FAA intends to support airports in meeting this challenge by expanding, optimizing, and increasing funding for existing Office of Airports environmental programs. In addition, FAA is developing a tool that will allow airports to estimate, track, and report on the amount of emissions reduction achieved when implementing projects. You can review further details about the challenge in a briefing that FAA published on their website here. 
Why Is the Administration Issuing This Challenge? The challenge is one of several initiatives that the Administration is pursuing after releasing its U.S. Aviation Climate Action Plan last fall, which outlined the federal government's strategy to put the aviation industry on a path toward zero-emissions by 2050. We provided an overview of the U.S. Aviation Climate Action Plan in our November 9 Regulatory Alert. Achieving net-zero emissions, economy-wide, by 2050 was a goal was established by President Biden days after he took office in January 2021, as outlined in Executive Order 14008. 
What Programs Is FAA Trying to Expand or Optimize? FAA is focused specifically on the VALE Program, ZEV Program, and the Airport Sustainability Planning Program in the first instance. However, FAA also has lesser-known authorities through the Deployment of Zero Emissions Technology Program, Energy Efficiency Program, and the Energy Supply, Redundancy, and Microgrids Program to fund projects that, for example, implement energy reduction measures or construct a microgrid. FAA is working to improve these programs so that more airports can take advantage of them. 
How Does FAA Plan to Expand or Optimize Existing Environmental Programs (e.g., VALE, ZEV)? FAA is in the process of reviewing feedback and recommendations that the agency received from industry on how to improve the value of their environmental programs, such as the VALE Program, without congressional action. Earlier this month, FAA hosted a briefing and discussion with AAAE staff and members to discuss these programs and receive input. AAAE is supportive of these programs and has provided recommendations and feedback to FAA on how to optimize them in a manner that could help airports achieve net-zero emissions by 2050. 
What FAA Funding Is Available for Airports to Help Meet the 2050 Net-Zero Emissions Goal? FAA has signaled that the agency will provide FY22 supplemental discretionary grants for specific projects that reduce GHG emissions. In the FY22 omnibus spending bill, which President Biden signed last month to fund the federal government through the current fiscal year, Congress included almost $554.2 million in supplemental discretionary funding for airport development projects (in addition to the normal AIP funding). Of that amount, approximately $279.2 million is reserved for earmarks, which are officially known as “Community Project Funding“ requests. This leaves approximately $275 million available that we believe FAA will use to fund GHG emission-reduction projects through the environmental programs identified above. 
How Can Airports Apply for FY22 Supplemental Discretionary Funding? FAA is expected to issue a NOFO outlining how airports can apply for a share of the supplemental discretionary funding—about $275 million—in the May or June timeframe. The NOFO will also outline with more specificity the types of projects that will be eligible for funding. 
Will Traditional AIP Discretionary Funds Be Available for Projects that Reduce GHG Emissions? In addition to the FY22 supplemental discretionary funds, FAA indicated in a NOFO this week that the agency is seeking to use traditional AIP discretionary grants to fund projects that reduce GHG emissions, as we explained in our April 19 Regulatory Alert. AAAE has raised concerns over prioritizing the use of AIP discretionary grants in this manner potentially at the expense of high priority projects. There is a long-standing process on how FAA issues these grants that is well documented in internal FAA guidance. Reprioritizing which projects are funded through AIP discretionary grants based on criteria tied to the goals of a particular Administration would be a significant policy change that deserves further discussion with the industry. 
The Federal Aviation Administration (FAA) launched what the agency is calling the Airport Climate Challenge on April 22,t an effort to encourage U.S. airports to reduce greenhouse gas (GHG) emissions with the goal of achieving net-zero emissions by 2050. In an accompanying announcement, FAA emphasized that airports can take advantage of several FAA funding programs to meet this goal, including the Voluntary Airport Low Emissions (VALE) Program and Zero Emissions Vehicle (ZEV) Program, among others. As part of this challenge, FAA has indicated that the agency will make funding available for specific projects that reduce GHG emissions at airports. 
While AAAE supports the aspirational goal of net-zero emissions by 2050 and the specific programs highlighted by FAA as part of the challenge, we opted not to sign on to the press release after concerns arose this week from members that FAA “ as noted in Wednesday's notice of funding opportunity (NOFO) “ could be planning to use fiscal year 2022 (FY22) discretionary grants under the Airport Improvement Program (AIP) to prioritize and fund projects that reduce GHG emissions potentially at the expense of other high priority projects. The establishment of new criteria for project evaluation and the prioritization of projects that are aligned with the goals of a particular Administration “ even worthy and strongly supported goals “ would alter a well-established process on how AIP discretionary funds have been distributed historically and represents a significant change in policy that necessitates public comment and further discussion. We have raised these concerns with FAA leadership, although we have emphasized that we are supportive of encouraging airports to meet net-zero emissions by 2050. 
Over the next few months, FAA will be working to expand and optimize existing environmental programs and direct additional funding opportunities to airports to help them meet the net-zero emissions goal. AAAE has provided some additional information below to help airports understand what this challenge means, especially in light of the various funding programs already available.
What Is the Airport Climate Challenge? According to FAA, the challenge is an initiative to encourage U.S. airports to reduce GHG emissions with the goal of achieving net-zero emissions by 2050. FAA intends to support airports in meeting this challenge by expanding, optimizing, and increasing funding for existing Office of Airports environmental programs. In addition, FAA is developing a tool that will allow airports to estimate, track, and report on the amount of emissions reduction achieved when implementing projects. You can review further details about the challenge in a briefing that FAA published on their website here. 
Why Is the Administration Issuing This Challenge? The challenge is one of several initiatives that the Administration is pursuing after releasing its U.S. Aviation Climate Action Plan last fall, which outlined the federal government's strategy to put the aviation industry on a path toward zero-emissions by 2050. We provided an overview of the U.S. Aviation Climate Action Plan in our November 9 Regulatory Alert. Achieving net-zero emissions, economy-wide, by 2050 was a goal was established by President Biden days after he took office in January 2021, as outlined in Executive Order 14008. 
What Programs Is FAA Trying to Expand or Optimize? FAA is focused specifically on the VALE Program, ZEV Program, and the Airport Sustainability Planning Program in the first instance. However, FAA also has lesser-known authorities through the Deployment of Zero Emissions Technology Program, Energy Efficiency Program, and the Energy Supply, Redundancy, and Microgrids Program to fund projects that, for example, implement energy reduction measures or construct a microgrid. FAA is working to improve these programs so that more airports can take advantage of them. 
How Does FAA Plan to Expand or Optimize Existing Environmental Programs (e.g., VALE, ZEV)? FAA is in the process of reviewing feedback and recommendations that the agency received from industry on how to improve the value of their environmental programs, such as the VALE Program, without congressional action. Earlier this month, FAA hosted a briefing and discussion with AAAE staff and members to discuss these programs and receive input. AAAE is supportive of these programs and has provided recommendations and feedback to FAA on how to optimize them in a manner that could help airports achieve net-zero emissions by 2050. 
What FAA Funding Is Available for Airports to Help Meet the 2050 Net-Zero Emissions Goal? FAA has signaled that the agency will provide FY22 supplemental discretionary grants for specific projects that reduce GHG emissions. In the FY22 omnibus spending bill, which President Biden signed last month to fund the federal government through the current fiscal year, Congress included almost $554.2 million in supplemental discretionary funding for airport development projects (in addition to the normal AIP funding). Of that amount, approximately $279.2 million is reserved for earmarks, which are officially known as “Community Project Funding“ requests. This leaves approximately $275 million available that we believe FAA will use to fund GHG emission-reduction projects through the environmental programs identified above. 
How Can Airports Apply for FY22 Supplemental Discretionary Funding? FAA is expected to issue a NOFO outlining how airports can apply for a share of the supplemental discretionary funding—about $275 million—in the May or June timeframe. The NOFO will also outline with more specificity the types of projects that will be eligible for funding. 
Will Traditional AIP Discretionary Funds Be Available for Projects that Reduce GHG Emissions? In addition to the FY22 supplemental discretionary funds, FAA indicated in a NOFO this week that the agency is seeking to use traditional AIP discretionary grants to fund projects that reduce GHG emissions, as we explained in our April 19 Regulatory Alert. AAAE has raised concerns over prioritizing the use of AIP discretionary grants in this manner potentially at the expense of high priority projects. There is a long-standing process on how FAA issues these grants that is well documented in internal FAA guidance. Reprioritizing which projects are funded through AIP discretionary grants based on criteria tied to the goals of a particular Administration would be a significant policy change that deserves further discussion with the industry. 
