SUPPORTING
STATEMENT
SURVEY
OF
AIRPORT
DEICING
OPERATIONS
U.
S.
Environmental
Protection
Agency
Office
of
Water
Office
of
Science
and
Technology
September
2005
ii
TABLE
OF
CONTENTS
Page
PART
A
OF
THE
SUPPORTING
STATEMENT
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1
1.
Identification
of
the
Information
Collection
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1
a.
Title
of
the
Information
Collection
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b.
Short
Characterization/
Abstract
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2.
Need
for
and
Use
of
the
Collection
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a.
Need/
Authority
for
the
Collection
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b.
Practical
Utility/
Users
of
The
Data
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2
i.
General
Use
of
the
Data
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2
ii.
Detailed
Technical
Analyses
Supported
by
Part
A
of
the
Questionnaire
Data
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4
iii.
Detailed
Economic
Analyses
Supported
by
Part
B
of
the
Questionnaire
Data
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3.
Non­
Duplication,
Consultations,
and
Other
Collection
Criteria
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a.
Non­
Duplication
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b.
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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c.
Consultations
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d.
Effects
of
Less
Frequent
Collection
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12
e.
General
Guidelines
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12
f.
Confidentiality
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g.
Sensitive
Questions
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4.
The
Respondents
and
the
Information
Requested
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a.
Respondent
NAICS
Codes
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b.
Information
Requested
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13
i.
Data
Items,
Including
Record
Keeping
Requirements
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ii.
Respondent
Activities
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5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
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a.
Agency
Activities
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b.
Collection
Methodology
and
Management
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c.
Small
Entity
Flexibility
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d.
Collection
Schedule
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6.
Estimating
the
Burden
and
Cost
of
the
Collection
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a.
Estimating
Respondent
Burden
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b.
Estimating
Respondent
Costs
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i.
Estimating
Labor
Costs
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ii.
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs
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iii.
Capital/
Start­
up
Operating
and
Maintenance
Costs
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iv.
Annualizing
Capital
Costs
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c.
Estimating
Agency
Burden
and
Costs
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37
TABLE
OF
CONTENTS
(
Continued)

Page
iii
d.
Estimating
the
Respondent
Universe
and
Total
Burden
Costs
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39
e.
Bottom­
Line
Burden
Hours
and
Cost
Tables
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f.
Reasons
for
Change
in
Burden
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g.
Burden
Statement
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39
PART
B
OF
THE
SUPPORTING
STATEMENT
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41
1.
Questionnaire
Objectives,
Key
Variables,
and
Other
Preliminaries
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a.
Questionnaire
Objectives
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b.
Key
Variables
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41
2.
Sample
Design
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42
a.
Airports
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i.
Sample
Frame
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42
ii.
Sample
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44
b.
Airlines
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i.
Airline
Screener
Questionnaire
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45
ii.
Airline
Detailed
Questionnaire
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c.
Precision
Requirements
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49
i.
Precision
Targets
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49
ii.
Response
Rates
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iii.
Processing
Errors
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50
3.
Pre­
tests
and
Pilot
Tests
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50
4.
Collection
Methods
and
Follow­
up
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51
5.
Analysis
and
Reporting
Questionnaire
Results
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51
a.
Data
Preparation
.
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51
b.
Analysis
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.
51
Appendix
A.
Summary
of
Comments
on
the
Public
Notices
for
the
Proposed
Information
Collection
for
Airport
Deicing
Operations
and
EPA's
Response
.
.
.
.
.
.
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.
53
iv
LIST
OF
TABLES
Page
Table
A.
6­
1.
Estimated
Respondent
Burden
to
Complete
the
Questionnaires
.
.
.
.
.
.
.
.
.
.
.
.
.
34
Table
A.
6­
2.
Estimated
Respondent
Costs
to
Complete
the
Questionnaire
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
36
Table
A.
6­
3.
Estimated
Agency
Burden
and
Labor
Cost
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
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.
.
.
.
.
.
.
38
Table
A.
6­
4.
Estimated
Agency
Total
Cost
(
Labor
and
O&
M)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
38
Table
B.
2­
1.
Airports
Identified
in
Data
Sources
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
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.
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.
.
.
.
.
43
Table
B.
2­
2.
Number
of
Airports
in
Sample
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
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.
.
45
Table
B.
2­
3.
Estimated
Number
of
Airport/
Airline
Combinations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
46
Table
B.
2­
4.
Screener:
Number
of
Airlines
Reporting
for
Airport/
Airline
Combinations
.
.
.
.
.
47
Table
B.
2­
5.
Number
of
Airport/
Airline
Combinations
in
Detailed
Questionnaire
(
DQ)
Sample
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
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.
48
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
a.
Title
of
the
Information
Collection
Survey
of
Airport
Deicing
Operations.

b.
Short
Characterization/
Abstract
The
Survey
of
Airport
Deicing
Operations
would
collect
information
from
airports
and
airlines
that
perform
deicing/
anti­
icing
operations
on
aircraft
and
airfield
pavement.
EPA
would
use
the
results
of
the
questionnaire
to
support
the
development
of
deicing
stormwater
discharge
standards
(
i.
e.,
effluent
guidelines)
for
airports
pursuant
to
the
Agency's
2004
Effluent
Guidelines
Plan
(
69
FR
53719,
September
2,
2004).
"
Deicing
stormwater"
is
any
stormwater,
runoff,
or
snow
melt
that
comes
in
contact
with
or
is
generated
from
deicing
and/
or
anti­
icing
fluids
or
chemicals,
for
example,
stormwater
containing
used
aircraft
deicing
fluid
(
ADF)
that
is
collected
from
deicing
pads,
or
stormwater
that
is
contaminated
with
runway
deicing
chemicals.

There
are
three
questionnaire
instruments
in
this
data
collection:
two
detailed
questionnaires
(
one
for
airports
and
one
for
airlines)
and
one
screener
questionnaire
for
airlines.

The
information
to
be
collected
by
the
airport
questionnaire
includes:
°
Airfield
deicing
operations
and
chemical
usage;
°
Discharge
status
and
destination
of
deicing
stormwater;
°
Deicing
stormwater
collection
and
treatment
systems
used;
°
Pollution
prevention
programs
and
management
practices;
°
Information
pertaining
to
environmental
assessment;
°
Information
on
pollutant
monitoring;
and
°
Financial
information
and
data
necessary
for
economic
impact
analysis.

The
information
collected
by
the
airline
detailed
questionnaire
includes:
°
Who
performs
aircraft
deicing
and
where
deicing
operations
are
performed;
°
Type
of
equipment
used
to
apply
ADFs;
°
Amount
of
deicing
chemicals
purchased;
°
Pollution
prevention
programs
and
management
practices;
and
°
Financial
information
and
data
necessary
for
economic
impact
analysis.

The
airline
screener
questionnaire
would
provide
information
on
who
performs
deicing/
anti­
icing
operations
on
airline
aircraft
including
the
names
of
other
airlines,
FBOs,
or
private
contractors
that
deice
and/
or
anti­
ice
the
aircraft.
This
questionnaire
would
be
used
to
select
the
recipients
of
the
airline
detailed
questionnaire.

EPA
would
distribute
the
airport
questionnaire
by
mail
to
a
stratified
sample
of
airport
owners/
operators
to
help
the
Agency
compile
a
national
assessment
of
deicing
operations.
EPA
would
distribute
the
airline
screener
to
the
airlines
serving
the
airports
in
the
aforementioned
2
sample.
Each
airline
detailed
questionnaire
recipient
would
be
asked
to
provide
responses
for
a
specified
sample
of
airport
locations
at
which
the
airline
operates,
i.
e.
a
subset
of
the
locations
listed
in
the
screener.
EPA
estimates
the
total
respondent
burden
and
costs
associated
with
this
ICR
are
20,734
hours
and
$
866,834.

2.
Need
for
and
Use
of
the
Collection
a.
Need/
Authority
for
the
Collection
On
September
2,
2004,
under
Section
304(
m)(
1)(
B)
of
the
Clean
Water
Act,
EPA
issued
the
2004
Effluent
Guidelines
Plan
(
69
FR
53705)
and
identified
airport
deicing
operations
as
a
new
industrial
category
that
discharges
toxic
and
nonconventional
pollutants
in
nontrivial
amounts.

EPA's
Office
of
Water
has
begun
an
effort
to
develop
regulations
for
the
appropriate
control
of
the
discharge
of
stormwater
from
deicing/
anti­
icing
operations
by
airports
under
the
authority
of
section
308
of
the
Clean
Water
Act
(
Federal
Water
Pollution
Control
Act,
33
U.
S.
C.
Section
1318).

b.
Practical
Utility/
Users
of
The
Data
i.
General
Use
of
the
Data
The
purpose
of
this
effort
is
to
provide
information
for
the
development
of
national
effluent
guidelines
regulations
for
the
airport
deicing
category.
Airport
deicing/
anti­
icing
operations
are
performed
by
airlines,
fixed­
base
operators
(
i.
e.,
contract
service
providers),
and
airports.
Typically,
airlines
and
fixed­
base
operators
(
FBOs)
are
responsible
for
aircraft
deicing/
anti­
icing
operations,
while
airports
are
responsible
for
the
deicing/
anti­
icing
of
airfield
pavement.
Compliance
with
environmental
regulations
and
requirements
associated
with
deicing/
anti­
icing
operations
may
be
shared
between
airlines/
FBOs
and
the
airports
as
copermittees
although
the
airport
is
ultimately
responsible
for
the
management
of
the
deicing
stormwater
generated.
This
data
collection
effort
includes
questionnaire
instruments
to
collect
information
on
deicing/
anti­
icing
operations
performed
by
airlines
and
airports.

EPA
would
use
the
technical
data
collected
in
Part
A
of
the
airport
questionnaire
to
determine
rates
of
deicing
stormwater
generation
and
collection,
deicing
stormwater
prevention,
management,
treatment,
and
discharge
status,
and
characteristics
of
receiving
waters.
EPA
would
also
use
these
technical
data
together
with
the
financial
data
collected
in
Part
B
of
the
questionnaire
to
assess
the
costs
and
benefits
associated
with
any
new
discharge
standards
considered
for
the
airport
deicing
category.
Finally,
EPA
would
characterize
the
economic
status
of
the
airport
category
and
estimate
the
possible
economic
impacts
of
such
national
effluent
guidelines
regulation.
These
analyses
will
rely
on
financial
and
economic
data
collected
from
Federal
Aviation
Administration
(
FAA)
databases
and
Part
B
of
the
airport
questionnaire.
3
For
the
airline
detailed
questionnaire,
EPA
would
use
the
technical
data
in
Part
A
to
develop
an
industry
profile
for
deicing
operations.
Airline
financial
data
collected
from
the
Bureau
of
Transportation
Statistics
(
BTS)
and
Part
B
of
the
airline
detailed
questionnaire
would
be
used
together
with
the
technical
data
to
characterize
the
economic
status
of
the
airline
industry
and
estimate
the
possible
economic
impacts
of
such
national
effluent
guidelines
regulations.

The
sections
in
the
airport
and
airline
detailed
questionnaires
are
designed
to
collect
the
following
information:


Deicing
Stormwater
Sources.
EPA
would
use
this
information
to
develop
an
industry
profile
of
deicing
stormwater
generation
which
would
contribute
to
developing
and
evaluating
possible
regulatory
and
underlying
technology
options
and
compliance
cost
estimates.


Deicing
Stormwater
Generation,
Collection,
and
Treatment
System
Design
and
Operating
Parameters.
EPA
would
use
this
information
to
develop
treatment­
in­
place,
technology
options
and
compliance
cost
estimates.


Deicing
Stormwater
Generation,
Collection,
and
Treatment
Costs.
EPA
would
use
this
information
to
develop
and
validate
compliance
cost
estimates
for
underlying
technology
options.


Deicing
Stormwater
Characterization.
Information
on
pollutant
monitoring
and
sampling
would
indicate
the
availability
of
deicing
stormwater
characterization
data
that
EPA
could
request
in
follow­
up
to
determine
current
deicing
stormwater
discharge
characteristics
for
each
airport,
evaluate
deicing
stormwater
treatment
performance,
and
estimate
pollutant
discharge
loadings.


Pollution
Prevention
Practices.
EPA
would
use
this
information
to
identify
specific
practices
that
may
become
part
of
the
regulatory
technology
options
and
their
associated
costs
and
pollution
reductions.


Receiving
Waters
Characterization.
EPA
would
use
this
information
to
help
assess
environmental
impacts
from
deicing
stormwater
discharges
and
the
potential
benefits
from
reducing
these
impacts.


Financial
Information,
Including
Income
Statements
for
Each
Airport/
Airline,
Airport/
Airline
Owner,
and
Parent
Company.
These
data
would
permit
EPA
to
calculate
a
baseline
for
an
economic
impact
analysis.
Using
this
industry
baseline,
EPA
would
assess
potential
changes
in
economic
and
financial
conditions
in
the
market
due
to
compliance
costs.

EPA
would
use
all
of
these
data
to
develop
effluent
guidelines
and
standards
in
accordance
with
the
statutory
standards.
Specifically,
the
technical
information
collected
in
Part
A
of
the
airport
and
airline
detailed
questionnaires
would
allow
EPA
to:
4

Properly
characterize,
classify,
and
if
necessary
subcategorize
the
airport
deicing
category
by
pollutants,
generated
deicing
stormwater
characteristics,
deicing
stormwater
destination,
or
a
combination
of
these
or
other
factors
yet
to
be
determined;


Identify
best
management
practices
and
pollution
prevention
and
source
reduction
activities
to
decrease
pollutant
levels;


Identify
effective
containment
and
collection
measures;


Identify
best
available
technologies
which
are
based
on
factors
such
as
treatment
technology
efficiency
and
total
cost
to
the
industry;


Determine
treatment­
in­
place;


Determine
the
most
effective
deicing
stormwater
treatment
technologies;
and

Determine
the
airport
treatment
system
modifications
and
associated
costs
necessary
for
individual
airports
to
comply
with
regulatory
options
including
underlying
technology
options
and
associated
effluent
guidelines
and
standards.

EPA
plans
to
collect
financial
and
economic
information
in
Part
B
of
the
detailed
questionnaire
from
airports
and
airlines
to
estimate
the
impact
of
compliance
costs
on
the:

(
a)
cost
of
airport/
airline
services;
(
b)
cost
per
enplaned
passenger;
(
c)
landing
fees;
(
d)
financial
condition
of
the
airport/
airline;
and
(
e)
potential
change
in
regional
and/
or
local
economies
due
to
reduced
airport
revenues
and
employees,
or
the
reduction
of
airline
services.

ii.
Detailed
Technical
Analyses
Supported
by
Part
A
of
the
Questionnaire
Data
To
develop
effluent
guidelines
and
standards,
EPA
would
collect
and
analyze
information
pertaining
to
deicing
stormwater
characteristics
(
e.
g.,
pollutants
discharged,
deicing
stormwater
volumes),
deicing
stormwater
treatment
and
controls
(
e.
g.,
pollution
prevention
techniques,
endof
pipe
treatment
systems),
and
the
economic
impacts
of
these
treatment
technologies.
Specifically,
to
develop
effluent
guidelines
and
standards
for
airport
deicing,
EPA
would
use
responses
to
the
airport
and
airline
detailed
questionnaires
to
assist
in
characterizing
the
pollutants
discharged
from
airport
deicing/
anti­
icing
operations
and
to
develop
regulatory
options
to
control
these
pollutant
discharges.

The
Agency
would
use
the
data
collected
to
assist
in
establishing
current
baseline
estimates
of
industry­
wide
pollutant
concentrations,
pollutant
loadings,
and
deicing
stormwater
generation
volumes
per
airport,
in
order
to
estimate
the
engineering
costs
of
compliance
and
analyze
the
economic
impacts
and
environmental
benefits
associated
with
each
regulatory
option.
5
EPA
would
select
appropriate
regulatory
options
for
airport
deicing
operations
based
on
the
results
of
these
analyses
and
data
from
EPA
site
visits,
sampling
episodes,
and
industry
submissions.

EPA
engineers,
statisticians,
biologists,
and
contractors
would
perform
detailed
analyses
of
the
data
collected
through
Part
A
of
the
questionnaires.
The
technical
data
would
include
basic
airport
and
airline
information,
deicing
stormwater
generation
information,
deicing
stormwater
characterization
summaries,
collection,
detailed
deicing
stormwater
treatment
system
data,
pollution
prevention
data,
receiving
water
characteristics,
and
costing
information.
Specific
analyses
using
the
technical
data
are
described
below.

(
a)
Subcategorization
In
developing
the
effluent
guidelines
and
standards,
EPA
would
consider
whether
it
is
appropriate
to
subcategorize
or
segment
airport
deicing
operations
based
upon
such
factors
as:


Airport
size
determined
by
the
number
of
airport
operations
(
number
of
take
offs/
landings
per
year);


Deicing/
anti­
icing
chemicals
or
methods
used;


Amount
of
deicing
performed
determined
by
the
amount
of
ADF
used
and/
or
purchased;


Deicing
stormwater
collection,
handling
and
discharge
practices;


Deicing
stormwater
characteristics;
and/
or

Non­
water
quality
or
secondary
impacts.

These
factors
can
result
in
distinct
effluent
characteristics
and
would
provide
a
means
to
take
into
account
technology
achievability
and
economic
impacts
unique
to
specific
segments
of
the
industry
(
e.
g.,
small
hub,
non­
hub
airports
).
EPA
may
subcategorize
the
industry
based
on
one
or
a
combination
of
the
factors
listed
above,
if
necessary
and
appropriate.
Once
these
subcategories
are
established,
technically
feasible
control
options
would
be
developed
for
each
subcategory.

To
perform
the
subcategorization,
EPA
would
group
airport
deicing
operations
into
separate
classes
of
similar
characteristics.
EPA
would
use
the
questionnaire
data,
EPA
airport
visits,
and
sampling
data
to
evaluate
and
consider
each
of
the
factors
listed
above
as
they
affect
the
airport
deicing
category.

(
b)
Deicing
Stormwater
Characterization
and
Evaluation
EPA
would
use
data
collected
through
the
questionnaire
to
analyze
airport
deicing
stormwater
generation,
collection,
pollution
prevention
practices,
and
deicing
stormwater
6
treatment
systems.
Specifically,
EPA
would
analyze
each
deicing
stormwater
source,
factors
affecting
deicing
stormwater
generation
and
collection
and
deicing
stormwater
discharge
rates;
pollution
prevention
techniques
associated
with
each
deicing
stormwater
source;
and
the
characteristics
of
deicing
stormwater
generated
from
each
source.
EPA
would
also
analyze
industry­
wide
pollution
prevention
practices
and
deicing
stormwater
treatment
systems
to
determine
the
deicing
stormwaters
that
are
being
treated,
the
treatment
technologies
that
are
applicable
to
those
deicing
stormwaters,
the
effectiveness
of
these
systems
and
pollution
prevention
practices,
best
management
practices,
and
the
final
discharge
characteristics
from
airport
deicing
operations.

Deicing
stormwater
characterization
is
used
to
determine
the
sources
(
i.
e.,
aircraft
and/
or
airfield
pavement
deicing/
anti­
icing
operations)
of
the
deicing
stormwater
and
the
pollutants
and
pollutant
concentrations
that
are
present
in
the
deicing
stormwater.
This
information
is
ultimately
used
to
compare
the
performance
of
the
different
control
measures
and
to
develop
a
list
of
pollutants
that
are
commonly
found
in
the
deicing
stormwater.
Deicing
stormwater
characterization
includes
the
following:


Determining
deicing
stormwater
sources,
and
deicing
stormwater
generation
and
collection
practices
associated
with
airport
deicing
operations;


Identifying
pollutants
of
concern
(
POCs);
and

Characterizing
deicing
stormwater
data
for
the
POCs.

(
c)
Technical
Feasibility
Analysis
EPA
must
select
technically
feasible
control
options
for
each
airport
deicing
operation
subcategory
developed.
The
feasibility
assessment
of
these
control
options
would
be
based
upon
the
effectiveness
of
the
control
options
at
reducing
overall
volumes
and
specific
pollutants
in
the
effluent
and
the
demonstration
and
availability
of
the
treatment
technologies
for
airport
deicing/
anti­
icing
operations.

(
d)
Pollutant
Loadings
and
Removals
Pollutant
loadings
and
removals
are
calculated
to
evaluate
current
deicing
stormwater
discharges,
the
effectiveness
of
regulatory
control
options,
pollutant
reductions
after
incorporation
of
regulatory
control
options,
and
the
cost­
effectiveness
of
regulatory
options
in
reducing
pollutant
loadings.
Calculating
pollutant
loadings
and
removals
includes
the
following:


Calculating
the
baseline
loadings
in
the
last
three
winter
seasons
(
i.
e.,
the
pollutant
loadings
being
discharged
prior
to
the
rulemaking);


Calculating
option
loadings
(
i.
e.,
the
estimated
pollutant
loadings
after
implementation
of
a
regulatory
option);
and
7

Calculating
the
pollutant
reductions
(
i.
e.,
the
difference
between
the
baseline
loadings
and
regulatory
option
loadings).

(
e)
Assessment
of
Technology
Costs
EPA
staff
and
contractors
would
estimate
the
costs
of
various
control
options
and
pollution
prevention/
management
practices
being
considered
for
the
basis
of
the
effluent
guidelines
and
standards.
The
costs
of
the
control
options
or
practices
would
include
the
following
items:
capital
costs
for
engineering
design,
equipment
and
installation,
annual
operating
and
maintenance
(
O&
M)
costs
for
the
option;
and
compliance
monitoring.
The
airport
questionnaire
includes
a
request
for
capital,
O&
M,
and
monitoring
costs
associated
with
existing
treatment
and
collection
systems
as
well
as
pollution
prevention
practices
and
best
management
practices.

EPA
would
use
data
collected
through
the
questionnaires
to
estimate
the
direct
costs
of
the
deicing
stormwater
treatment
and
control
options
and/
or
pollution
prevention/
management
practices
selected
as
the
technology
bases
for
any
effluent
guidelines
and
standards.
These
data
include
deicing
stormwater
flow
rates,
deicing
stormwater
source
data,
data
related
to
deicing
stormwater
collection
and
treatment/
control
technologies,
pollution
prevention/
management
practices,
and
pollutant
concentrations.

EPA
would
estimate
the
incremental
investment
costs
and
incremental
operating
and
maintenance
costs
for
the
airport
and/
or
airline
to
comply
with
the
technology
options
considered.
These
compliance
costs
would
be
used
to
determine
the
potential
economic
impacts
on
the
industry.
In
addition,
these
compliance
costs
would
be
weighed
against
the
effluent
reduction
benefits
resulting
from
each
technology
option.
In
order
to
estimate
airport­
and
airline­
level
compliance
costs,
EPA
would
need
to
consider
the
pollutant
reductions
resulting
from
implementation
of
each
option.
This
information
would
be
used
to
determine
whether
airports
and/
or
airlines
need
to
improve
their
deicing
stormwater
collection
and
control
technology
(
e.
g.,
by
installing
new
units
or
entire
systems)
or
modify
their
operating
practices
to
comply
with
the
effluent
guidelines
and
standards
for
a
particular
technology
option.

(
f)
Calculation
of
Effluent
Guidelines
and
Standards
EPA
would
determine
effluent
guidelines
and
standards
for
each
alternative
technology
option
and
subcategory.
These
limitations
would
be
based
upon
a
detailed
statistical
analysis
of
data
from
those
airports
with
well­
operated
treatment
systems,
using
the
recommended
control
options.
The
data
from
the
questionnaire
would
enable
EPA
to
identify
these
airports
for
future
evaluation
of
their
treatment
systems.

Calculating
effluent
guidelines
and
standards
may
include
calculating
long­
term
averages,
variability
factors,
and
limitations.
In
order
to
perform
these
calculations,
the
following
steps
are
taken:
8

Collecting
effluent
data;


Selecting
data
for
the
model
pollutant
control
options;
and

Calculating
the
limitations.

(
g)
Environmental
Assessment
and
Economic
Benefits
Analysis
EPA
would
perform
an
environmental
assessment
to
estimate
current
impacts
from
deicing
stormwater
discharges
on
ecosystem
and
human
health.
Conducting
an
environmental
assessment
includes
characterizing
the
following:


Behavior
of
deicing
stormwater
discharges
in
the
environment;


Exposure
of
ecosystems
and
human
populations
to
deicing
stormwater
discharges;
and

Reactions
of
ecosystems
and
human
populations
to
deicing
stormwater
discharge
exposure
The
airport
questionnaire
includes
a
request
for
information
on
the
characteristics
of
the
waters
that
receive
deicing
stormwater
discharges.
This
information
will
help
EPA
assess
the
environmental
behavior
of
deicing
stormwater
discharges
and
the
potential
for
exposure
of
ecosystems
and
human
populations
to
the
discharges.

Following
an
assessment
of
the
current
environmental
impacts,
EPA
would
estimate
the
potential
change
in
environmental
impact
(
including
non­
water
quality
impacts)
associated
with
different
control
options
for
deicing
stormwater
discharges.
EPA
would
use
this
information
to
help
characterize
the
economic
benefits
associated
with
the
different
control
options.

As
part
of
the
environmental
assessment,
EPA
would
also
examine
behavior
of
deicing
stormwater
discharges
to
publicly
owned
treatment
works
(
POTWs)
and
the
potential
for
environmental
impacts
from
POTW
discharges.
This
information
would
be
used
to
help
determine
the
change
in
environmental
impact
and
economic
benefit
associated
with
different
options
for
handling
deicing
stormwater
within
POTWs.

(
h)
Development
of
Regulatory
Options
and
Selection
of
Final
Option
After
all
subcategories
are
identified,
technology
options
are
assessed,
effluent
guidelines
and
standards
are
calculated,
pollutant
reductions
are
calculated,
and
economic
analyses
are
performed,
EPA
would
develop
regulatory
options
for
consideration
by
EPA
senior
management.
Each
option
contains
detailed
information
on
the
technology
basis
for
the
option
and
associated
effluent
guidelines
and
standards,
amounts
of
pollutants
removed,
potential
costs
to
the
industry,
economic
impacts
of
these
costs
on
businesses
(
e.
g.,
if
airports
may
be
forced
to
raise
landing
fees
or
passenger
facility
charges
because
of
regulatory
costs),
cost­
effectiveness,
and
non­
water
quality
environmental
impacts.
Based
upon
all
of
these
analyses,
EPA
selects
the
most
appropriate
regulatory
option
for
each
airport
deicing
operation
subcategory.
9
iii.
Detailed
Economic
Analyses
Supported
by
Part
B
of
the
Questionnaire
Data
EPA
economists
and
contractors
will
use
information
collected
in
the
questionnaires
to
estimate
airport­
specific,
airline­
specific,
and
national
costs,
and
to
project
the
potential
economic
impacts
of
the
proposed
rule
on
those
entities.
EPA
has
undertaken
substantial
efforts
to
use
nonquestionnaire
data
sources.
EPA
will
collect
airport
income
and
capital
expenditure
data
primarily
through
FAA
databases.
Thus,
the
airport
questionnaire
focuses
on
ownership
structure,
financial
relationships
with
airlines,
and
funding
sources
for
capital
expenditures.
Similarly,
EPA
will
use
BTS
data
for
airline
income
and
balance
sheet
statements,
as
well
as
to
characterize
airport
operations,
airline
route
structure
and
passenger
enplanements.
Therefore,
the
airline
questionnaire
primarily
focuses
on
network
and
airport­
specific
aircraft
deicing
operations
and
costs.

(
a)
Estimation
of
Impacts
on
Airports
The
primary
element
of
the
economic
impact
analysis
will
be
a
determination
of
any
proposed
regulation's
impact
on
each
airport's
rates
and
charges
structure.
Because
airports
are
frequently
publicly­
owned
not­
for­
profit
organizations,
the
standard
discounted
cash
flow
model
for
a
profit­
maximizing
firm
is
not
useful
for
projecting
impacts
of
a
potential
rule.
Furthermore,
airports
may
have
some
market
power
reflected
in
their
ability
to
raise
fees
on
airlines
using
the
airport.
For
example,
airlines
are
contractually
obligated
to
cover
increases
in
airport
costs
if
they
have
a
residual
use
agreement
with
the
airport.
Thus,
examining
impacts
to
an
airport's
discounted
cash
flow
to
determine
"
profit"
or
"
loss"
is
not
a
useful
measurement
tool,
nor
does
it
result
in
a
clear
decision
rule
for
determining
potential
airport
financial
impacts.

Instead,
EPA
will
examine
several
measures
of
potential
financial
impacts
to
airports
to
determine
if
a
proposed
rule
is
economically
achievable.
First,
EPA
will
examine
the
magnitude
of
estimated
compliance
costs
relative
to
airport
operating
income
(
operating
revenues
less
operating
expenses)
and
"
net
income"
(
which
includes
nonoperating
expenses
and
revenues).
Second,
if
airports
choose
to
pass
on
increased
deicing
stormwater
treatment
costs
to
airlines,
it
may
be
in
the
form
of
increased
landing
fees.
EPA
will
project
the
increase
in
landing
fees
that
would
be
necessary
to
cover
these
increased
costs.
Third,
a
measure
commonly
used
by
industry
to
determine
the
affordability
or
reasonableness
of
an
airport's
rate
structure
is
airline
cost
(
e.
g.,
landing
fees,
terminal
rentals,
etc.)
per
enplaned
passenger.
EPA
will
estimate
the
potential
change
in
airline
cost
per
enplaned
passenger
resulting
from
the
proposed
rule.
Finally,
a
widely
used
measure
of
the
availability
of
debt
financing
to
an
airport
is
its
debt
service
coverage
ratio.
EPA
will
estimate
the
post­
regulatory
debt
service
coverage
ratio
to
determine
if
the
rule
will
impact
an
airport's
ability
to
obtain
financing
to
cover
other
airport
capital
improvements.

EPA
has
obtained
many
data
elements
necessary
to
perform
these
analyses
from
publicly
available
sources.
BTS
data
on
airport­
specific
departures
by
airline,
aircraft
type,
and
enplaned
passengers
will
be
used
to
determine
the
scale
of
deicing
operations
at
each
airport
(
to
estimate
compliance
costs),
as
well
as
provide
the
baseline
operational
data
for
projecting
the
potential
change
in
landing
fees.
In
addition,
most
airports
likely
to
be
surveyed
routinely
submit
financial
data
to
FAA
that
are
adequate
for
the
impact
analysis;
EPA
anticipates
that
only
a
small
percentage
of
questionnaire
recipients
will
need
to
complete
those
questions
on
the
questionnaire.
10
Thus,
on
the
questionnaire
EPA
requests
data
not
readily
available
from
other
sources.
These
include
airport
landing
fees,
the
percentage
of
airport
revenues
directly
attributable
to
airline
fees,
and
the
components
of
the
airport's
debt
service
coverage
ratio.

(
b)
Estimation
of
Impacts
on
Airlines
EPA
anticipates
that
the
costs
of
the
rule
will
most
likely
be
incurred
by
airlines,
either
in
the
form
of
higher
landing
fees,
or
increased
direct
deicing
costs
per
aircraft.
To
examine
airline
impacts,
EPA
will
examine
at
least
two
different
measures.
First,
EPA
will
project
impacts
to
airlines
on
a
per
flight
basis.
Regulatory
costs
may
have
differential
impacts
across
an
airline's
route
structure.
Impacts
will
vary
for
different
routes
for
a
number
of
reasons,
including:
distance
(
e.
g.,
other
things
equal,
a
longer
flight
could
be
expected
to
have
smaller
impacts
than
a
shorter
flight),
aircraft
type
(
a
larger
plane
will
incur
larger
costs
than
a
smaller
plane
since
landing
fees
are
based
on
aircraft
weight),
and
load
factors
(
a
fuller
flight
might
be
expected
to
have
smaller
impacts
than
a
less
full
flight
since
costs
can
be
spread
over
more
passengers).

Second,
EPA
will
also
examine
impacts
to
airlines
at
the
company
level.
Airline
compliance
cost
per
airport
will
be
extrapolated
and
aggregated
over
all
affected
airports
at
which
the
airline
operates,
then
the
impact
of
those
aggregate
deicing
costs
on
airline
income
will
be
examined.

Again,
EPA
will
collect
many
data
elements
for
these
analyses
from
publicly
available
sources.
BTS
data
on
airport
departures
by
airline,
aircraft
type,
and
enplaned
passengers
will
be
used
to
determine
the
airline's
route
structure
for
each
airport.
EPA
will
also
use
BTS­
collected
airline
income
statements
and
balance
sheets
and
income
statements
for
all
U.
S.
certificated
air
carriers.
Therefore
the
questionnaire
focuses
on
data
not
available
from
publicly
available
sources.
The
data
elements
collected
in
the
questionnaire
will
be
used
to
estimate
baseline
deicing
costs,
financial
structure
(
to
determine
appropriate
tax
rates),
and
information
that
may
be
used
to
extrapolate
compliance
costs
incurred
by
airlines
at
each
airport
sampled
to
total
airline
compliance
costs
from
all
airports
served.

(
c)
Regulatory
Flexibility
Analysis
Although
EPA
anticipates
that
few,
if
any,
small
airports
will
be
affected
by
a
potential
rule,
EPA
will
need
to
examine
the
projected
impacts
of
any
proposed
rule
on
small
business
entities.
Among
airports,
ownership
is
the
key
determinant
of
size.
In
the
case
of
municipal
and
county­
owned
airports,
small
business
status
is
determined
by
the
size
of
the
entity
that
owns
it,
not
by
the
size
of
the
airport
itself
(
whether
measured
by
employment
or
revenues).
EPA
is
collecting
airport
ownership
information
in
the
questionnaire.

For
the
purpose
of
analyzing
impacts
to
small
airlines,
airline
employment
is
the
relevant
metric
specified
by
the
Small
Business
Administration.
BTS
collects
airline
employment
data,
therefore
EPA
will
not
need
to
obtain
that
data
through
the
questionnaire.
11
3.
Non­
Duplication,
Consultations,
and
Other
Collection
Criteria
a.
Non­
Duplication
These
questionnaires
do
not
duplicate
any
existing
data
collections.

There
are
two
federal
agencies
principally
responsible
for
regulation
and
analysis
of
the
aviation
industry:
the
FAA
and
the
Department
of
Transportation
(
DOT).
EPA
met
with
FAA
staff
and
reviewed
databases
and
reports
prepared
by
the
FAA
and
DOT
for
information
relevant
to
airport
and
aircraft
deicing
operations.
These
agencies
have
comprehensive
information
on
the
location
and
operational
size
of
airports
(
i.
e.,
as
measured
by
annual
number
of
flights
or
departures).
They
also
keep
track
of
which
airlines
operate
at
particular
airports,
air
flight
routes,
and
some
airline
financial
information.
These
data
will
be
helpful
to
EPA
in
developing
general
demographic
profiles
of
the
population.
However,
neither
of
these
agencies
collect
data
on
aircraft
deicing
operations,
nor
the
configuration
of
stormwater
or
wastewater
collection
systems
at
airports.

In
2003,
FAA
conducted
a
limited,
one­
time
questionnaire
of
major
airports
on
their
pavement
deicing
practices.
EPA
has
obtained
the
results
of
this
questionnaire,
which
was
completed
by
453
airports.
The
questionnaire
provides
some
basic
information
on
the
name
and
type
of
chemical
deicing
products
that
were
used
at
the
time,
but
no
information
was
provided
on
the
amounts
used,
information
on
wastewater/
stormwater
collection
and
treatment,
or
other
environmental
data.
EPA
has
determined
that
it
needs
more
comprehensive
information
on
pavement
deicing
for
the
purposes
of
developing
the
proposed
effluent
guidelines.

EPA
also
asked
the
airport
and
airline
industry
associations
to
identify
any
existing
federal
data
sources
that
would
be
useful
to
EPA
in
the
effluent
guidelines
project.
No
other
sources
were
identified
by
the
industry
associations.

b.
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Announcements
of
a
public
comment
period
for
this
ICR
were
made
in
the
Federal
Register
on
January
28,
2005
(
70
FR
4117)
for
the
airport
questionnaire
and
on
March
17,
2005
(
70
FR
13025)
for
the
airline
detailed
questionnaire.
EPA
received
four
comments
from
the
following
entities:
private
individuals;
the
Air
Transport
Association
(
ATA);
the
Airports
Council
International
(
ACI),
and
American
Association
of
Airport
Executives
(
AAAE);
and
the
Alliance
of
Residents
Concerning
O'Hare
(
ARECO).
In
addition
to
publishing
the
Federal
Register
notice,
EPA
informed
industry
trade
associations
of
the
notice
publication
via
phone
and
e­
mail.

In
summary,
the
comments
received
generally
requested
clarification
of
terms/
terminology
and
estimation.
Specific
comments
included
whether
airports
or
airlines
should
be
the
source
of
requested
deicing
information,
the
time
basis
of
data,
and
questionnaire
organization.
In
most
cases,
questions
or
data
requests
were
revised
or
added
to
the
questionnaire.
For
example,
the
time
basis
of
the
data
was
expanded
to
the
last
three
winters
per
comment
from
the
industry.
A
summary
of
comments
received
on
the
public
notices
and
EPA's
response
is
presented
in
Appendix
A.
12
c.
Consultations
On
May
2,
2005,
during
the
public
comment
period
on
the
questionnaires,
EPA
met
with
members
of
the
principal
industry
associations:
Air
Transport
Association
(
ATA),
American
Association
of
Airport
Executives
(
AAAE),
and
Airports
Council
International
(
ACI).
EPA
provided
the
associations
with
an
overview
of
the
questionnaire
design.
The
associations
asked
questions
of
EPA
and
offered
informal
comments.
They
subsequently
filed
formal
written
comments
at
the
end
of
the
comment
period.
Several
environmental
and
citizen
groups
contacted
EPA
to
ask
about
the
questionnaires
and
they
received
copies
of
the
public
drafts.
One
of
these
groups,
ARECO,
submitted
written
comments.

d.
Effects
of
Less
Frequent
Collection
The
airport
and
airline
detailed
questionnaires
and
the
airport
telephone
screener
are
a
one
time
only
data
collection
activity
for
the
respondents.

e.
General
Guidelines
The
proposed
data
collection
activities
would
be
conducted
in
accordance
with
the
Paperwork
Reduction
Act
guidelines
in
5
CFR
1320.6
and
EPA's
Quality
Assurance
Guidance.
Information
to
be
disseminated
would
comply
with
EPA's
Information
Quality
Guidelines
which
were
developed
for
implementing
OMB's
Guidelines
for
Ensuring
and
Maximizing
the
Quality,
Objectivity,
Utility,
and
Integrity
of
the
Information
Disseminated
by
Federal
Agencies.

f.
Confidentiality
The
questionnaires
inform
respondents
of
their
right
to
claim
information
confidential
in
accordance
with
40
CFR
part
2,
subpart
B,
Section
2.203.
The
questionnaires
provide
instructions
on
the
Confidential
Business
Information
(
CBI)
procedures
for
making
these
claims.
Since
airports
are
generally
public
entities,
EPA
expects
little
or
no
information
to
be
claimed
as
CBI
on
the
airport
questionnaires.
EPA
also
does
not
expect
any
of
the
deicing
practices
conducted
by
airlines
to
be
considered
CBI,
though
airline
economic
information
may
be
subject
to
a
CBI
claim.
To
date
no
information
provided
during
the
site
visit
program
of
airports
has
been
claimed
as
CBI.
EPA
considered
a
global
CBI
check
box
for
the
technical
and
economic
portions
of
the
industry
questionnaires.
However,
both
airline
and
airport
representatives
have
indicated
they
do
not
want
a
global
CBI
check
box
because
it
could
severely
restrict
their
ability
to
review
relevant
information.
The
airport
and
airline
detailed
questionnaires,
therefore,
provide
a
question
specific
CBI
claim.

g.
Sensitive
Questions
No
sensitive
questions
pertaining
to
private
or
personal
information,
such
as
sexual
behavior
or
religious
beliefs,
would
be
asked
in
the
questionnaire.
13
4.
The
Respondents
and
the
Information
Requested
a.
Respondent
NAICS
Codes
The
respondents
affected
by
this
information
collection
request
are
airports
and
airlines
that
perform
deicing
and
anti­
icing
on
aircraft
and/
or
airfield
pavement.
The
North
American
Industry
Classification
System
(
NAICS)
identification
number
applicable
to
airport
respondents
is:
488119:
Other
Airport
Operations,
for
airports.
The
U.
S.
Census
Bureau
describes
this
U.
S.
industry
as
establishments
primarily
engaged
in
(
1)
operating
international,
national,
or
civil
airports,
or
public
flying
fields
or
(
2)
supporting
airport
operations,
such
as
runway
maintenance
services,
hangar
rental,
and/
or
cargo
handling
services.
The
NAICS
identification
number
applicable
to
airline
respondents
is:
481:
Air
Transportation.

b.
Information
Requested
i.
Data
Items,
Including
Record
Keeping
Requirements
EPA
has
developed
three
questionnaire
instruments
for
this
data
collection
effort.
These
include
the
airport
and
airline
detailed
questionnaires
and
the
airline
screener
questionnaire.
The
detailed
questionnaires
developed
for
airports
and
airlines
would
be
part
of
a
statistical
analysis
addressing
airport
deicing/
anti­
icing
operations,
including
the
use
of
anti­
icing
and
deicing
fluids
(
ADFs);
the
generation,
collection,
containment,
treatment
and
discharge
of
ADF­
contaminated
stormwater;
ownership
and
management
structure;
revenues;
and
costs.
These
questionnaires
would
provide
information
to
evaluate
the
potential
outcome
of
developing
effluent
guidelines
for
the
airport
deicing
category.
Airport
and
airline
respondents
would
be
asked
to
complete
a
detailed
and
a
screener
questionnaire
to
be
solicited
by
mail.
The
airline
screener
questionnaire
would
only
impact
airlines.

For
the
airline
screener,
recipients
would
indicate
whether
they
perform
their
own
aircraft
deicing
or
would
provide
the
name
of
another
airline,
FBO,
or
private
contractor
that
performs
most
of
the
deicing/
anti­
icing
operations
on
their
aircraft
at
specific
airports
provided
by
EPA.
The
screener
information
would
be
used
to
select
a
sample
of
recipients
for
the
airline
detailed
questionnaire.
Descriptions
of
the
data
items
in
these
questionnaires
are
provided
below.

(
a)
Airport
Questionnaire
The
airport
questionnaire
consists
of
two
parts.
Part
A
requests
airport
technical
information
about
deicing
and
anti­
icing
primarily
of
airfield
pavement.
Financial
and
economic
information
is
requested
in
Part
B.
Each
of
these
parts
is
divided
into
sections.
At
the
end
of
each
section,
there
is
a
question
that
provides
space
for
the
respondent
to
add
comments
that
explain
or
expand
responses
to
questions
within
that
section.
A
detailed
description
of
the
questionnaire
questions
follows.

For
quantitative
questions,
EPA
is
asking
for
three
years
of
data.
EPA
decided
to
take
this
approach
after
consultation
with
industry
representatives
who
indicated
that
three
years
of
14
data
was
necessary
because
of
the
variability
of
weather
patterns
and
deicing
stormwater
generation.

PART
A.
TECHNICAL
INFORMATION
Section
1.
General
Airport
Information
Section
1
requests
general
information
about
the
airport.
Questions
1
to
6
collect
information
that
identifies
the
airport
name
and
address,
and
the
primary
and
secondary
contacts
to
verify
or
clarify
the
technical
questionnaire
information.

Question
7
asks
whether
deicing/
anti­
icing
operations
were
performed
at
the
airport
during
the
2002/
2003,
2003/
2004,
and
2004/
2005
winter
seasons
(
hereafter
referred
to
as
the
last
three
winter
seasons).
EPA
would
use
this
question
to
identify
airports
that
should
complete
the
questionnaire;
airports
that
did
not
perform
deicing/
anti­
icing
operations
would
not
complete
the
rest
of
the
questionnaire.

Questions
8
to
10
ask
for
basic
information
about
the
destination
of
deicing
stormwater
discharges
associated
with
the
last
three
winter
seasons
(
i.
e.,
to
publicly
owned
treatment
works
(
POTW)
or
directly
to
surface
water).
EPA
would
use
these
questions
to
identify
airports
that
should
answer
additional
questions
on
the
characteristics
of
the
POTW
(
Question
9)
or
surface
water
to
which
they
discharge
deicing
stormwater
(
Questions
11
to
14).

Question
11
requests
information
from
facilities
that
discharge
deicing
stormwater
directly
to
surface
water.
The
question
requests
information
on
the
receiving
water
destination
of
deicing/
anti­
icing
stormwater,
applicable
permit
information,
and
a
copy
of
the
facility's
Stormwater
Pollution
Prevention
Plan
(
SWPPP)
(
if
applicable).
EPA
would
use
this
information
to
generally
determine
the
location
of
airport
stormwater
discharges
(
including
deicing
discharges)
and
to
identify
potential
sources
of
existing
airport
stormwater
discharge
data.
EPA
would
also
use
this
information
to
update
the
industry
profile
and
possibly
to
assist
in
the
estimate
of
baseline
pollutant
loadings.
EPA
would
use
the
latitude
and
longitude
data
of
surface
water
outfalls
to
characterize
with
greater
accuracy
where
deicing
stormwater
discharges
to
surface
waters
are
taking
place
relative
to
any
nearby
ecosystems
and
human
populations
within
a
watershed.

Question
12
requests
a
latitude
and
longitude
referenced
map
showing
facility
boundaries,
locations
of
outfalls
that
discharge
deicing
stormwater,
and
the
surface
waters
that
receive
those
discharges.
EPA
would
use
this
information
to
help
determine
proximity
of
ecosystems
and
human
population
both
within
and
beyond
airport
boundaries
to
discharge
outfalls
and
the
surface
waters
that
receive
those
discharges.

Question
13
requests
information
on
the
surface
waters
to
which
a
facility
discharges
deicing
stormwater.
For
streams
and
rivers,
the
question
requests
information
on
receiving
water
flow
regime
and
flow
volume
during
the
time
of
year
during
which
deicing
stormwater
discharges
take
place
(
if
available).
For
lakes
and
ponds
the
question
requests
the
volume
of
the
receiving
water.
EPA
would
use
this
information
to
help
characterize
the
behavior
(
e.
g.,
movement
and
dilution)
of
the
deicing
stormwater
once
it
is
discharged
and
the
type
of
ecosystems
that
may
be
15
immediately
exposed
to
the
discharges.
The
question
also
asks
for
the
names
of
the
surface
waters
downstream
of
the
receiving
water.
This
will
help
EPA
place
even
very
small
receiving
waters
within
a
watershed
context.
(
Many
of
the
very
small
receiving
waters,
sometimes
called
"
first­
order
streams,"
are
not
catalogued
in
national
data
systems
such
as
the
National
Hydrography
Dataset
operated
by
EPA
and
the
US
Geological
Survey.)
This
information
will
also
help
EPA
characterize
ecosystems
and
human
populations
downstream
of
the
outfall
point
that
could
be
exposed
to
deicing
stormwater
discharges.

Question
14
asks
whether
deicing
stormwater
is
discharged
continuously
or
intermittently
and,
if
applicable,
requests
the
months
during
which
intermittent
discharge
takes
place.
Information
from
Question
14
would
be
used
to
help
determine
the
types
and
condition
of
the
ecosystems
and
organisms
that
would
come
into
contact
with
deicing
stormwater
discharges.

Question
15
requests
information
about
the
depth
of
the
uppermost
groundwater
aquifer
at
the
airport
and
about
its
use
within
and
immediately
adjacent
to
the
airport
facility's
boundaries
for
drinking
water.
EPA
will
use
this
information
to
examine
the
potential
for
impacts
to
drinking
water
supplies
from
deicing
stormwater.
The
question
also
requests
the
Safe
Drinking
Water
Information
System
identification
numbers
for
any
wells
withdrawing
from
the
uppermost
aquifer
within
airport
facility
boundaries.
This
information
will
help
EPA
characterize
the
population
obtaining
drinking
water
from
the
uppermost
aquifer.

Question
16
asks
for
information
on
characterization
studies
of
the
receiving
surface
waters
and/
or
of
the
behavior
of
deicing
stormwater
discharges
from
the
airport
within
those
surface
waters
(
e.
g.,
watershed
studies,
environmental
impact
studies,
bioassays).
Information
from
Questions
16
would
be
used
to
help
determine
the
types
of
ecosystems,
the
condition
of
the
ecosystems
and
organisms
that
would
come
into
contact
with
deicing
stormwater
discharges.

Question
17
provides
a
checklist
of
methods
and
practices
to
indicate
how
airports
that
do
not
discharge
deicing
stormwater
achieve
zero
discharge.
Information
from
these
questions
would
be
used
for
subcategorization
and
to
determine
which
airports
would
be
covered
by
this
rulemaking.
In
addition,
the
zero
discharge
information
could
be
used
to
develop
regulatory
options
and
to
identify
industry
pollution
prevention
practices.

Question
18
asks
if
the
airport
plans
any
major
changes
in
the
destination
of
deicing
stormwater
and
the
planned
year
of
the
changes.
During
EPA
site
visits
and
sampling,
some
airports
stated
they
planned
to
change
the
destination
of
deicing
stormwater.
EPA
would
use
this
information
to
indicate
trends
in
the
industry.

Question
19
asks
if
precipitation­
related
records
are
collected
at
the
airport.
Responses
to
this
question
would
indicate
the
availability
of
precipitation
data
for
use
by
EPA
to
evaluate
the
variability
of
snow
events
across
winter
seasons.
Question
20
requests
the
average
number
of
days
deicing
and
anti­
icing
airfield
pavement
operations
were
performed
in
the
last
three
winter
seasons.
The
months
which
airfield
deicing
and
anti­
icing
operations
are
typically
performed
are
requested
in
Question
21.
These
questions
help
to
characterize
the
extent
of
each
airport's
winter
deicing
season.
16
Questions
22
and
23
ask
whether
airport
personnel,
airlines,
or
an
FBO
perform
deicing
and/
or
anti­
icing
of
aircraft
and
airfield
pavement.
EPA
would
use
the
responses
to
these
questions
to
characterize
deicing/
anti­
icing
operations
and
also
to
update
the
industry
profile.

Question
24
provides
an
opportunity
for
the
respondent
to
comment
on
questionnaire
responses
in
this
section.

Section
2.
Airport
Deicing
and
Anti­
icing
Operations
Section
2
is
designed
to
obtain
information
about
airport
deicing/
anti­
icing
stormwater
sources,
flows,
and
destinations.
This
section
requests
a
schematic
flow
diagram
for
untreated
deicing/
anti­
icing
deicing
stormwater
collection,
holding,
and
distribution.
It
also
requests
information
about
the
deicing/
anti­
icing
chemicals,
materials
and
or
practices
used
on
airfield
pavement
to
further
characterize
deicing
stormwater
generation
and
chemical
use
and
addition
for
each
airport.
Responses
to
Section
2
would
provide
EPA
with
information
needed
to
develop
an
industry
profile
of
deicing
stormwater
generation
and
collection;
airfield
deicing
chemical
usage
to
determine
baseline
loadings;
and
information
to
develop
and
evaluate
possible
regulatory
technology
options
and
compliance
cost
estimates.

Question
1
asks
where
aircraft
deicing/
anti­
icing
operations
are
performed
at
the
airport.
This
information
is
needed
to
develop
and
update
the
industry
profile
of
potential
sources
of
deicing
stormwater.

Question
2
requests
a
schematic
flow
diagram
for
deicing
stormwater.
The
schematic
flow
diagram
is
required
to
illustrate
the
sources
and
distribution
of
deicing
stormwater.
The
diagram
would
provide
a
clear
understanding
of
the
components
and
the
destination
of
deicing
stormwater.
A
checklist
and
two
example
diagrams
are
presented
following
the
question
instructions,
to
ensure
that
the
schematic
flow
diagram
is
complete
and
submitted
as
intended.
This
information
would
be
used
to
determine
deicing
stormwater
characteristics;
specifically,
it
would
be
used
to
determine
deicing
stormwater
sources
and
generation
practices.

Question
3
asks
whether
a
diversion
valve
is
included
in
the
diagram,
when
it
is
used,
and
if
the
diversion
procedures
are
specified
in
the
airport's
permit.
Some
airports
divert
stormwater
from
direct
discharge
to
a
treatment
system
during
the
winter
season.
EPA
would
use
this
information
to
determine
airports
that
employ
separation
of
their
deicing
stormwater
from
other
stormwater
to
establish
baseline
industry
practices
and
update
the
industry
profile.

The
type
of
deicing/
anti­
icing
practices
and
chemical
use,
amount,
formulation,
and
concentration
are
requested
in
Questions
4
through
6
for
airfield
pavement
deicing.
This
information
is
requested
for
three
winter
seasons
(
i.
e.,
2002/
2003,
2003/
2004,
and
2004/
2005)
to
address
the
variability
of
snow
events
across
seasons.
To
reduce
burden,
respondents
are
given
the
option
to
attach
chemical
usage
reports
in
lieu
of
completing
Questions
4
through
6.
Responses
to
these
questions
are
intended
to
provide
information
on
the
types
and
concentrations
of
chemicals
used
and
likely
to
be
present
in
deicing
stormwater
drainage
and
collection
systems
in
order
to
characterize
the
deicing
stormwater
generated
at
airports.
Responses
to
these
questions
would
also
be
evaluated
to
identify
and
select
pollutants
of
concern,
and
to
identify
17
opportunities
for
pollution
prevention
through
chemical
substitution
and
best
management
practices,
and
to
identify
trends
among
airports.
The
information
would
aid
in
developing
an
industry
profile
of
deicing
stormwater
generation
and
in
evaluating
differences
in
airport
deicing
stormwater
generation
and
characteristics.
The
information
provided
in
responses
to
Questions
3
through
5
also
would
contribute
to
developing
compliance
cost
estimates
and
could
be
used
for
industry
subcategorization.

Question
7
provides
an
opportunity
for
the
respondent
to
comment
on
questionnaire
responses
in
this
section.

Section
3.
Deicing
Stormwater
Containment
Collection,
and/
or
Conveyance
Many
airports
have
deicing
stormwater
containment
systems
to
comply
with
discharge
requirements
for
stormwater
contaminated
with
deicing
agents.
Section
3
is
designed
to
collect
information
on
the
collection,
containment,
conveyance,
discharge
and/
or
disposal
methods
for
deicing
stormwater.
Responses
to
these
questions
would
also
identify
pollution
prevention
and
best
management
practices.

Question
1
asks
whether
the
airport
implements
stormwater
containment,
collection,
and/
or
conveyance
measures
to
control
the
discharge
of
deicing
stormwater
to
surface
waters
and/
or
POTWs.
EPA
would
use
this
information
to
determine
the
industry
profile
of
stormwater
collection/
containment/
conveyance
methods.

The
methods
used
by
the
airport
for
the
collection,
containment,
and/
or
conveyance
of
deicing
stormwater
are
requested
in
Question
2.
This
question
is
in
a
table
format
listing
potential
airport
deicing
stormwater
sources
and
check
boxes
for
various
collection,
containment,
and/
or
conveyance
methods.
Question
3
requests
the
capital
and
operation
and
maintenance
costs
associated
with
the
airport's
glycol
recovery
vehicles
or
vacuum
trucks
if
applicable.
(
Glycol
is
the
principal
ingredient
in
ADFs.)
This
information
would
contribute
to
developing
compliance
cost
estimates
and
assessing
pollution
prevention
practices.
Questions
4
through
6
request
information
on
the
segregation,
discharge,
and
disposal
of
glycol­
contaminated
stormwater
and
glycol
recovery.
Information
from
questions
in
this
section
would
aid
in
developing
an
industry
profile
for
deicing
stormwater
collection,
discharge,
and
disposal
and
in
evaluating
differences
in
airport
deicing
stormwater
handling.
EPA
would
also
use
this
information
to
evaluate
pollution
prevention
and
best
management
practices.

Question
7
asks
whether
the
airport
has
plans
to
add
a
stormwater
containment
unit
or
system
in
the
future
to
control
the
discharge
of
deicing
stormwater.
Responses
to
this
question
would
indicate
trends
in
the
industry.

Question
8
provides
an
opportunity
for
the
respondent
to
comment
on
questionnaire
responses
in
this
section.
18
Section
4.
Deicing
Stormwater
Treatment/
Recovery
Section
4
is
designed
to
provide
information
on
deicing
stormwater
treatment
technologies
and
units
operated
by
the
airport
during
the
last
three
winter
seasons.
The
information
in
this
section
includes
deicing
stormwater
treatment
diagrams;
design
and
operating
specifications;
sources
of
influent;
chemical
additions;
operating
and
maintenance
costs;
and
discharge
practices.
Responses
to
these
questions
are
critical
input
for
developing
control
technology
options,
regulatory
options
and
compliance
cost
estimates.
Information
concerning
the
availability
of
deicing
stormwater
characterization
data
and/
or
data
to
characterize
the
effectiveness
of
deicing
stormwater
treatment
is
requested.
Information
from
this
section
would
be
used
to
assess
operation,
maintenance,
control,
and
performance
of
treatment
technologies.

Question
1
asks
if
the
airport
operated
a
deicing
stormwater
treatment/
recovery
system,
and
Question
2
requests
a
list
of
the
deicing
stormwater
treatment
unit
operations
used
to
treat
deicing
stormwater.
Question
2
also
indicates
the
corresponding
table
to
be
completed
for
the
detailed
deicing
stormwater
treatment
operation
information
requested
in
Question
5
of
this
section.

Question
3
requests
a
diagram
for
each
deicing
stormwater
treatment
system
used
to
treat
wastes
associated
with
deicing/
anti­
icing
operations.
These
diagrams
would
identify
all
sources
entering
the
treatment
system;
deicing
stormwater
destinations;
any
chemical
additions
and
recycle
streams;
the
locations
of
sludges,
oils,
and
wastes
leaving
the
system;
and
the
location
of
any
deicing
stormwater
sample
points.
In
addition,
the
diagram
would
specify
annual
effluent
flow
rates
and
show
the
specific
location
of
the
chemical
addition.
This
information
would
be
necessary
to
understand
the
individual
deicing
stormwater
treatment
processes
in
order
to
contribute
to
developing
technology
options
and
associated
designs,
regulatory
options,
and
compliance
cost
estimates.
A
checklist
and
two
example
diagrams
are
provided
following
the
question
instructions
to
ensure
that
each
deicing
stormwater
treatment
system
diagram
is
complete.

Question
4
requests
information
on
deicing
stormwater
treatment
units
used
by
the
airport
to
treat
deicing
and/
or
anti­
icing
stormwater
in
the
last
three
winter
seasons.
This
question
is
divided
into
six
subsections
(
A­
F)
in
a
table
format
describing
different
deicing
stormwater
treatment
unit
processes
and
operations.
Only
one
or
a
few
of
these
subsections
would
be
applicable
to
any
single
airport.
For
example,
an
airport
with
an
equalization
unit
and
no
other
treatment
units
would
need
to
complete
only
Subsection
A,
Equalization.
Information
requested
under
each
subsection
includes
unit
specifications,
information
regarding
all
influent
and
effluent
flows
(
solids
and
liquids),
and
chemical
additions
if
applicable.
This
information
would
be
used
to
develop
the
designs
of
individual
unit
operations
for
development
of
technology
options
and
regulatory
compliance
and
cost
estimates,
and
to
develop
appropriate
best
management
practices.

Question
5
requests
actual
operating
and
maintenance
costs
paid
and
rates
for
each
deicing
stormwater
treatment
system
during
the
last
three
winter
seasons
and
is
in
a
table
format.
Costs
include
operating
labor,
training,
maintenance
equipment
and
services,
laboratory
costs,
chemical
costs,
and
sludge,
oil,
or
other
residual
disposal
fees.
Data
from
this
question
would
provide
the
best
available
information
on
operation
and
maintenance
costs
associated
with
19
existing
deicing
stormwater
treatment
systems
and
would
be
used
to
develop
compliance
cost
estimates.
This
information
would
be
used
to
estimate
incremental
operating
and
maintenance
costs
for
each
airport
to
comply
with
each
technology
option.

Whether
the
airport
plans
to
add
any
deicing
stormwater
treatment
operations
to
treat
deicing
stormwaters
in
the
future
is
requested
in
Question
6.
Responses
to
this
question
could
indicate
trends
in
the
industry.

Question
7
provides
an
opportunity
for
the
respondent
to
comment
on
questionnaire
responses
in
this
section.

Section
5.
Analytical
Data
Questions
1
through
3
request
information
concerning
the
availability
of
deicing
stormwater
characterization
data,
receiving
water
in­
stream
monitoring
data,
and/
or
data
characterizing
the
effectiveness
of
treatment
of
deicing
stormwater.
Questions
1
and
2
require
a
yes/
no
answer
and
ask
whether
deicing
stormwater
samples
were
collected
and
analyzed
to
characterize
any
untreated,
treated,
partially
treated,
treatment
residuals,
and
paired
influent
and
effluent
deicing
stormwater
generated
by
each
airport.
Question
3
is
in
a
table
format
and
requests
information
on
the
pollutants
monitored
and/
or
sampled,
including
sampling
points,
analytes,
and
sampling
frequency.
Responses
to
these
questions
would
indicate
whether
and
what
sampling
data
are
available
for
potential
use
by
EPA.
EPA
would
then
follow
up
with
selected
airports
to
request
specific
long­
term
monitoring
data.
EPA
would
use
this
information
to
determine
current
deicing
stormwater
discharge
characteristics
for
an
airport,
to
evaluate
deicing
stormwater
treatment
performance,
to
estimate
pollutant
discharge
loadings,
and
to
characterize
behavior
of
the
discharge
in
the
receiving
water
body.
Information
collected
from
these
questions,
coupled
with
deicing
stormwater
treatment
system
design
and
operating
data
collected
from
Section
4,
would
be
used
to
assess
the
performance
of
deicing
stormwater
treatment
technologies
and
to
help
assess
environmental
impacts.

Question
4
provides
an
opportunity
for
the
respondent
to
comment
on
questionnaire
responses
in
this
section.

Section
6.
Pollution
Prevention
Practices
Section
6
requests
information
to
evaluate
the
status
of
pollution
prevention
practices
for
each
airport,
and
to
identify
pollution
prevention
technologies.
EPA
would
use
this
information
to
identify
appropriate
practices
that
may
become
part
of
regulatory
options
yet
to
be
developed
and
to
prepare
an
industry
profile
of
pollution
prevention
practices,
and
also
potentially
allow
EPA
to
assess
their
impact
on
deicing
stormwater
generation
rates.

Questions
1
through
10
request
a
description
and
costs
and/
or
savings
of
implementing
specific
pollution
prevention
practices.

Question
11
asks
if
future
pollution
prevention
practices
are
planned
and
asks
the
respondent
to
list
the
practice(
s)
and
the
scheduled
implementation
date.
In
response
to
industry
20
comment,
EPA
has
added
a
question
(
Question
12)
asking
for
a
description
of
pollution
prevention
practices
considered
but
rejected
by
the
airport
and
details
on
why
a
particular
practice
was
rejected.

EPA
would
use
responses
to
Questions
1
through
12,
supplemented
by
responses
to
preceding
questions,
to
develop
any
necessary
and
appropriate
best
management
practices
applicable
to
airports
handling
deicing
stormwater
and
to
determine
industry
trends.

Question
13
provides
an
opportunity
for
the
respondent
to
comment
on
questionnaire
responses
in
this
section.

PART
B.
AIRPORT
FINANCIAL
AND
ECONOMIC
INFORMATION
Section
1.
Ownership
and
Management
Structure
Questions
in
Section
1
characterize
the
ownership
and
management
structure
of
the
surveyed
airports.
Question
2,
airport
ownership,
is
particularly
important
for
determining
the
small
business
status
of
the
airport;
many
airports
are
city
or
county
owned,
and
their
small
business
status
will
be
determined
by
the
size
of
the
city
or
county.
Question
3
will
be
used
to
characterize
the
size
of
the
airport
(
financially)
relative
to
the
size
of
the
owning
entity.

Some
airport
management
teams
will
be
responsible
for
multiple
airports;
this
particularly
occurs
in
large
metropolitan
areas
where
the
same
ownership/
management
team
might
be
responsible
for
a
large
commercial
service
airport
as
well
as
smaller
airports
to
relieve
the
primary
airport
of
general
aviation
and
business
jet
operations.
Revenues
from
the
primary
airport(
s)
are
sometimes
used
to
subsidize
operations
at
the
reliever
airports,
and
capital
expenditures
at
the
smaller
airport
may
be
financed,
in
part,
by
the
primary
airport.
Thus,
to
accurately
project
impacts
to
the
owning
entity,
EPA
must
be
able
to
estimate
expenditures
at
all
airports
for
which
the
entity
is
responsible.
Thus,
Question
4
requests
the
identity
of
all
airports
for
which
the
management
team
is
responsible.

Question
5
asks
whether
the
airport
is
managed
directly
by
the
owning
entity
or
contracted
to
an
independent
airport
management
entity.
This
question
is
asked
in
order
to
be
able
to
characterize
airport
ownership/
management
patterns
for
the
purpose
of
the
industry
profile.

Questions
6,
7,
and
8
are
closely
related.
Airports
have
traditionally
used
a
residual
cost
approach
to
financial
management.
Under
a
residual­
cost
approach
airlines
are
contractually
responsible
for
any
revenue
short­
falls
in
a
cost
center.
Thus,
increased
airfield
costs
resulting
from
improved
deicing
stormwater
treatment
might
be
directly
paid
for
by
airlines.
Conversely,
under
a
compensatory
approach,
airlines
are
not
legally
responsible
for
such
increased
costs.
Finally,
as
a
consequence
of
the
residual
cost
financial
management
approach,
airlines
that
sign
the
airport
use
agreement
typically
have
at
least
some
veto
power
of
airport
capital
spending
projects.
Thus,
the
relationships
examined
in
Questions
6
through
8
have
important
implications
for
how
airport
management
might
respond
to
a
potential
effluent
guideline.
21
Some
airport
management
teams
have
significantly
more
operational
authority
than
others.
For
example,
a
city­
owned
airport
may
delegate
day­
to­
day
operational
responsibility
for
the
airport,
but
significant
capital
expenditures
might
require
the
consent
of
the
city
council.
Question
9
determines
where
the
true
decision­
making
power
lies
for
capital
expenditures
at
the
airport.

Question
10
asks
for
airport
employment,
both
to
characterize
airport
size
and
to
examine
potential
impacts
of
an
effluent
guideline.
While
employees
of
concessionaires
and
other
airport
tenants
may
be
affected
by
the
rule,
the
airport
is
unlikely
to
know
their
employment
and
it
would
probably
be
a
significant
burden
to
them
to
require
them
to
contact
all
tenants
to
find
out
each
tenant's
employment.

Section
2.
Airport
Finances
Question
11
requests
airport
financial
information.
This
is
necessary
to
determine
the
preregulatory
financial
condition
of
the
airport,
as
well
as
current
capital
improvement
programs
that
may
affect
an
airport's
ability
to
undertake
additional
capital
expenditures.
This
is
also
necessary
to
project
the
potential
post­
regulatory
impacts
of
the
rule.
Although
Question
11
appears
to
be
large
and
burdensome,
EPA
anticipates
that
the
vast
majority
of
airports
already
provide
this
information
in
this
format
to
the
FAA.
Therefore
the
burden
of
this
question
to
those
airports
will
not
be
significant.
Airports
that
do
not
already
provide
this
information
to
FAA
will
tend
to
be
small
airports
with
relatively
simple
financial
statements.
Because
the
financial
information
is
requested
by
items
commonly
tracked
by
airports
for
internal
use
(
e.
g.,
landing
fees,
terminal
rents,
concession
income),
it
should
be
straightforward
for
those
airports
to
complete
Question
11.
Question
12
allows
EPA
to
match
the
financial
information
to
the
appropriate
time
frame
for
airline
operational
data.

Question
13
asks
for
operating
revenues
paid
by
commercial
airlines.
Cost
per
enplaned
passenger
is
a
measure
commonly
used
in
the
industry
to
determine
how
burdensome
an
airport's
cost
structure
is
to
user
airlines,
and
thus
how
competitive
the
airport
is
to
potentially
close
rivals.
Question
13
allows
EPA
to
determine
the
pre­
regulatory
airline
cost
per
enplaned
passenger,
and
estimate
the
post­
regulatory
cost
per
enplaned
passenger.
The
relative
change
in
cost
will
be
used
as
one
measure
of
the
potential
impact
of
the
rule
on
airports.

Traditionally,
many
airports
have
been
subsidized
by
county
or
local
government,
or
airport
revenues
may
legally
be
used
to
subsidize
associated
activities
such
as
transportation
infrastructure,
or
other
airports
owned
by
the
same
authority.
Questions
14
and
15
characterize
the
revenue
flows
from
such
subsidies.

Questions
16
and
17
will
allow
EPA
to
project
impacts
by
estimating
the
change
in
airport
landing
fees
necessary
to
pay
for
an
ADF
treatment
system
should
the
airport
pay
for
it
through
landing
fees.
EPA
intends
to
combine
airport
specific
landing
fees
from
Question
16
with
BTS
data
on
the
number
and
type
of
aircraft
landed
by
each
airline
at
each
airport
and
FAA
certificated
landing
weights
for
each
aircraft
type
to
project
changes
in
landing
fees
necessary
to
cover
compliance
costs.
The
increase
in
fees
will
be
another
measure
of
airport
specific
impacts,
and
the
increased
fees
paid
by
each
airline
will
be
utilized
in
projecting
airline
impacts.
Furthermore,
22
Question
18
ensures
that
there
is
no
agreement
in
place
that
might
make
it
impossible
for
the
airport
to
increase
landing
fees
in
a
timely
manner.

During
site
visits,
some
airports
have
indicated
that
it
would
be
very
difficult
for
them
to
increase
landing
fees
due
to
the
existence
of
nearby
airports
that
directly
compete
with
them.
Questions
19
and
20
are
designed
to
examine
this
issue.
Question
19
asks
the
airport
for
its
perceived
ability
to
increase
landing
fees
without
significantly
affecting
traffic
volume.
Question
20
asks
for
the
proximity
of
airports
that
may
be
considered
direct
competitors.

While
both
airlines
and
airports
suggested
in
comments
that
Question
19
was
more
appropriate
for
the
airline
questionnaire
rather
than
the
airport
questionnaire,
EPA
chose
to
leave
the
question
on
the
airport
questionnaire.
The
idea
for
the
question
came
from
a
site
visit,
where
airport
management
volunteered
to
EPA
that
it
was
very
reluctant
to
raise
landing
fees
for
fear
of
losing
substantial
traffic
to
a
nearby
airport.
Since
then,
EPA
has
discussed
this
topic
at
other
site
visits
and
has
found
airport
management
generally
has
a
good
sense
of
their
vulnerability
to
competition
from
neighboring
airports.

It
would
be
much
more
difficult
to
ask
this
question
of
airlines.
The
airline
perspective
differs
from
the
airport
perspective:
airline
management
can
state
if
their
airline
is
likely
to
reduce
service
in
response
to
increased
landing
fees,
but
this
tells
us
little
about
other
airlines'
responses.
EPA's
reason
for
asking
this
question
is
to
collect
information
on
how
likely
the
airport
is
to
raise
landing
fees
if
it
incurs
significant
costs
under
the
rule,
not
the
potential
response
of
a
single
airline
at
that
airport.
Further,
it
is
unclear
to
whom
this
question
may
be
asked
at
the
airline.
The
airline
station
managers
are
unlikely
to
be
able
to
answer
because
it
involves
managerial
decisions
well
outside
the
scope
of
their
responsibilities.
Each
airline
would
have
to
find
a
relatively
senior
manager
that
could
answer
the
question
for
all
airports
surveyed
for
that
airline.

Section
3.
Capital
Expenditures
Section
3
characterizes
funding
methods
for
current
airport
capital
expenditures,
as
well
as
anticipated
forms
of
funding
for
capital
improvements
related
to
the
treatment
of
ADF.
Question
21
asks
for
the
relative
importance
of
various
ways
of
financing
capital
expenditures.
As
this
is
primarily
a
profile
question,
EPA
reduces
the
burden
of
the
question
by
asking
the
respondent
to
use
readily
available
information
rather
than
to
make
a
detailed
calculation.

While
EPA
assumes
the
FAA
Airport
Improvement
Program
(
AIP)
grants
will
not
be
available
to
finance
capital
improvements,
an
airport
may
be
able
to
assess
Passenger
Facility
Charges
(
PFC).
Question
22
determines
how
close
the
airport
is
to
the
maximum
PFC,
and
for
how
long
those
funds
are
committed;
Question
23
determines
how
far
into
the
future
AIP
funds
are
committed.

Question
24
asks
the
respondent
to
characterize
the
percentage
of
compliance
costs
that
would
be
passed
through
to
different
types
of
tenants.
While
EPA
anticipates
costs
would
be
passed
through
to
airlines
in
the
form
of
higher
landing
fees,
this
question
will
aid
EPA
in
determining
if
its
assumption
is
accurate.
23
Question
25
requests
the
airport's
debt
service
coverage
ratio,
as
well
as
the
relevant
numerator
and
denominator
used
for
the
calculation.
The
debt
service
coverage
ratio
is
widely
used
in
the
industry
to
assess
airports'
credit
worthiness.
First,
using
the
pre­
regulatory
ratio,
EPA
will
be
able
to
assess
if
the
airport
would
have
access
to
debt
financing
to
pay
for
deicingrelated
capital
improvements.
Second,
EPA
can
estimate
each
airport's
post­
regulatory
ratio
to
determine
if
the
effluent
guideline
financially
stresses
any
airports.
EPA
requested
the
net
revenue
and
net
debt
figures
for
calculating
the
ratio
because
review
of
publicly­
available
financial
statements
demonstrated
that
airports
make
adjustments
to
revenues
and
debts
for
the
purpose
of
calculating
the
ratio
that
EPA
could
not
make
based
on
data
collected
in
other
parts
of
the
questionnaire.

Section
4.
Airport
Operations
In
Section
4,
EPA
requests
information
about
airport
operations.
EPA
anticipates
collecting
airport
operational
data
for
commercial
air
carriers
using
BTS
databases.
However,
the
publicly­
available
data
for
other
airport
user
types
(
military,
air
taxi
and
general
aviation)
is
less
reliable.
In
addition,
anecdotal
evidence
suggests
that
these
airport
users
add
little
to
airport
deicing
operations
since
they
tend
to
be
hangered
in
bad
weather,
and
rarely
fly
in
weather
requiring
significant
deicing.
Question
26,
in
addition
to
asking
for
operations
for
these
types
of
aircraft,
asks
whether
they
are
typically
hangered
in
bad
weather.

Question
27
requests
the
airport's
financial
statement.
This
will
be
used
to
obtain
additional
details
concerning
airport
financial
management,
including
atypical
fluctuations
in
revenues,
expenses,
or
capital
expenditures.
It
will
also
be
used
to
obtain
the
airport's
bond
ratings
and
interest
rates
paid
on
recent
bond
issues
to
determine
the
airport's
cost
of
capital.

(
b)
Airline
Screener
Questionnaire
Although
airports
are
the
primary
dischargers
of
deicing
stormwater
and
may
be
the
only
parties
listed
in
some
discharge
permits,
airport
deicing
stormwater
is
generated
from
the
deicing
of
both
aircraft
and
airfield
pavement.
Deicing/
anti­
icing
of
aircraft
is
primarily
performed
by
the
airlines.
(
Some
states
include
airlines
in
permits
as
co­
permittees.)
EPA
needs
information
on
deicing/
anti­
icing
operations
performed
by
airlines
to
obtain
complete
information
on
deicing
operations
that
generate
airport
deicing
stormwater.

The
airline
screener
requests
information
on
who
performs
most
of
the
deicing/
anti­
icing
operations
on
an
airlines'
aircraft
including
the
name
of
another
airline,
FBO,
or
private
contractor
that
performs
this
service.
This
questionnaire
would
be
used
to
select
the
recipients
of
the
airline
detailed
questionnaire.
In
addition
to
identifying
potential
airline
detailed
questionnaire
recipients,
the
screener
would
also
indicate
the
potential
contribution
of
FBO's
to
deicing
operations
and
to
the
discharge
of
ADF­
contaminated
stormwater.
EPA
does
not
expect
any
of
this
information
to
be
CBI
and
did
not
include
CBI
check
boxes
on
the
screener
form.

Question
1
collects
information
that
identifies
the
name,
address,
etc.
of
the
airline
contact
to
verify
or
clarify
the
screener
information.
24
Question
2
asks
who
performs
most
of
the
deicing/
anti­
icing
operations
on
their
airline
aircraft
at
specific
airports
and
also
requests
the
name
of
another
airline,
FBO,
or
private
contractor.
This
question
is
in
a
table
format,
and
EPA
will
provide
the
names
of
the
specific
airports
in
the
table
for
each
airline
screener
recipient.

Question
3
provides
an
opportunity
for
the
respondent
to
comment
on
the
screener
questionnaire
responses.

(
c)
Airline
Detailed
Questionnaire
The
Airline
Detailed
Questionnaire
consists
of
two
parts.
Part
A
requests
airline
technical
information
about
deicing
and
anti­
icing
primarily
of
aircraft.
Financial
and
economic
information
is
requested
in
Part
B.
Each
of
these
parts
is
divided
into
sections.
At
the
end
of
each
section,
there
is
a
question
that
provides
space
for
the
respondent
to
add
comments
that
explain
or
expand
responses
to
questions
within
that
section.
A
detailed
description
of
the
questionnaire
questions
follows.

PART
A.
AIRLINE
TECHNICAL
INFORMATION
Section
1.
General
Airline
Information
Section
1
requests
general
information
about
the
airline.
Questions
1
to
4
collect
information
that
identifies
the
airline
name
and
address,
and
the
primary
and
secondary
contacts
to
verify
or
clarify
the
technical
questionnaire
information.

Question
5
provides
an
opportunity
for
the
respondent
to
comment
on
questionnaire
responses
in
this
section.

Section
2.
Airline
Deicing
and
Anti­
icing
Operations
Instructions
for
Sections
2
and
3
provide
a
list
of
the
airport
locations
for
which
the
airline
should
complete
the
questionnaire.
EPA
will
specify
the
airport
locations
for
which
information
is
requested
and
would
provide
the
number
of
copies
of
Part
A,
Sections
2
and
3
for
each
airport
location.
As
stated
in
part
B
of
this
statement,
we
will
utilize
airline
screener
questionnaire
results
to
select
the
airport/
airline
combinations
using
a
statistical
design
Section
2
is
designed
to
obtain
information
on
deicing/
anti­
icing
operations
performed
on
the
airlines'
aircraft
or
by
the
airline
for
another
airline's
aircraft
at
each
specified
airport.
Members
of
the
airline
industry
have
indicated
to
EPA
that
they
sometimes
perform
deicing
operations
on
other
airline's
aircraft
and
that
they
do
not
keep
separate
records
on
ADF
usage
between
their
aircraft
and
others.
Additionally,
members
of
the
airline
industry
have
also
indicated
that
it
will
be
difficult
for
them
to
obtain
ADF
usage
information
and
that
they
will
have
better
access
to
ADF
purchasing
information.
Therefore,
industry
has
asked
EPA
to
request
airline
ADF
quantitative
data
as
total
ADF
amounts
purchased
for
use
on
their
own
aircraft
or
others.
25
Question
1
requires
a
yes/
no
answer
and
asks
whether
the
airline
performed
deicing
and/
or
anti­
icing
operations
on
their
aircraft
during
any
of
the
last
three
winter
seasons.
EPA
would
use
this
information
to
identify
airlines
that
should
fill
out
the
questionnaire;
airlines
that
had
no
deicing/
anti­
icing
operations
performed
on
their
aircraft
would
not
complete
the
rest
of
the
questionnaire.
Also,
EPA
would
use
the
information
from
this
question
in
the
industry
profile
of
airlines
that
performed
deicing/
anti­
icing
operations
during
the
last
three
winter
seasons.

The
location
of
deicing
operations
is
requested
in
Question
2.
Questions
3
and
5
ask
if
the
airline
performs
deicing
operations
on
their
own
aircraft
and
whether
they
deice
for
another
airline,
respectively.
The
types
of
equipment
used
to
apply
aircraft
deicing/
anti­
icing
fluids
at
each
airport
are
requested
in
Question
4.
The
information
from
these
questions
would
aid
in
developing
an
industry
profile
of
ADF
application
methods
and
industry
trends
and
in
evaluating
differences
between
airline
deicing
operations.

The
type
of
deicing/
anti­
icing
practices,
ADF
chemicals,
amounts
purchased
or
used,
and
chemical
formulations
and
concentrations
are
requested
in
Questions
6
through
13
for
aircraft
deicing.
This
information
is
requested
for
three
winter
seasons
(
i.
e.,
2002/
2003,
2003/
2004,
and
2004/
2005)
to
address
the
variability
of
snow
events
across
seasons.
To
reduce
burden,
respondents
are
given
the
option
to
attach
chemical
usage
reports
in
lieu
of
completing
Questions
6
through
8
and
Questions
11
through
13.
Responses
to
these
questions
are
intended
to
provide
information
to
estimate
loadings
and
to
provide
EPA
with
information
on
the
types
of
ADFs
used.
These
data
will
help
to
characterize
the
deicing
stormwater
generated
at
airports
by
aircraft
deicing/
anti­
icing.
Responses
to
these
questions
would
also
be
evaluated
to
identify
and
select
among
those
pollutants
which
may
be
of
concern,
and
to
identify
opportunities
for
pollution
prevention
through
chemical
substitution
and
best
management
practices,
and
to
identify
trends
among
airports.
The
information
would
aid
in
developing
an
industry
profile
of
deicing
stormwater
generation
and
in
evaluating
differences
in
airport
deicing
stormwater
generation
and
characteristics.

Questions
6
through
8
request
information
on
chemicals
purchased
and
materials
and
practices
used
to
deice
the
airlines'
own
aircraft
and/
or
other
airline
aircraft.
Information
about
ADF
that
is
left
over
from
a
winter
season
is
also
requested
in
Questions
6
through
8
to
help
EPA
assess
whether
this
is
a
common
occurrence
and
to
determine
the
use/
disposal
of
left
over
ADF.
Consultations
with
airlines
on
the
draft
questionnaire,
indicated
that
chemical
usage
was
not
readily
available
and
that
the
amount
purchased
could
be
provided
by
airlines.
EPA
revised
these
questions
to
request
information
on
chemicals
purchased
rather
than
chemical
usage
per
industry
comments.
Some
airlines
may
have
deicing
chemical
usage
and
the
airlines
are
asked
to
provide
usage
information
if
it
is
available.

Questions
9
and
10
ask
whether
another
airline,
an
FBO,
or
a
private
contractor
deices
the
airline's
aircraft,
respectively.
If
an
FBO
or
private
contractor
deiced
the
airline's
aircraft,
the
airline
would
complete
Questions
11
through
13
that
request
the
ADF
amount
used,
formulation,
and
concentration
used
on
airline
aircraft
deiced
by
the
FBO
or
private
contractor
during
the
last
three
winter
seasons.
FBOs
have
indicated
to
EPA
that
they
provide
ADF
usage
information
in
their
invoices
to
the
airline's
for
whom
they
deice.
Therefore,
EPA
revised
the
questionnaire
to
request
this
ADF
usage
information
for
those
airlines
that
use
FBOs
or
private
contractors.
26
Question
14
provides
an
opportunity
for
the
respondent
to
comment
on
questionnaire
responses
in
this
section.

Section
3:
Pollution
Prevention
Practices
Section
3
requests
information
to
evaluate
the
status
of
pollution
prevention
practices
for
each
airline,
and
to
identify
pollution
prevention
technologies
at
each
specified
airport.
EPA
would
use
this
information
to
identify
appropriate
practices
that
may
become
part
of
regulatory
options
yet
to
be
developed
and
to
prepare
an
industry
profile
of
pollution
prevention
practices.
The
information
may
also
potentially
allow
EPA
to
assess
their
impact
on
deicing
stormwater
generation
rates.

Questions
1
through
10
request
a
description
and
costs
and/
or
savings
of
implementing
specific
pollution
prevention
practices.

Question
11
asks
if
future
pollution
prevention
practices
are
planned
and
asks
the
respondent
to
list
the
practice(
s)
and
the
scheduled
implementation
date.
A
description
of
pollution
prevention
practices
considered
but
rejected
and
why
they
were
rejected
is
requested
in
Question
12.

EPA
would
use
responses
to
Questions
1
through
12,
supplemented
by
responses
to
preceding
questions,
to
develop
any
necessary
and
appropriate
best
management
practices,
and
to
determine
industry
trends.

Question
13
provides
an
opportunity
for
the
respondent
to
comment
on
questionnaire
responses
in
this
section.

PART
B.
AIRLINE
FINANCIAL
AND
ECONOMIC
INFORMATION
Section
1.
Airline
Deicing
Costs
and
Operations
EPA
constructed
the
questionnaire
so
that
each
airline
would
only
have
to
answer
the
questions
in
Section
1
once.
Question
2
asks
for
the
airline's
financial
structure
so
that
EPA
can
calculate
the
correct
after
tax
compliance
costs
for
each
airline.
Question
3
will
be
used
to
characterize
public/
private
ownership
patterns
in
the
industry.
EPA
expects
this
will
vary
with
airline
size.

Questions
4
and
5
request
the
estimated
interest
rate
and
the
estimated
equity
rate
the
airline
expects
to
pay
to
finance
capital
improvements,
respectively.
Question
6
asks
about
the
mix
of
debt
(
Question
4)
and
equity
(
Question
5)
used
to
finance
capital
improvements.
Should
EPA
determine
that
airlines
may
incur
capital
costs
under
a
proposed
rule,
the
economic
analysis
will
use
these
data
to
annualize
those
costs.

All
certificated
carriers
must
submit
financial
information,
including
income
statement
and
balance
sheet,
to
the
BTS
(
biannually
for
small
certificated
and
commuter
carriers;
quarterly
for
large
certificated
carriers).
To
reduce
the
burden
to
industry,
EPA
will
obtain
essentially
all
other
airline
financial
information
from
BTS
rather
than
request
that
data
from
the
questionnaire.
27
However,
EPA
does
request
each
airline's
financial
statement
in
Question
7.
This
is
to
gain
access
to
notes
and
other
details
about
the
airline's
financial
status
that
are
not
necessarily
reflected,
or
readily
interpretable,
from
the
financial
data
downloaded
from
BTS.

Section
2.
Airport­
specific
Deicing
Costs
and
Operations
This
section
focuses
in
more
detail
on
operations
at
specified
surveyed
airports.
Questions
8
and
9
ask
about
airport­
specific
conditions
that
might
affect
airline
deicing
operations.
Question
8
asks
if
the
airport
is
an
operational
hub
for
the
airline.
At
hubs,
airlines
schedule
flights
in
"
banks"
to
allow
for
connections.
This
suggests
that
at
hubs,
deicing
operations
may
be
particularly
intensive
for
periods
of
time
as
the
airline
tries
to
deice
an
entire
bank
of
aircraft
for
departure
while
minimizing
delay.
Therefore,
deicing
costs
per
aircraft
might
be
higher
at
hubs
than
non­
hubs.
In
addition,
industry
has
told
EPA
that
deicing
costs
will
tend
to
be
higher
at
airports
where
a
large
number
of
aircraft
overnight.
These
aircraft
have
a
greater
opportunity
to
accumulate
a
significant
covering
of
ice
and
snow,
and
require
relatively
more
deicing
fluid
to
prepare
for
flight.
Therefore,
Question
9
asks
how
many
aircraft
typically
overnight
at
the
specified
airport.

Question
10
requests
the
airline's
airport­
specific
deicing
budget
for
the
2004/
2005
deicing
season.
EPA
would
prefer
to
use
actual
deicing
costs
rather
than
budgeted
costs.
However,
industry
has
stated
that
it
would
be
highly
burdensome
to
collect
cost
data.
EPA
chose
to
reduce
the
burden
on
industry
by
accepting
budget
rather
than
cost
data.
The
question
further
asks
the
respondent
to
indicate
the
expense
categories
included
in
the
budget.
However,
EPA
does
not
request
the
percentage
of
costs
attributed
to
each
category
to
reduce
industry
burden.

It
will
be
very
helpful
to
EPA's
understanding
of
deicing
processes
to
know
which
entities
are
responsible
for
deicing
operations
at
an
airport.
On
draft
versions
of
the
questionnaire,
EPA
requested
data
on
the
number
of
aircraft
deiced,
as
well
as
the
percentage
of
those
aircraft
deiced
by
other
airlines
and/
or
FBOs.
Industry
indicated
that
it
does
not
track
the
number
of
aircraft
deiced,
and
therefore
could
not
answer
those
questions.
EPA
modified
the
question
to
request
percentages
of
aircraft
deiced
in
relatively
broad
ranges,
without
asking
the
respondent
to
try
to
determine
in
detail
how
many
aircraft
were
deiced,
and
by
whom.
EPA
expects
this
question
can
be
answered
by
experienced
personnel
without
performing
burdensome
calculations.
Thus,
Question
11
meets
EPA's
goal
of
obtaining
information
about
deicing
patterns
by
entity
without
unduly
burdening
industry.

Question
12
asks
the
respondent
to
characterize
"
typical"
capital
expenditures
for
deicing
operations.
Because
purchases
of
certain
equipment,
such
as
boom
trucks,
probably
does
not
occur
every
year,
EPA
asks
for
the
average
capital
expenditures
over
the
most
recent
three
year
period.

Finally,
Question
13
asks
the
respondent
to
characterize
how
deicing
costs
have
changed
over
the
last
5
years.
This
question
is
designed
to
determine
if
there
are
particular
components
of
deicing
operations
costs
of
which
EPA
needs
to
be
aware.
28
(
d)
Record
Keeping
Requirements
There
are
no
record
keeping
requirements.

ii.
Respondent
Activities
Each
respondent
would
receive
Parts
A
(
Technical
Information)
and
B
(
Financial
and
Economic
Information)
of
either
the
detailed
airport
or
airline
questionnaires.
The
respondents
must
read
the
transmittal
letter
with
attachments
citing
authority
of
section
308
of
the
Clean
Water
Act
and
confidentiality
and
handling
of
any
responses
for
which
assertions
of
confidential
business
information
(
CBI)
may
be
made.
In
addition,
respondents
must
read
the
Introduction,
General
Instructions,
Definition
of
Key
Terms,
Abbreviations/
Symbols,
and
Certification
Statement
sections
in
the
beginning
of
Part
A
of
the
questionnaire.
The
Introduction
section
provides
the
purpose
and
use
of
the
questionnaire,
questionnaire
outline,
e­
mail
information,
how
to
return
the
questionnaire,
and
provisions
regarding
data
confidentiality.
The
General
Instructions
section
gives
the
respondent
guidance
on
completing
the
responses
and
including
attachments,
if
needed.
The
Definition
of
Key
Terms
provides
respondents
with
all
pertinent
definitions
and
acronyms
to
understand
and
complete
the
questionnaire.

The
questionnaire
respondent
would
have
to
read
and
understand
the
questionnaire,
plan
response
activities,
gather
information,
compile
and
review
information,
and
complete
the
questionnaire
form.
The
respondent
would
also
be
required
to
photocopy
and
retain
the
completed
questionnaire
form
for
up
to
one
year,
in
the
event
that
EPA
has
to
contact
the
respondent
for
clarification
of
any
response.

Sections
in
Part
A
of
the
airport
and
airline
detailed
questionnaires
require
the
respondent
to
consult
records
on
airfield
deicing
chemical
usage
or
ADF
purchase
in
the
2004/
2005,
2003/
2004,
and
2002/
2003
winter
seasons,
and
Section
4
in
Part
A
of
the
airport
questionnaire
requires
the
respondent
to
consult
records
on
deicing
stormwater
treatment
and
discharge
information.

To
complete
Part
B
of
the
questionnaire,
an
airport
would
need
access
to
cost
and
revenue
information
in
the
format
that
matches
the
FAA
form
(
if
the
respondent
submits
a
Form
5100­
127
to
FAA,
they
need
only
provide
a
copy
to
answer
that
part
of
the
questionnaire),
the
revenue
portion
paid
by
commercial
airlines,
a
list
of
landing
fees,
a
list
of
signatory
airlines,
net
revenues
and
net
debt
service
for
2004,
and
the
number
and
types
of
noncommercial
aircraft
based
at
the
airport.
An
airline
would
need
access
to
its
cost
of
capital,
deicing
budget
for
that
airport,
deicing
arrangements
at
that
airport,
and
purchases
of
deicing
capital
equipment
at
that
airport
within
the
last
three
years.

Respondents
to
the
airline
screener
questionnaire
would
provide
the
name
of
another
airline,
fixed­
base
operator,
or
private
contractor
performing
most
of
the
deicing/
anti­
icing
of
their
aircraft
at
specified
airports
provided
by
EPA.
29
5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
a.
Agency
Activities
The
Agency
has
conducted,
is
conducting,
or
would
conduct
the
following
activities
to
administer
the
airport
and
airline
detailed
questionnaires
and
the
airline
screener
questionnaire:


Development
of
two
detailed
questionnaire
questionnaires
and
one
screener
questionnaire;


Development
of
Federal
Register
Notices
(
FRNs);


Review
of
questionnaire
review
comments
provided
by
trade
associations,
industry
representatives,
EPA
workgroup,
OMB,
and
other
stakeholders;


Development
of
the
ICR;


Revisions
of
the
questionnaires
based
on
comments
from
trade
associations,
individual
airports
and
airlines,
EPA
workgroup
members,
OMB,
and
other
stakeholders;


Development
of
a
statistical
sample
design;


Development
of
a
mailing
list
database
and
mailing
labels;


Development
of
a
tracking
system
for
questionnaire
mail­
out,
receipt,
and
return
activities;


Mail­
out
of
questionnaires;


Development
and
maintenance
of
e­
mail
addresses
and
a
website
for
respondents
who
require
assistance
in
completing
their
questionnaire
which
includes
responding
to
questions
via
e­
mail
or
call
backs
and
documentation
of
the
contacts;


Development
of
a
database
for
questionnaire
responses;


Receipt
and
review
(
coding)
of
questionnaire
response;


Data
entry
and
verification;


Summarization
and
analysis
of
questionnaire
responses
(
industry
profile);
and

Performance
of
statistical
summaries
and
technical
analyses.

EPA
would
use
the
questionnaire
results
as
a
part
of
its
effort
to
develop
discharge
regulations
for
the
airport
deicing
category.
The
data
received
would
be
transferred
from
the
questionnaire
forms
to
a
master
database
for
future
use.
30
b.
Collection
Methodology
and
Management
Each
selected
airport
and
airline
would
receive
their
own
questionnaire.
Each
respondent
can
complete
the
questionnaire
by
legibly
handwriting
or
typing
the
responses
in
the
spaces
provided.
Electronic
versions
would
also
be
available
to
the
respondents
at
their
request.
The
questionnaire
would
be
sent
via
Federal
Express
or
comparable
carrier
to
ensure
a
point
of
contact
signs
for
and
receives
the
questionnaire
package.
Each
airport
and
airline
would
be
allowed
60
calendar
days
to
return
the
completed
detailed
questionnaire,
and
airlines
would
be
allowed
30
calendar
days
to
return
the
airline
screener
questionnaire.

One
e­
mail
address
for
the
technical
information
and
the
financial
and
economic
information
would
be
available
to
provide
assistance
in
completing
the
questionnaire
to
respondents
in
different
time
zones.
The
e­
mail
address
would
reduce
the
burden
to
the
questionnaire
respondents
by
providing
a
timely
response
to
any
inquiries
that
the
respondents
may
have.
The
e­
mail
address
would
also
reduce
any
misinterpretations
of
the
questionnaire
and
thus
decrease
the
burden
of
follow­
up
phone
calls
and
letters
to
the
respondents.
E­
mail
is
the
preferred
means
of
communication
because
airport/
airline
personnel
have
ready
access
to
this
resource.
EPA
or
its
representatives
would
contact
respondents
by
phone
upon
request.
In
the
questionnaire
assistance
section
of
the
questionnaire
introduction,
respondents
who
desire
assistance
by
telephone
are
instructed
to
send
an
e­
mail
with
"
Please
Call
Me"
in
the
subject
line.
They
are
also
instructed
to
provide
the
call­
back
phone
number,
desired
day
and
time
to
call,
and
an
indication
of
whether
the
questions
are
technical
and/
or
financial.
The
return
phone
call
would
be
timely
and
free
of
charge
to
the
respondent.
This
approach
would
save
both
the
Agency
and
the
respondent
time
by
avoiding
"
telephone
tag"
and
by
ensuring
appropriate
staff
(
e.
g.,
technical
or
economic)
reply
by
telephone.

Each
airport
and
airline
would
be
assigned
a
unique
identification
number
for
ease
of
tracking.
The
identification
number
would
be
used
to
track
the
mailing
date
of
the
questionnaire,
questionnaire
receipt
date,
follow­
up
letters
and
telephone
calls
to
respondents,
and
EPA's
receipt
of
the
completed
questionnaire.
The
identification
number
would
also
be
used
as
an
identification
code
for
data
entry
in
the
questionnaire
database.

Upon
receipt
of
completed
detailed
questionnaires,
EPA
and
EPA
contractors
would
review
the
questionnaires
for
completeness
and
accuracy
and
enter
data
codes
to
prepare
the
questionnaire
for
data
entry.
Follow­
up
calls
would
be
performed
as
needed
to
clarify
inconsistencies
in
airport
and
airline
responses,
and
to
remind
non­
respondents
of
the
requirement
to
complete
and
return
the
questionnaire.
The
coded
questionnaire
responses
would
be
entered
into
a
database.
This
database
would
then
be
used
to
perform
data
analysis.

c.
Small
Entity
Flexibility
The
detailed
technical
questionnaires
have
an
initial
question
asking
whether
or
not
deicing
operations
occur
at
the
airport
or
on
the
airline's
aircraft.
If
not,
the
respondent
is
relieved
of
the
burden
of
answering
the
rest
of
the
questionnaire.
This
would
eliminate
questionnaire
burden
for
small
and
very
small
airports
that
close
operations
in
inclement
weather
when
deicing
might
be
31
required
and
for
smaller
airlines
that
do
not
fly
in
inclement
weather.
However,
the
steps
taken
to
minimize
burden
on
all
respondents
(
see
Section
6(
a))
apply
to
small
entities
as
well.

d.
Collection
Schedule
The
schedule
for
the
questionnaire
distribution,
response
receipt,
and
data
collection
activities
is
provided
in
the
chart
below.
This
schedule
assumes
an
OMB
review
period
of
30
days.

Airport
Deicing
Survey
Schedule
9/
1/
05
10/
2/
05
11/
2/
05
12/
3/
05
1/
3/
06
2/
3/
06
3/
6/
06
4/
6/
06
1
OMB
Review
2
Mail
Airport
Questionnaires
3
Mail
Airline
Screeners
4
Receive
Screener
Responses
5
Mail
Airline
Detail
Quest
6
Receive
Airport
Responses
7
Receive
Airline
Detail
Resp
8
Complete
Survey
Follow­
up
9
Data
entry
of
survey
resp
10
Analysis
of
survey
responses
6.
Estimating
the
Burden
and
Cost
of
the
Collection
a.
Estimating
Respondent
Burden
Members
of
the
Agency's
airport
deicing
effluent
guidelines
project
team
share
experience
with
the
extensive
data
collection,
maintenance,
and
analysis
activities
associated
with
the
development
of
effluent
guidelines
and
standards,
and
they
worked
closely
with
airport
and
airline
trade
associations
and
FAA
that
have
detailed
knowledge
of
airport
deicing
to
eliminate
redundant,
unclear,
and
unnecessary
questions.
EPA
designed
the
questionnaire
instruments
to
be
as
user­
friendly
as
possible
by
requesting
data
in
the
form
and
units
in
which
respondents
have
already
collected
them.
EPA
revised
both
the
airport
and
airline
detailed
questionnaires
after
consultations
with
industry
and
industry
review
comments
indicated
some
information
requested
would
require
considerable
effort
to
compile,
was
unclear,
and/
or
was
not
available.
EPA
revised
the
questionnaires
using
terminology
suggested
by
industry
and
deleted
or
simplified
questions
to
reduce
the
burden
where
possible.
32
The
Agency's
airport
deicing
effluent
guidelines
project
team
designed
the
detailed
questionnaire
instruments
to
include
many
burden­
reducing
formatting
features:


Many
questions
are
formatted
in
"
check
box"
form
or
easy
to
read
tables.
Examples
are
provided
with
several
questions.


Questions
on
related
topics
are
grouped
together
in
the
questionnaire;


The
respondent
is
directed
to
skip
over
questions
not
relevant
to
their
operation
and
can
check
"
Unknown"
when
estimation
is
impossible
or
when
data
are
not
available
(
e.
g.,
pollution
prevention
questions);


The
airport
respondent
can
provide
existing
chemical
usage
reports
instead
of
completing
the
tables
requesting
the
type,
amount,
formulation,
etc.
of
the
deicing/
anti­
icing
chemicals
used
on
aircraft
and
airport
pavement;
and

Airport
respondents
can
provide
copies
of
permits
instead
of
completing
certain
table(
s)
for
pollutants
monitored
or
sampled.


Airports
have
the
option
of
submitting
a
copy
of
the
form
5100­
127
they
submit
to
FAA
rather
than
completing
the
cost
and
revenues
data.


EPA
obtained
Bureau
of
Transportation
Statistics
data
on
airport­
specific
departures
by
airline,
aircraft
type,
and
enplaned
passengers,
thus
relieving
the
burden
of
reporting
this
information
by
airports
and
airlines.


EPA
obtained
Bureau
of
Transportation
Statistics
data
on
airline
income
statements
and
balance
sheets,
thus
relieving
the
burden
of
reporting
this
information
by
airlines.

In
addition,
the
Agency
would
have
an
internet
e­
mail
address
where
a
respondent
may
request
assistance.

The
questionnaire
was
submitted
to
the
Airport
Transport
Association
(
ATA),
American
Association
of
Airport
Executives
(
AAAE),
and
Airport
Council
International
(
ACI),
environmental
interest
groups,
and
other
stakeholders
for
review
and
comment
and
to
estimate
the
total
number
of
burden
hours
to
complete
the
questionnaire.
The
burden
to
respondents
includes
the
time
necessary
to
read
and
understand
the
questionnaire
and
instructions,
plan
response
activities,
gather
information,
compile
and
review
information,
and
complete
the
questionnaire
form.

As
described
in
Sections
3(
b)
and
3(
c)
of
this
Information
Collection
Request,
EPA
provided
many
opportunities
for
comment
on
the
burden
to
respond
to
the
questionnaire.
EPA
received
two
comments
indicating
that
EPA
had
underestimated
the
burden;
EPA
received
two
comments
containing
a
quantitative
burden
estimate.
The
commenters
estimated
that
it
would
take
130
hours
per
questionnaire
to
complete
the
technical
portions
of
the
questionnaire
and
40
hours
to
complete
the
economic
portion
of
the
questionnaire.
One
commenter
estimated
it
would
33
take
14.5
full­
time
employees
90
days
to
complete
the
questionnaire.
EPA
believes
the
commenters
estimate
did
not
consider
that
the
airports
and
airlines
do
not
perform
multiple
and
complex
industrial
operations
or
treatment
controls.
The
information
requested
is
confined
to
deicing
operations
and
control
of
deicing
stormwater.
EPA
did
increase
the
burden
for
the
collection
of
airport
technical
information
and
financial
information
from
both
airports
and
airlines.

For
the
purpose
of
estimating
burden,
there
are
two
types
of
airports:
(
1)
airports
with
ADF­
contaminated
stormwater
treatment;
and
(
2)
airports
that
do
not
perform
deicing
or
for
which
deicing
operations
are
minimal.

Those
airports
with
ADF­
contaminated
stormwater
treatment
would
need
to
complete
additional
questions
regarding
the
treatment
system
design,
operation,
and
operating
costs,
resulting
in
an
increased
respondent
burden.
EPA
estimates
it
would
take
these
respondents
an
average
of
62
hours
to
complete
and
review
their
responses
to
the
questionnaire
and
associated
data
submissions.

For
those
airports
that
do
not
perform
deicing
or
for
which
deicing
operations
are
minimal,
EPA
expects
that
it
would
take
fewer
hours
to
complete
and
review
responses
to
the
questionnaire.
As
a
conservative
measure,
EPA
has
assumed
62
hours/
questionnaire
for
all
165
airports
to
be
surveyed.

For
the
recipients
of
the
airline
detailed
questionnaire,
EPA
estimates
it
would
take
an
average
of
21
hours
to
complete
and
review
the
questionnaire.

EPA
estimates
it
would
take
5.5
hours
for
the
airlines
to
complete
the
airline
screener
questionnaire
for
an
average
of
11
airport
locations.

EPA
would
distribute
detailed
questionnaires
to
165
airports
and
473
airport/
airline
combinations
where
deicing
is
performed.
Because
the
recipients
are
legally
obligated
to
complete
the
questionnaire
under
the
authority
of
Clean
Water
Act
Section
308,
EPA
expects
at
least
a
90
percent
response
rate.
EPA
estimates
that
the
total
burden
for
165
recipients
of
the
airport
questionnaire
would
be
approximately
10,230
hours.
EPA
estimates
that
the
total
burden
for
473
recipients
of
the
airport/
airline
combination
detailed
questionnaire
would
be
approximately
9,933
hours.
EPA
estimates
that
the
total
burden
for
the
125
airlines
responding
to
the
airline
screener
would
be
688
hours.
The
screener
burden
estimate
is
based
on
0.5
hours
to
provide
information
for
each
specific
airport
and
assumes
the
125
airline
screener
recipients
will
provide
the
information
for
an
average
of
11
airports.
Table
A.
6­
1
presents
the
average
hourly
and
total
burden
by
labor
category
associated
with
all
respondent
activities
necessary
to
complete
the
questionnaires.
34
Table
A.
6­
1.
Estimated
Respondent
Burden
to
Complete
the
Questionnaires
(
Hours)

Respondent
Activity
Environmental
Engineer
Accountant
Clerical
Support
Engineering
Manager
Financial
Manager
Lawyer
Total
Burden
per
Activity
(
Hours)

Airports
Read
Instructions
1
1
1
0.5
1.5
5
Gather
Information/
Data
25
2
3
30
Complete
Questionnaire
10
2
1
13
Review
Questionnaire
4
2
4
10
Provide
Follow­
up
Data
1
3
4
Estimated
Burden
for
Airport
62
Subtotal
of
Questionnaire
Burden
(
Average
Respondent
Hours
×
165
Airports)
10,230
Airlines
(
Screener
Questionnaire)

Complete
Questionnaire
3.5
2
5.

Subtotal
of
Screener
Burden
(
Average
Respondent
Hours
for
11
airports
×
125
Airlines)
688
Airlines
(
Detailed
Questionnaire)

Read
Instructions
1
1
1
0.5
0.5
4
Gather
Information/
Data
4
2
1
7
Complete
Questionnaire
1
2
1
4
Review
Questionnaire
2
2
2
6
Estimated
Burden
for
Airline
21
Subtotal
of
Questionnaire
Burden
(
Average
Respondent
Hours
×
473
Airlines)
9,933
Total
Respondent
Burden
(
Estimated
Hours
for
Airports
and
Airlines)
20,851
b.
Estimating
Respondent
Costs
i.
Estimating
Labor
Costs
The
direct
cost
to
respondents
to
complete
the
questionnaire
equals
the
time
required
to
read
and
understand
the
questionnaire,
gather
the
information,
compile
and
review
the
information,
and
complete
the
questionnaire
form.
An
e­
mail
address
would
be
operated
by
EPA
contractors
to
assist
airports
and
airlines
in
responding
to
the
questionnaires.
Material
costs
to
each
respondent
would
include
photocopying
and
postage.
Labor
costs
would
comprise
the
majority
of
the
financial
burden
imposed
on
the
industry.

The
Agency
estimates
a
cost
of
$
2,635
(
averaged
between
managerial,
professional,
and
clerical
staff)
for
each
airport
questionnaire
recipient,
$
842
(
averaged
between
managerial,
professional,
and
clerical
staff)
for
each
airline
detailed
questionnaire
recipient,
and
$
247
averaged
35
between
management
and
professional
staff
for
each
airline
screener
questionnaire
recipient.
EPA
estimates
the
total
cost
for
the
165
airports
would
be
approximately
$
434,775,
$
398,214
total
cost
for
the
473
airport/
airline
combination
detailed
questionnaire
recipients,
and
$
30,875
total
cost
for
the
125
airline
screener
questionnaire
recipients.
Table
A.
6­
2
presents
the
average
and
total
respondent
cost
to
complete
the
questionnaire
using
earnings
data
from
the
Bureau
of
Labor
Statistics,
National
Compensation
Survey
(
July
2003).
EPA
increased
the
median
hourly
earnings
by
31.25
percent
to
account
for
benefits.
The
total
respondent
labor
cost
to
complete
the
three
questionnaires
is
$
871,998.
36
Table
A.
6­
2.
Estimated
Respondent
Costs
to
Complete
the
Questionnaire
Respondent
Position
Bureau
of
Labor
Statistics
Occupation
Median
Hourly
Earnings
Median
Hourly
Earnings
Plus
Benefits
Average
Hours
O&
M
(
Dollars)
Total
Cost*

Airports
(
Detailed
Questionnaire)

Environmental
Engineer
Engineer,
n.
e.
c.
$
35.33
$
46.37
37
$
1,716
Accountant
Accountant
$
23.30
$
30.58
5
$
153
Clerical
Support
Typist
$
13.51
$
17.73
7
$
124
Engineering
Manager
Engineering
Manager
$
32.38
$
42.50
5
$
213
Financial
Manager
Financial
Manager
$
29.57
$
38.81
2.5
$
97
Lawyer
Lawyer
$
45.95
$
60.31
5.5
$
332
Estimated
Average
Cost
for
Airport
$
2,635
Subtotal
of
Questionnaire
Costs
(
Average
Respondent
Costs
×
165
Airports)
$
434,775
Airlines
(
Screener
Questionnaire)

Environmental
Engineer
Engineer,
n.
e.
c.
$
35.33
$
46.37
3.5
$
162
Engineering
Manager
Engineering
Manager
$
32.38
$
42.50
2
$
85
Estimated
Average
Cost
for
Airline
Screener
$
247
Subtotal
of
Screener
Questionnaire
Costs
(
Average
Respondent
Costs
×
125
Airlines)
$
30,875
Airlines
(
Detailed
Questionnaire)

Environmental
Engineer
Engineer,
n.
e.
c.
$
35.33
$
46.37
6
$
278
Accountant
Accountant
$
23.30
$
30.58
5
$
153
Clerical
Support
Typist
$
13.51
$
17.73
2
$
35
Engineering
Manager
Engineering
Manager
$
32.38
$
42.50
3
$
127
Financial
Manager
Financial
Manager
$
29.57
$
38.81
2.5
$
97
Lawyer
Lawyer
$
45.95
$
60.31
2.5
$
151
Estimated
Average
Cost
for
Airline
$
842
Subtotal
of
Questionnaire
Costs
(
Average
Respondent
Costs
×
473
Airport/
airline
combinations)
$
398,214
Total
Respondent
Labor
Costs
(
Estimated
Cost
for
the
three
questionnaires)
$
863,864
Total
Respondent
Labor
and
O&
M
Costs
(
Estimated
Cost
for
the
three
questionnaires
)
$
8134
$
871,998
Note:
Wage
rates
are
increased
by
31.25%
to
account
for
benefits.
*
Rounding
errors
involved
Source:
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics.
National
Compensation
Survey,
July
2003.
Supplementary
Table
2­
2.
Private
Industry:
Mean
Hourly
Earnings
and
Percentiles,
Full­
Time
Workers.
http://
www.
bls.
gov/
ncs/
ocs/
sp/
ncbl05040.
pdf,
downloaded
12
April
2005.

ii.
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs
Because
EPA
would
not
require
questionnaire
respondents
to
purchase
any
goods,
including
equipment
or
machinery,
to
respond
to
the
questionnaire,
the
Agency
does
not
expect
capital
costs
to
result
from
the
administration
of
this
data
collection
questionnaire.
Operation
and
maintenance
costs
include
only
photocopying
and
postage
for
the
completed
questionnaire.
37
iii.
Capital/
Start­
up
Operating
and
Maintenance
Costs
EPA
estimates
there
would
be
no
capital
or
start
up
costs
associated
with
responding
to
the
questionnaires.
Operating
and
maintenance
costs
include
only
photocopying
and
postage.
EPA
assumed
a
photocopying
rate
of
$
0.10
per
page
for
85
questionnaire
pages
and
150
SWPPP
pages
per
airport
respondent
for
a
total
photocopying
cost
of
$
23.50/
airport.
EPA
assumed
a
photocopying
rate
of
$
0.10
per
page
for
27
airline
detailed
questionnaire
pages
per
airport/
airline
combination
for
a
cost
of
$
2.70
per
airport/
airline
combination.
EPA
assumed
a
photocopying
rate
of
$
0.10
per
page
for
five
airline
screener
questionnaire
pages
per
airline
for
a
cost
of
$
0.50
per
airline.
EPA
assumes
the
respondents
would
return
the
completed
questionnaire
via
Federal
Express
or
a
comparable
delivery
carrier
that
requires
a
signature
to
acknowledge
receipt.
EPA
estimates
the
Federal
Express
Saver
rate
at
$
9.65
for
a
1­
lb
package
per
respondent
for
a
total
mailing
cost
of
$
1,592
for
airport
respondents
and
approximately
$
724
for
an
estimated
75
corporate
airline
detailed
questionnaire
respondents.
EPA
estimates
the
Federal
Express
Saver
rate
at
$
4.80
for
a
0.5
lb
package
for
a
total
mailing
cost
of
$
552
for
airline
screener
respondents.
Total
O&
M
cost
for
165
airports
is
estimated
at
$
5,470,
$
2,001
for
the
473
airport/
airline
combinations,
and
$
663
for
the
125
airline
screener
respondents.

iv.
Annualizing
Capital
Costs
EPA
estimates
that
there
would
be
no
capital
costs
associated
with
responding
to
the
questionnaires.

c.
Estimating
Agency
Burden
and
Costs
Table
A.
6­
3
presents
an
estimate
of
the
burden
and
labor
cost
that
EPA
would
incur
to
administer
the
deicing
questionnaires.
The
table
identifies
the
collection
administration
tasks
to
be
performed
by
Agency
employees
and
contractors,
with
the
associated
hours
required
for
each
grouping
of
related
tasks.
EPA
determined
Agency
labor
costs
by
multiplying
Agency
burden
figures
by
the
hourly
Agency
labor
rate
of
$
65.19.
EPA
determined
this
rate
by
dividing
the
2005
Washington­
Baltimore­
Northern
Virginia,
DC­
MD­
PA­
VA
(
DCB)
GS­
13,
Step
5
rate
of
$
84,751
by
a
person­
year
of
2,080
hours,
and
then
multiplying
the
result
by
a
benefits
multiplication
factor
of
1.6.
EPA
determined
contractor
labor
costs
by
multiplying
contractor
burden
figures
by
an
average
contract
labor
rate
of
$
74.27.
This
rate
is
consistent
with
current
Agency
contracts.
Table
A.
6­
4
presents
an
estimate
of
the
total
Agency
cost
including
estimates
of
the
one­
time
operating
and
maintenance
costs
associated
with
photocopying
and
postage.
EPA
estimated
O&
M
costs
based
on
experience
with
similar
collections.
Total
Agency
costs
(
including
contractor
and
O&
M
costs)
are
estimated
at
$
612,454.
Labor
costs
for
responding
to
comments,
revising
the
questionnaire,
and
analyzing
questionnaire
responses
contribute
to
the
majority
of
total
costs.
38
Table
A.
6­
3.
Estimated
Agency
Burden
and
Labor
Cost
Activities
Burden
(
hours)
Labor
Cost*

Agency
Contractor
Total
Hours
Agency
($
65.19/
hr)
Contractor
($
74.27/
hr)
Total
Cost
Develop
the
questionnaire
instruments;
Provide
the
draft
questionnaire
instruments
to
industry
trade
associations
for
review;
Meet
with
trade
association
representatives;
Publish
notice
of
anticipated
ICR
in
Federal
Register;
Respond
to
all
comments
received;
Revise
questionnaire
instrument
based
on
reviewers'
comments.
470
460
930
$
30,639
$
34,164
$
64,804
Design
sampling
frame
Develop
a
mailing
list
database;
Develop
a
system
to
track
mailing
and
receipt
activities;
Mail
questionnaire
instruments.
75
550
625
$
4,889
$
40,849
$
45,738
Develop
and
maintain
e­
mail
helpline
address
80
150
230
$
5,215
$
11,141
$
16,356
Maintain
response
tracking
system;
Implement
appropriate
procedures
for
handling
CBI
responses;
Review
and
code
responses;
Collect
missing
information.
Engineering
and
economic
followup
to
clarify
responses
to
questionnaire
and
request
specific
analytical
data.
350
5,000
5,350
$
22,817
$
371,350
$
394,167
Develop
questionnaire
database
Enter
and
verify
data
10
1,050
1,060
$
652
$
77,984
$
78,635
TOTAL
985
7,210
8,195
$
64,212
$
535,487
$
599,699
*
Note:
Rounding
errors
involved.

Table
A.
6­
4.
Estimated
Agency
Total
Cost
(
Labor
and
O&
M)

Agency
Contractor
Total
Agency
and
Contractor
Cost
Labor
Costs
$
64,212
$
535,487
$
599,699
O&
M
Costs
$
3,625
$
9,130
$
12,755
Total
Labor
and
O&
M
Costs
$
67,837
$
544,617
$
612,454
39
d.
Estimating
the
Respondent
Universe
and
Total
Burden
Costs
EPA
estimates
a
total
burden
of
20,851
hours
and
a
total
labor
and
O&
M
cost
of
$
871,998
for
all
respondents.
See
Tables
A.
6­
1
and
A.
6­
2.

e.
Bottom­
Line
Burden
Hours
and
Cost
Tables
The
upper
bound
estimate
with
677
detailed
questionnaires
and
questionnaire
follow­
up
information
requests
to
clarify
questionnaire
responses
is
20,851
hours
and
$
871,998
for
the
respondent
community
and
8,195
hours
and
$
612,454
for
the
Agency.
See
Tables
A.
6­
1
through
A.
6­
4.

f.
Reasons
for
Change
in
Burden
Not
applicable.
This
is
a
new
collection.

g.
Burden
Statement
EPA
estimates
it
would
take
an
average
of
62
hours
and
$
2,635
for
airport
questionnaire
respondents,
21
hours
and
$
842
for
airline
detailed
questionnaire
respondents,
and
5.5
hours
and
$
247
for
airline
screener
respondents
to
complete
and
review
their
responses
to
the
questionnaire
and
associated
data
submissions.
This
estimate
is
based
on
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics'
National
Compensation
Survey
(
July
2003)
labor
rates
for
the
likely
range
of
personnel
involved
in
responding.

EPA
estimates
that
the
total
burden
for
the
three
questionnaires
would
be
approximately
20,851
hours,
or
$
871,998.
EPA
estimates
that
there
would
be
no
start
up
or
capital
cost
associated
with
the
questionnaires
described
above.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OW­
2004­
0038,
which
is
available
for
public
viewing
at
the
Water
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
40
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Water
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OW­
2004­
0038)
and
OMB
control
number
(
XXX)
in
any
correspondence.
41
PART
B
OF
THE
SUPPORTING
STATEMENT
1.
Questionnaire
Objectives,
Key
Variables,
and
Other
Preliminaries
a.
Questionnaire
Objectives
EPA
has
identified
the
airport
deicing
category
as
discharging
nontrivial
amounts
of
toxic
and
nonconventional
pollutants.
The
major
source
of
pollutant
discharges
from
deicing
operations
is
stormwater
contaminated
with
deicing
agents
typically
containing
glycols
and
additives.
Review
of
current
or
proposed
discharge
permits
for
a
sample
of
airports
indicates
airports
with
stringent
permits
have
reduced
their
ADF
discharges,
but
there
is
significant
disparity
among
discharge
requirements.

This
Information
Collection
Request
includes
three
statistical
questionnaires:
two
detailed
questionnaires
(
one
for
airports
and
one
for
airlines)
and
one
airline
screener
questionnaire.
The
airport
and
airline
detailed
questionnaires
would
gather
information
on
deicing
operations
performed
on
aircraft
and
airfield
pavement
by
airports
and
airlines.
The
airline
screener
would
provide
information
that
would
be
used
to
select
recipients
for
the
airline
detailed
questionnaire.

The
primary
objectives
of
the
airport
and
airline
detailed
questionnaires
are
to:
(
1)
gather
and
update
existing
information
on
the
industry
profile
including
deicing
operations
and
deicing
stormwater
generation,
collection,
characterization,
management
and
treatment;
and
(
2)
determine
the
industry's
financial
and
economic
status.
EPA
would
use
this
information
to
develop
national
effluent
guideline
regulations
for
the
category.

b.
Key
Variables
EPA
would
collect
technical
and
financial/
economic
information
on
the
following
key
variables:


Airport
deicing
and
anti­
icing
operations;


Containment
of
ADF­
contaminated
stormwater;


Collection
of
ADF­
contaminated
stormwater;


Deicing
stormwater
discharge
practices;


Deicing
stormwater
treatment
operations
and
disposal
practices;


Pollution
prevention
practices;


Ownership
and
management
structure;


Airport
and
airline
finances;


Airport
capital
expenditures;
and

Airline
deicing
budgets.

See
Part
A,
Section
4(
b)(
i)
of
this
ICR
for
detailed
information
on
the
data
items
for
the
questionnaires.
42
2.
Sample
Design
This
information
collection
request
covers
one
survey
with
three
questionnaire
instruments.
One
instrument
(
detailed
questionnaire)
is
for
airports
and
two
instruments
(
screener
questionnaire
and
detailed
questionnaire)
are
for
airlines.
The
sampling
design
will
use
stratified
probability
samples,
augmented
with
judgement
samples.
First,
we
will
select
a
sample
of
airports
to
receive
the
airport
questionnaire.
Second,
from
publicly
available
information,
we
will
identify
the
airlines
that
use
the
airports
in
our
sample.
We
then
will
send
one
screener
questionnaire
to
each
airline's
corporate
headquarters
for
information
about
the
sampled
airports
used
by
that
airline
for
1000
departures
or
more.
Each
airline
screener
will
be
customized
to
identify
the
airports
used
by
that
airline,
and
for
which
we
need
information.
From
the
information
from
the
airline
screener
questionnaire,
we
will
select
a
sample
of
airport/
airline
combinations
to
receive
the
airline
detailed
questionnaire.
The
procedures
for
collecting
information
for
each
instrument
are
detailed
below.

a.
Airports
i.
Sample
Frame
The
sampling
frame
for
airports
was
developed
from
information
found
in
the
following
sources:


The
Bureau
of
Transportation
Statistics
T100
database;
and

The
National
Flight
Data
Center
database.

The
Bureau
of
Transportation
Statistics
(
BTS)
collects
data
from
Form
41,
Schedule
T­
100,
"
U.
S.
Air
Carrier
Traffic
and
Capacity
Data
By
Nonstop
Segment
and
On­
flight
Market"
and
Form
41,
Schedule
T­
100(
f),
"
Foreign
Air
Carrier
Traffic
and
Capacity
Data
by
Nonstop
Segment
and
On­
flight
Market."
The
T­
100
and
T­
100(
f)
reporting
systems
were
developed
to
provide
complete
and
accurate
data
regarding
domestic
air
travel
within
the
U.
S.
and
international
air
travel
between
the
U.
S.
and
foreign
countries.
The
T­
100
and
T­
100(
f)
databases
includes
traffic
data
(
passenger
and
cargo),
capacity
data
and
other
operational
data
for
U.
S.
air
carriers
and
foreign
air
carriers
operating
to
and
from
the
United
States.
At
the
most
detailed
level,
the
databases
provide
monthly
traffic
and
operational
data
for
each
air
carrier.
The
T­
100
database
is
not
based
on
sampled
data
or
data
questionnaires,
but
represent
a
100
percent
census
of
the
data.
Because
the
data
meet
the
BTS
data
quality
guidelines,
we
are
confident
that
the
data
are
appropriate
for
our
sample
frame.

Because
the
T100
databases
do
not
provide
much
data
about
general
aviation
and
noncommercial
airports,
we
also
used
the
National
Flight
Data
Center
(
NFDC)
database
which
contains
airport­
submitted
master
record
data
(
the
5010
program)
for
approximately
20,000
landing
facilities.
(
We
eliminated
duplicates
from
our
combined
database.)
The
NFDC
database
will
indicate
if
it
is
an
airport,
seaplane
base
or
other
type
of
facility,
but
not
the
airport
class
(
e.
g.,
hub).
Available
data
include
facility
type,
location,
contact
information,
airport
services,
navigational
information,
number
of
based
aircraft,
and
general
operations
data.
About
6,300
of
the
landing
facilities
are
seaplane
bases,
heliports,
balloon
ports,
and
similar
facilities.
Many
of
the
43
"
airports"
appear
to
be
little
more
than
privately­
owned
landing
strips,
many
of
which
are
probably
not
even
paved
(
e.
g.,
"
Ben's
Landing,"
"
The
Homestead").
Operations
data
are
submitted
by
the
airport,
not
the
airline,
and
while
much
of
it
appears
to
be
approximated
(
e.
g.,
many
of
the
numbers
are
suspiciously
"
round"),
it
may
be
the
best
source
of
data
for
air
taxi
and
general
aviation
operations.
Because
the
data
meet
the
FAA
data
quality
guidelines,
we
are
confident
that
the
quality
of
the
data
are
appropriate
for
our
sample
frame.

The
two
sources
identified
1,843
airports
that
existed
during
mid­
2003
through
mid­
2004.
The
following
identified
the
numbers
of
airports
by
type
as
defined
by
number
of
departures.

Table
B.
2­
1.
Airports
Identified
in
Data
Sources
Airport
Type
Number
of
Airports
Large
Hub
33
Medium
Hub
35
Small
Hub
68
Non­
Hub
235
Other
Non­
primary
134
General
Aviation
1,338
TOTAL
1,843
For
our
sample
frame,
we
retained
all
large
hubs
(
33)
and
medium
hubs
(
35)
because
they
account
for
80
percent
of
commercial
departures
and
enplanements,
and
most
(
90
percent)
are
jet
aircraft
which
are
more
likely
to
fly
in
weather
requiring
deicing
than
propeller­
driven
aircraft.
We
also
retained
all
small
hubs
(
68)
and
non­
hubs
(
235)
to
determine
typical
deicing
usage
and
related
costs.
In
addition,
we
retained
the
general
aviation
airports
(
3)
serving
cargo
carriers
(
i.
e.,
those
with
more
than
five
cargo
departures
per
day),
because
they
have
significant
jet
air
traffic
which
may
require
deicing.
We
excluded
all
other
general
aviation
(
1,335)
and
non­
primary
commercial
airports
(
134),
because
our
research
indicates
that
they
rarely
fly
in
deicing
weather.
As
a
result
of
this
refinement,
the
sample
frame
contains
only
374
airports.

We
considered
the
inclusion
of
military
airports
in
the
sample
frame,
but
are
separately
working
with
the
Department
of
Defense
to
obtain
information
about
deicing
operations.
Because
military
facilities
have
many
different
characteristics
(
e.
g.,
revenues
and
operating
expenses
are
different),
we
were
concerned
that
our
questionnaire
instrument
would
not
accurately
reflect
conditions
at
those
facilities,
and
thus,
other
data
collection
mechanisms
would
be
more
appropriate
than
this
questionnaire
effort.

Because
it
is
based
upon
data
from
BTS
and
FAA,
EPA
considers
the
resulting
sample
frame
of
374
airports
to
be
current,
reasonably
complete,
and
reasonably
free
of
duplication.
We
will
select
a
sample
from
this
sample
frame
for
the
airport
questionnaire.
44
ii.
Sample
As
shown
in
Table
B.
2­
2,
we
will
select
a
sample
of
airports
using
a
stratified
random
sample
design,
augmented
by
a
small
judgement
sample.

To
develop
the
stratified
random
design,
we
first
stratified
the
sample
frame
by
airport
type.
We
selected
all
airports
in
the
Large
Hub
(
33),
Medium
Hub
(
35),
and
Carrier
(
3)
strata
because
of
the
relatively
small
sizes
of
the
strata,
and
the
potentially,
relatively
large
contributions
of
deicing
fluid
discharges.

For
the
Small
Hub
and
Non­
Hub
strata,
we
further
stratified
by
the
size.
For
this
purpose,
we
defined
`
size'
as
the
number
of
departures.
We
included
all
airports
with
30,000
departures
or
more,
because
the
departure
size
overlapped
with
the
sizes
of
medium
hubs.
There
were
8
airports
in
this
category:
6
from
small
airports,
and
2
from
non­
hub
airports.
For
the
remaining
airports
with
less
than
30,000
departures,
we
stratified
into
two
approximately
equal
groups
based
upon
the
weather.
We
evaluated
one
year
of
weather
data
to
determine
the
number
of
days
with
1
inch
or
more
of
snow
or
freezing
precipitation
(
SOFP).
Fifteen
days
per
year
of
SOFP
provided
two
groups
(
strata)
of
about
the
same
size.
Because
the
weather
database
did
not
contain
information
for
Alaska,
Hawaii,
and
the
territories,
we
assigned
them
to
strata
by
assuming
that
all
airports
in
Alaska
had
15
or
more
SOFP
days,
and
Hawaii
and
the
territories
had
none.
We
then
selected
twice
as
many
airports
from
the
group
with
SOFP
with
15
days
or
more
per
year
because
this
group
is
more
likely
to
have
deicing
operations.

After
determining
the
statistical
sample
size,
we
adjusted
the
sample
upwards
by
nineteen
airports.
The
nineteen
airports
will
be
selected
from
the
SOFP
strata
for
the
Small
Hub
and
Non­
Hub
airports,
because
we
already
will
have
selected
all
the
airports
from
the
other
strata.
The
first
adjustment
incorporates
nine
additional
airports
for
a
possible
10
percent
non­
response
rate
from
the
SOFP
strata
for
Small
Hubs
and
Non­
Hubs.
This
assumption
of
a
10
percent
non­
response
rate
is
based
upon
a
typical
effluent
guidelines
questionnaire.
The
second
adjustment
is
for
a
judgement
sample
with
10
additional
airports.
Typically,
in
developing
effluent
guidelines,
we
identify
facilities
for
which
additional
information
would
be
useful,
but
were
not
captured
into
the
statistical
sample.
For
example,
industry
may
identify
a
facility
with
a
unique
treatment
system
for
which
we
need
data
to
evaluate
its
performance.
For
this
reason,
we
are
including
a
judgement
sample
of
airports.
We
will
develop
our
national
estimates
based
upon
the
statistical
sample
with
the
non­
response
adjustment,
and
will
use
the
data
from
the
judgement
sample
separately
in
a
qualitative
manner.
45
Table
B.
2­
2.
Number
of
Airports
in
Sample
Airport
Strata
Number
of
Airports
in:

Sample
Frame
Sample
Large
Hub
33
33
Medium
Hub
35
35
Cargo
Carriers
3
3
Small
Hub

30,000
departures
6
6
Non­
Hub

30,000
departures
2
2
Small
Hub
(
68
total
in
frame
including
small
hub
airports
above)

<
30,000
departures
and

15
SOFP
days
38
9
<
30,000
departures
and
<
15
SOFP
days
24
5
Non­
Hub
(
235
total
in
frame
including
non­
hub
airports
above)

<
30,000
departures
and

15
SOFP
days
99
36
<
30,000
departures
and
<
15
SOFP
days
134
17
Total
Statistical
Sample
146
Adjustment
for
Non­
response
by
Airports
in
Statistical
Sample
*
9
Judgement
Sample
10
TOTAL
AIRPORT
SAMPLE
165
*
Note:
Adjustment
includes
only
the
SOFP
strata,
because
we
have
selected
all
airports
in
the
other
strata.

b.
Airlines
i.
Airline
Screener
Questionnaire
Once
we
select
the
airport
sample,
we
will
identify
the
airlines
that
serve
the
sampled
airports.
This
information
is
publicly
available
and
described
in
Section
B.
2.(
a)(
i).
From
this
information,
we
will
select
all
airport/
airline
combinations
with
1,000
departures
or
more
for
the
sample
frame.
We
will
exclude
airport/
airline
combinations
of
less
than
1,000
departures
to
reduce
the
burden,
and
because
they
are
unlikely
to
have
a
substantial
impact
on
stormwater
discharges.

We
will
collect
information
about
all
airport/
airline
combinations
in
the
sample
frame.
For
purposes
of
estimating
the
airline
sample
size
and
burden
of
the
screener
questionnaire,
we
performed
a
sample
draw
based
upon
145
airports
(
i.
e.,
the
airport
sample
size
before
adjusting
1
The
number
of
airports
is
one
less
than
provided
in
Table
B.
2­
1.
For
this
analysis,
we
excluded
a
medium
hub
in
San
Juan,
Puerto
Rico
(
SJU),
because
our
databases
did
not
include
departure
information
for
this
airport.

46
for
non­
response
and
the
judgement
sample).
1
From
this
"
strawman"
sample,
we
identified
1,242
airport/
airline
combinations,
as
shown
in
Table
B.
2­
3.
Most
of
the
airport/
airline
combinations
are
located
at
airports
in
the
Large
and
Medium
Hub
strata.
Because
we
plan
to
select
all
airports
in
these
two
strata
and
the
Carrier
strata,
all
of
the
corresponding
airport/
airline
combinations
will
be
selected
into
any
sample
draw
for
the
airline
screener
questionnaire.
The
airport/
airline
combinations
for
the
Small
Hub
and
Non­
Hub
strata
will
change
in
each
sample
draw,
but
these
strata
contain
relatively
fewer
combinations
than
the
other
strata.
Thus,
because
the
strata
sample
sizes
will
remain
relatively
constant,
we
expect
the
final
sample
draw
to
have
approximately
the
same
sample
size
as
the
strawman
sample.

We
will
adjust
the
sample
size
to
include
an
estimated
67
airport/
airline
combinations
from
the
nineteen
additional
airports
selected
for
the
non­
response
adjustment
and
the
judgement
sample
of
airports.
In
addition,
the
strawman
sample
excluded
one
medium
hub
airport,
with
an
estimated
11
airport/
airline
combinations.
Thus,
the
total
sample
size
is
1320
(
i.
e.,
1242
+
67
+
11)
airport/
airline
combinations.

Table
B.
2­
3.
Estimated
Number
of
Airport/
Airline
Combinations
Airport
Strata
Airports
Airport/
Airline
Combinations
with
1000
or
More
Departures
Sample
Frame
Sample
Number
Average
Large
Hub
33
33
586
17.8
Medium
Hub
*
34
34
389
11.4
Cargo
Carrier
3
3
3
1.0
Small
Hub
68
20
160
17.8
Non­
Hub
33
55
104
1.9
SAMPLE
SIZE
*
145
1,242
8.6
Adjustment
for
SJU,
non­
response
and
Judgement
Sample
20
78
3.9
TOTAL
ADJUSTED
SAMPLE
SIZE
165
1,320
*
For
this
analysis,
we
excluded
one
medium
hub
(
SJU)
located
in
Puerto
Rico
because
we
did
not
have
the
number
of
departures.

To
reduce
the
airline
burden,
we
will
send
each
distinct
airline
one
screener
questionnaire
that
identifies
all
of
the
sampled
airports
for
which
that
airline
has
1,000
departures.
The
strawman
sample
consists
of
115
distinct
airlines.
The
distribution
about
this
average
is
highly
47
skewed,
as
shown
in
Table
B.
2­
4.
One
airline
would
report
for
68
airports;
while
71
airlines
would
each
report
for
four
or
fewer
airports.
On
average,
each
airline
would
be
asked
to
report
for
10.8
airports.
Because
the
final
sample
draw
will
be
slightly
different
than
the
strawman
draw,
we
have
assumed
that
the
screener
questionnaire
will
be
sent
to
125
distinct
airlines
for
purposes
of
burden
estimates.

Table
B.
2­
4.
Screener:
Number
of
Airlines
Reporting
for
Airport/
Airline
Combinations
Number
of
Airport/
Airline
Combinations
per
Airline
Number
of
Airlines
60­
68
3
50­
59
3
30­
49
10
20­
29
6
10­
19
10
5­
9
12
4
7
3
6
2
18
1
40
All
115
ii.
Airline
Detailed
Questionnaire
From
the
airline
screener
questionnaire
responses,
we
will
select
airport/
airline
combinations
for
the
detailed
questionnaire.
We
will
exclude
any
airport/
airline
combination
that
does
not
deice
its
planes.
For
the
remaining
combinations
that
deice
planes,
we
will
categorize
them
according
to
the
entity
that
performs
most
of
the
deicing
in
the
last
three
winter
seasons.
The
airport/
airline
combinations
will
be
placed
into
one
of
three
categories:
1)
combinations
that
perform
the
deicing
for
its
planes;
2)
combinations
that
contract
to
FBOs
for
deicing
services;
or
3)
combinations
that
contract
to
other
airlines
for
deicing
services.
We
will
restrict
eligibility
for
the
detailed
questionnaire
to
the
first
two
categories
where
deicing
is
performed
by
the
combination
or
a
FBO.
For
the
combinations
in
the
third
category,
we
will
assign
the
departures
to
the
combinations
that
perform
the
deicing
services
for
them.

After
assigning
departures
from
the
third
category
to
the
appropriate
airport/
airline
combinations,
we
will
stratify
the
resulting
sample
frame
by
departures,
as
shown
in
Table
B.
2­
5.
48
We
will
select
all
airport/
airline
combinations
with
at
least
20,000
annual
departures
(
i.
e.,
about
55
departures
per
day).
We
estimate
that
there
will
be
88
or
fewer
combinations,
because
our
data
sources
contain
88
possible
airport/
airline
combinations
before
considering
eligibility
due
to
deicing
operations
and
reassignments
due
to
the
third
category.
For
purposes
of
this
ICR,
we
will
assume
that
there
are
88
airport/
airline
combinations.

We
also
will
select
a
statistical
sample
of
300
airport/
airline
combinations
with
less
than
20,000
departures.
Because
the
response
rate
for
airport
affects
the
overall
response
rate
of
the
airport/
airline
combinations,
we
have
adjusted
our
original
sample
size
of
300
airport/
airline
combinations
by
20
percent.
This
adjustment
accounts
for
a
non­
response
rate
of
10
percent
by
airports
and
an
additional
10
percent
by
airport/
airline
combinations.
This
assumption
of
a
10
percent
non­
response
rate
for
each
group
is
based
upon
a
typical
effluent
guidelines
questionnaire.
This
adjustment
adds
another
60
airport/
airline
combinations
for
a
total
of
360
combinations.

Table
B.
2­
5.
Number
of
Airport/
Airline
Combinations
in
Detailed
Questionnaire
(
DQ)
Sample
Airport/
Airline
Strata
Sample
20,000
Departures
or
More
88
Less
than
20,000
Departures
300
Total
Statistical
Sample
388
Adjustment
for
Non­
response
for
the
Statistical
Sample
*
60
Judgement
Sample
25
TOTAL
AIRLINE
DQ
SAMPLE
473
*
Note:
Adjustment
excludes
the
first
stratum
because
all
units
will
be
selected
into
the
sample.

The
sample
of
360
airport/
airline
combinations
will
be
selected
in
proportion
to
the
total
number
of
departures
at
sampled
airports
of
each
size
(
i.
e.,
Large
Hub,
Medium
Hub,
Small
Hub,
and
Non­
Hub).
We
will
select
a
minimum
of
50
of
these
combinations
from
each
of
four
airport
sizes.
In
general,
we
will
limit
requests
from
any
one
airline
to
20
airports
or
less.
Most
airlines
will
be
requested
to
provide
information
on
much
less
than
20
airports.
(
See
Table
B.
2­
4
for
distribution
of
airport/
airline
combinations.)
We
will
select
the
airport/
airline
combinations
using
a
statistical
design
with
probability
proportional
to
the
square
root
of
size
(
i.
e.,
departures).
We
have
incorporated
size
into
the
sample
design,
because
airport/
airline
combinations
with
more
departures
are
likely
to
require
more
deicing
fluid
than
others.
This
sample
design
provides
the
larger
airport/
airline
combinations
with
a
greater
chance
of
being
selected
into
the
sample.

We
also
intend
to
select
25
additional
airport/
airline
combinations,
as
a
judgement
sample.
Typically,
in
developing
effluent
guidelines,
we
identify
facilities
for
which
additional
information
would
be
useful,
but
were
not
captured
into
the
statistical
sample.
Our
judgement
sample
may
include
some
small
or
foreign
airlines,
if
the
statistical
sample
does
not
provide
enough
49
information
about
them.
We
will
develop
our
national
estimates
based
upon
the
statistical
sample,
and
will
use
the
data
from
the
judgement
sample
separately
in
a
qualitative
manner.

c.
Precision
Requirements
In
developing
the
sample
design,
we
considered
the
precision
targets
and
non­
sampling
errors
for
the
estimates
resulting
from
this
data
collection.

i.
Precision
Targets
As
explained
in
Section
B.
2.(
a)(
ii),
for
airports,
we
will
select
all
of
the
airports
in
most
strata:
Large
Hubs,
Medium
Hubs,
Carriers,
Small
Hubs
with
30,000
departures
or
more,
and
Non­
Hubs
with
30,000
departures
or
more.
For
the
other
strata
(
SOFP
strata
for
Small
Hubs
and
Non­
Hubs),
the
sample
of
67
airports
will
provide
estimated
percentages
across
these
two
strata
within
plus
or
minus
10
percent.

Based
upon
an
assumption
that
all
possible
airport/
airline
combinations
would
be
eligible
for
selection
(
i.
e.,
all
combinations
have
deicing
operations),
the
sample
of
388
combinations
is
expected
to
yield
95­
percent
confidence
intervals
for
a
proportion
of
0.5
with
a
half­
width
of
plus
or
minus
0.05.

ii.
Response
Rates
In
developing
the
sample
design,
we
considered
both
unit
(
questionnaire)
and
item
(
question)
non­
response.
Non­
response
is
expected
to
be
relatively
low
for
this
survey
effort.
The
questionnaires
will
be
conducted
under
the
authority
of
Section
308
of
the
Clean
Water
Act,
which
requires
facilities
to
provide
the
information.
The
cover
letter
and
instructions
for
the
screener
and
detailed
questionnaires
will
explain
the
legal
authority,
responsibility
to
respond,
reasons
for
the
questionnaire,
and
penalty
for
non­
response.

While
we
expect
unit
response
rates
to
be
high,
we
adjusted
the
airport
and
airline
segments
for
an
estimated
non­
response
rate
of
10
percent
for
each
questionnaire.
This
assumption
of
a
10
percent
non­
response
rate
is
based
upon
a
typical
effluent
guidelines
questionnaire.
In
addition,
we
will
strive
to
improve
the
response
rates
by
reminder
letters
and/
or
telephone
calls.
If
possible,
we
will
obtain
the
endorsement
by
the
major
trade
associations.
We
recognize
that
some
non­
response
is
unavoidable,
and
in
past
questionnaire
efforts,
we
have
waived
the
duty
to
respond
in
extreme
and
rare
cases
(
e.
g.,
natural
disasters).
We
have
already
decided
to
exclude
airports
severely
impacted
by
Hurricane
Katrina.
We
will
evaluate
other
extreme
situations
if
they
arise.
Thus,
for
our
analyses,
we
plan
to
adjust
our
questionnaire
weights
for
any
remaining
non­
respondents.
Also,
we
will
review
publicly
available
information
(
e.
g.,
from
the
Bureau
of
Transportation
Statistics)
to
determine
if
non­
respondents
appear
to
have
different
characteristics
than
respondents.
We
will
examine
these
characteristics
both
for
the
entire
industry
and
for
subgroups
in
our
analyses.
If
we
find
any
differences
that
would
appear
to
affect
the
results,
we
will
assess
the
major
reasons
for
the
differences
and
will
incorporate
any
appropriate
adjustments
for
bias.
50
To
minimize
item
non­
response,
our
subject
matter
experts
have
worked
closely
with
industry
in
developing
questions
that
are
easy
to
understand
with
clearly
defined
and
familiar
terms;
are
formatted
in
a
logical
sequence;
and
request
data
that
are
readily
available
by
the
industry.
In
this
manner,
we
expect
to
minimize
inaccurate
or
incomplete
response
of
the
questions
that
can
occur
due
to
misunderstanding
or
misinterpretation
of
questions
and
the
unintentional
skipping
of
questions
by
respondents.
In
addition,
we
will
operate
an
e­
mail
helpline
to
assist
respondents
with
the
questionnaire.
After
receipt
of
the
completed
questionnaires,
we
plan
extensive
follow­
up
with
respondents
for
any
item
non­
response.
If
necessary,
we
will
impute
responses
to
key
questions
in
our
analyses.

iii.
Processing
Errors
Processing
errors
can
occur
when
responses
are
coded,
edited
and
entered
into
the
database.
The
design
and
implementation
of
the
questionnaire
would
employ
a
number
of
quality
assurance
techniques
to
reduce
the
frequency
of
such
errors.
These
techniques
include
the
following:


Use
double­
entry
keypunch
verification
on
all
detailed
questionnaires;


Perform
a
computerized
comparison
of
selected
responses
to
detect
inconsistencies
and
illogical
responses;


Perform
a
computerized
analyses
to
screen
for
out­
of­
range
and
inconsistent
numerical
values;
and

Perform
computerized
analyses
to
detect
missing
numerical
data
and
missing
units.

3.
Pre­
tests
and
Pilot
Tests
EPA
does
not
plan
to
pre­
test
the
questionnaires.
For
more
than
30
years,
EAD
has
conducted
surveys
of
numerous
industrial
sectors
to
collect
information
to
support
regulation
development
activities
in
the
effluent
guidelines
program.
While
EPA
develops
different
questionnaires
for
each
industry,
there
are
common
elements
for
all
industries.
We
collect
the
same
basic
information
such
as
information
about
processes,
treatment,
and
financial
status.
Thus,
when
EPA
develops
a
questionnaire
for
a
particular
industry,
it
generally
tailors
the
questions
for
specific
terms
and
processes
used
by
that
industry.
In
past
years,
EPA
has
relied
predominantly
on
active
participation
by
trade
groups
in
reviewing
the
questionnaires.
For
the
deicing
information
collection,
the
predominant
trade
associations
(
AAAE,
ACI,
ATA)
have
provided
detailed
comments
in
response
to
the
initial
Federal
Register
notice.
In
addition,
we
have
shared
our
revisions
with
them,
and
they
have
provided
additional
review
and
comment.
In
our
experience,
such
collaboration
generally
tends
to
better
reflect
the
industry
at
large,
than
pretests.
For
this
reason,
we
consider
additional
review
through
the
pretest
process
to
be
unnecessary
for
this
industry.
In
addition,
we
also
are
concerned
that
further
delays
for
pretesting
will
be
inconvenient
for
the
industry,
because
the
questionnaires
then
would
be
in
the
field
during
the
busy
deicing
season.
51
4.
Collection
Methods
and
Follow­
up
See
Part
A,
Section
5.
b.
of
this
ICR.

5.
Analysis
and
Reporting
Questionnaire
Results
a.
Data
Preparation
Upon
receipt
of
completed
questionnaires,
EPA
and
EPA
contractors
would
review
the
questionnaires
for
completeness
and
accuracy
and
enter
data
codes
to
prepare
the
questionnaire
for
data
entry.
Follow­
up
calls
would
be
performed
as
needed
to
clarify
inconsistencies
in
airport
and
airline
responses,
and
to
remind
non­
respondents
of
their
requirement
to
complete
and
return
the
questionnaire.
The
coded
questionnaire
responses
would
be
double­
key
entered
into
a
database.
Once
the
data
are
entered
into
a
database,
numerous
manual
and
electronic
QA
activities
would
be
performed
and
the
results
would
be
provided
to
engineering
and
economic
staff
for
further
resolution
and
documentation.
This
database
would
then
be
used
to
perform
data
analysis.

b.
Analysis
The
questionnaire
objectives
include:


Producing
narrative
and
quantitative
characterizations
of
airport
deicing
operations
and
deicing
stormwater
containment
and
treatment
technologies;


Identifying
best
management
and
pollution
prevention
and
source
reduction
activities
and
the
most
effective
deicing
stormwater
treatment
technologies;


Estimating
costs
of
regulatory
options
and
impacts;


Identifying
potentially
affected
environmental
resources
and
assessing
environmental
impacts;
and

Estimating
benefits
of
regulatory
options.

See
Part
A,
Section
2.
b.
of
this
ICR
for
a
detailed
discussion
of
the
technical
and
economic
analyses.

The
objectives
of
the
information
collection
can
be
achieved
by
our
statistically
designed
sample
survey
to
ensure
that
the
resulting
inferences
and
analyses
are
as
statistically
unbiased
and
as
precise
as
is
practicable.
We
will
apply
sample
weights
derived
from
the
statistical
sample
design
and
adjusted
for
non­
response.
Weighting
the
data
allows
inferences
to
be
made
about
all
eligible
facilities,
including
those
that
did
not
respond
to
the
questionnaires.
Another
advantage
is
that
weighted
estimates
have
smaller
variances
than
unweighted
estimates
(
i.
e.,
counts
of
the
52
responses).
Our
analyses
will
use
accepted
statistical
methods
for
survey
statistics,
such
as
those
described
in
Sampling
Techniques
(
Cochran,
1977)
and
Survey
Sampling
(
Kish,
1965).
We
will
use
the
data
from
the
judgement
sample
separately
in
a
qualitative
manner.
53
Appendix
A.
Summary
of
Comments
on
the
Public
Notices
for
the
Proposed
Information
Collection
for
Airport
Deicing
Operations
and
EPA's
Response
54
Summary
of
Comments
on
the
Public
Notice
for
the
Proposed
Information
Collection
for
Airport
Deicing
Operations
and
EPA's
Response
­
Technical
Sections
Questionnaire
Section
No./
Topic
Comment
Response
All
Sections/

Definitions/
Terms
Airport:

a.
Some
terms
are
confusing
(
e.
g.,
deicing
wastewater,
runway
deicing
vs.
airfield
pavement)

b.
Clarify
the
scope
and/
or
define:
airport
pavement,
deicing/

antiicing
day",
ramps,
aircraft
parking
apron,
aircraft
deicing
pads.

c.
Replace:
wastewater
with
stormwater,
cargo
facility
with
cargo
apron
areas.

d.
Distinguish
aircraft
deicing
events
from
pavement
deicing
events
in
the
two
questionnaires
e.
Define
treatment
f.
Define
utility
WW
Airline:

g.
Delete
definitions
that
do
not
appear
in
questionnaire.

h.
Use
definitions
consistent
with
FAA
regulations
(
e.
g.,

deicing/
anti­
icing
pads).

I.
Terms
needing
definitions:
toxic
chemicals,
pollution
management,
waste
reduction,
anti­
icing,

j.
Definitions
are
ambiguous
or
confusing:
anti­
icing,
deicing
WW,

glycol­
contaminated
WW,
stormwater,
facility,
recycle/
recovery,

source
reduction,
pollution
prevention.

k.
Same
as
e.
above
l.
Substitute
"
deicing­
impacted
runoff"
for
wastewater
as
defined
at
40
CFR
122.26(
b)
per
regulation
under
Sector
S
of
Multi­
Sector
General
Permit
Airport:

a.
Definitions
have
been
revised
to
address
comments.

b.
Deleted
use
of
the
terms
airport
pavement
and
deicing/
anti­
icing
day
and
revised
the
definition
for
aircraft
deicing
pad.

c.
Replaced
the
term
wastewater
with
"
deicing
stormwater".

Replaced
cargo
facility
with
cargo
apron
areas.

d.
EPA
has
called
out
these
events
separately
where
appropriate.

e.
The
section
on
deicing
stormwater
treatment
identifies
what
types
of
units
are
included
as
treatment.

f.
This
term
has
been
deleted
from
the
questionnaire.

Airline:

g.
Terms
not
used
in
the
questionnaire
have
been
deleted
from
the
definitions.

h.
EPA
has
provided
definitions
for
the
purpose
of
this
questionnaire.
The
deicing/
anti­
icing
pad
definition
has
been
revised.

i.
The
term
toxic
chemicals
has
been
deleted
from
the
questionnaire,
pollution
management
and
waste
reduction
terms
have
been
replaced
with
a
more
expansive
definition
for
pollution
prevention.
The
term
anti­
icing
is
defined.

j.
EPA
has
revised
the
definitions
to
address
the
ambiguous
or
confusing
terms
identified
by
the
commenters.

k.
The
airline
questionnaire
has
been
revised
and
no
longer
requests
information
on
treatment.

l.
EPA
has
replaced
the
use
of
the
term
wastewater
with
"
deicing
stormwater"
and
defined
this
term
in
the
definitions.
Questionnaire
Section
No./
Topic
Comment
Response
55
Burden
Airport:

a.
Need
200
hours
for
airport
questionnaire
(
130
technical,
40
economic,
30
legal
review).

b.
EPA
did
not
consider
variety
or
number
of
departments/
personnel
to
compile
data.

Airline:

c.
Airline
burden
did
not
consider
burden
to
provide
information
to
airports.

d.
Need
sample
design
to
assess
or
comment
on
airline
burden.

e.
Cost
burden
will
be
heavy
because
of
airlines'
past
and
anticipated
$
billion
losses.

f.
Same
as
b.
above
g.
Increased
burden
to
provide
data
not
available
in
format
requested
(
e.
g.,
type
and
quantities
of
ADF;
costs
by
material
type,

labor,
provider
of
deicing
service).

h.
Will
take
14.5
FTE
for
(
assumed)
90­
day
deadline
even
if
no
more
than
20
airports
per
airline
i.
Timing
of
questionnaire
response
in
late
summer
or
early
fall
coincides
with
busiest
period
for
personnel
managing
and
performing
deicing
operations.
Airport:

a.
EPA
does
not
agree
with
the
suggested
burden
related
to
completing
the
airport
questionnaire.
EPA
has
reassessed
and
refined
their
respondent
burden
estimate
for
the
airport
questionnaire.

b.
EPA
did
consider
the
types
of
personnel
required
to
assess
and
review
the
airport
questionnaire
in
their
updated
burden
estimate.

Airline:

c.
EPA
has
separated
the
information
required
from
airlines
and
airports
and
does
not
believe
that
airlines
will
be
required
to
provide
airports
with
information
to
complete
the
airport
questionnaire.

d.
EPA
provided
industry
with
an
overview
of
the
sample
design
during
the
May
2,
2005
EPA/
industry
meeting.

e.
EPA
requires
national
data
to
assess
ELGs
as
required
by
the
CWA.
The
data
requested
in
the
airline
questionnaire
is
not
available
through
other
databases.

f.
EPA
did
consider
the
types
of
personnel
required
to
assess
and
review
the
airline
questionnaire
in
their
updated
burden
estimate.

g.
EPA
has
revised
the
request
for
ADF
fluid
usage
to
ADF
purchase
in
response
to
industries
concerns
about
the
availability
of
the
information.

h.
EPA
does
not
agree
with
the
suggested
burden
related
to
completing
the
airline
questionnaire.
EPA
has
reassessed
and
refined
their
respondent
burden
estimate
for
the
airline
questionnaire.

i.
EPA
is
subject
to
the
requirements
of
the
ICR
process
and
is
striving
to
get
survey
approval
so
that
the
questionnaires
can
be
sent
prior
to
the
next
winter
season.
Questionnaire
Section
No./
Topic
Comment
Response
56
Best
estimates
Airport:

a.
Best
estimates
are
contrary
to
EPA's
statement
that
"
EPA
intends
that
responses
to
all
questions
be
based
upon
available
data
and
information".

b.
Estimations,
especially
for
operations
subject
to
significant
weather­
related
and
seasonal
variability,
would
be
unreliable
and
not
appropriate
bases
for
developing
regulations.

c.
%
Total
Glycol­
Contaminated
WW
Discharge:
Estimation
has
potential
to
mislead
EPA
assessment
of
ultimate
discharge
of
ADF.

Airline:

d.
Request
for
estimates
are
contrary
with
instructions
to
not
generate
new
or
different
data
and
increase
burden.

e.
Eliminate
estimate
requests
and
allow
respondent
to
indicate
data
are
not
available,
or
allow
estimate
without
label
of
"
best
engineering
estimate.
Airport:

a.,
b.,
and
c.

EPA
has
deleted
the
use
of
the
term
"
best
estimates".
EPA
intends
that
responses
be
based
upon
available
data
and
information.
EPA
has
added
options
to
identify
when
data
are
unknown
or
not
applicable.

Airline:

d.,
and
e.

EPA
has
deleted
the
use
of
the
term
"
best
estimates".
EPA
intends
that
responses
be
based
upon
available
data
and
information.
EPA
has
added
options
to
identify
when
data
are
unknown
or
not
applicable.

Airport
vs.
Airline
(
and
vice
versa)
as
source
for
requested
information
a.
Aircraft
deicing
operation
information
should
be
provided
by
airlines,
and
airports
should
provide
airfield
deicing
information.
a.
EPA
has
made
revisions
to
the
questionnaires
to
provide
a
clear
split
of
information
provided
by
airlines
versus
airports.
The
questionnaires
do
not
request
duplicative
data.

Questionnaire
Organization
Airline:

a.
Organize
questions
by
single
source
of
data
such
as
corporate
and
airport­
specific
rather
than
technical
and
financial.
Airline:

a.
EPA
has
continued
to
maintain
separate
questionnaire
parts
for
technical
information
versus
economic
information.
EPA
has
tried
to
respond
to
specific
question
organization
requests
within
specific
sections.

Time
basis
of
data
Airport:

a.
EPA
should
collect
chemical
use
data
for
a
period
of
three
years
instead
of
one
year
to
be
representative
(
Q.
4&
5).

b.
Period
of
time
for
airport
pavement
deicing
should
be
based
on
annual
use
rather
than
monthly
basis
(
Q.
20).
Airport:

a.
EPA
has
incorporated
this
recommendation
and
is
requesting
information
from
the
last
three
winter
seasons.

b.
EPA
is
requesting
annual
usage
data
for
airfield
pavement
deicing
chemicals.
Questionnaire
Section
No./
Topic
Comment
Response
57
Section
1/
General
Airport/
Airline
Information
Airport:

a.
Provide
option
of
roadway
intersections,
etc.
for
airports
that
may
not
have
street
addresses.

b.
Q.
21
Airfield
pavement
deicing:

­
Replace
"
who
performs
airfield
pavement
deicing.."
with
"
which
entities
are
responsible
for
performing..."

­
Add
airlines
and
tenants
to
response
as
airlines
perform
deicing
for
leased
terminal
pavement
area
c.
Q.
22
Aircraft
deicing:

­
Same
rewording
as
(
b)
above
for
aircraft
deicing
­
List
only
airport
and
airlines/
tenants
as
choices
and
add
Q.

whether
airport
uses
FBO.
Should
not
ask
airports
about
airline
use
of
FBO.

d.
Delete
Q.
23
requesting
list
of
airlines
performing
aircraft
deicing
and
obtain
list
from
other
source.

e.
Ask
if
ADF­
contaminated
snow
is
discharged
to
surface
waters.
Airport:

a.
EPA
has
incorporated
this
option.

b.
EPA
has
incorporated
these
changes.

c.
EPA
has
incorporated
these
changes.
However,
EPA
does
not
agree
that
airport
deicing
operation
managers
do
not
know
which
airlines/
FBOs
perform
deicing
at
their
airport.

d.
This
question
has
been
removed.
EPA
will
determine
the
list
of
airlines
performing
deicing
at
each
airport
through
the
telephone
screener
survey.

e.
EPA
has
incorporated
this
option.

Redundant
Questions
Airport:

a.
Delete
Q.
13
(
direct
discharge)
because
it
is
redundant
with
Q.
8
(
discharge
status).

Airline:

b.
Eliminate,
combine,
or
cross­
reference
redundant
questions
to
reduce
internal
contradictions.
(
e.
g.,
Q.
5,
Part
A,
Section
2
and
Q.

10,
Part
B,
Section
1
both
request
site­
specific
ADF
usage).
Airport:

a.
This
redundancy
has
been
eliminated.

Airline:

b.
This
redundancy
has
been
eliminated.

Permits
Airport:

a.
Q.
14­
16:
Multiple
permits
and
co­
permittees:

­
Specify
permit
for
stormwater
(
deicing
WW)

­
Add
lines
for
multiple
receiving
waters.

­
Add
lines
for
multiple
co­
permittees
Airport:

a.
EPA
has
incorporated
these
changes.
EPA
has
simplified
the
question
on
co­
permittees
to
only
ask
for
a
yes/
no
indication
of
whether
the
permit
includes
co­
permittees.

Weather
Data
Airport:

a.
Ask
if
weather
data
publicly
available
and
obtain
weather
data
from
existing
source
(
NOAA)
if
applicable
(
Q.
18).
Airport:

a.
EPA
has
revised
this
question
to
request
whether
the
airport
collects
airport­
specific
precipitation
(
type
and
amount)
data.
The
question
does
not
require
the
airport
to
submit
any
of
this
data.
Questionnaire
Section
No./
Topic
Comment
Response
58
Section
2/
Airport
Deicing
WW
Schematic
Flow
Diagram
Airport:

a.
Reword
to
request
sources
and
routing
of
"
stormwater
associated
with
industrial
activity"
instead
of
untreated
deicing/
anti­
icing
WW
as
"
treatment"
is
not
defined.

b.
Include
flow
from
potential
ADF
contact
to
point
of
discharge.

c.
Reword
2nd
check
off
to
label
and
identify
"
other
pollutant
sources
potentially
present
at
deicing/
anti­
icing
areas
consistent
with
your
SWPPP."

d.
Delete
requests
for
destination
of
untreated
deicing
WW
and
diversion
valves
to
wastewater
containment.

e.
Request
"
known"
average
final
effluent
discharge
and
delete
estimation
phrase.

f.
Add
indication
of
high/
low
glycol
concentration
and
request
airport's
definition
of
high/
low
concentration
as
definition
will
vary
among
airports.

g.
Remove
request
for
mass
balance
information.
Airport:

a.
EPA
has
revised
the
diagram
instructions
and
is
using
revised/
clarified
terms.

b.
The
diagram
instructions
ask
for
a
schematic
of
deicing
stormwater
sources
and
points
of
discharge.

c.
EPA
has
incorporated
this
revision.

d.
EPA
will
require
information
on
major
diversion
valves
and
deicing
stormwater
discharge
destinations
in
order
to
have
a
clear
understanding
in
how
the
airport
handles
its
deicing
stormwater.

e.
EPA
has
incorporated
this
revision.

f.
EPA
has
incorporated
this
revision.

g.
EPA
has
not
requested
mass
balance
information
in
the
questionnaire.
Questionnaire
Section
No./
Topic
Comment
Response
59
Section
2/
Aircraft
Deicing
Operations
Airport:

a.
Add
maintenance
hangar
ramp
areas
to
deicing
locations
(
Q.
2).

b.
Limit
request
for
deicing
equipment
to
respondents
that
identified
airports
as
responsible
for
deicing
in
Section
1,
Q.
22.

c.
Add
sodium
acetate
to
airfield
pavement
deicing/
anti­
icing
chemicals
(
Q.
5).

d.
Ask
the
percentage
of
anti­
icing
and
deicing
conducted
at
each
deicing
area.

e.
Ask
if
snow
melters
used
in
airfield/
airside
areas
direct
melted
snow
to
storm
drain,
surface
water,
or
diverted
for
treatment.

Airline:

f.
Locations
for
deicing:
See
b.
in
Definitions
above
g.
Deicing
chemical
use,
material,
practice
(
Q.
5):

­
Clarify
whether
gallons
applied
(
diluted)
or
as
purchased.

­
Clarify
whether
use
for
own
aircraft
or
other
carrier.

­
Quantity
of
ADF
per
season
may
not
be
available
at
some
locations.

­
Add
Type
III
ADF
currently
in
use.

­%
Concentration
or
Range
is
not
routinely
available
and
may
vary
with
weather
conditions.

­
Use
amount
ADF
purchased
instead
of
amount
used
for
quantity.

­
Add
"
Check
all
that
apply"
to
question
directions
or
move
nonchemical
deicing
practices
to
separate
question.

h.
Same
as
d.
above.
Airport:

a.
EPA
has
incorporated
this
revision.

b.
EPA
has
split
the
equipment
questions
by
airline
(
aircraft
deicing
equipment)
and
airport
(
airfield
deicing
equipment).

c.
EPA
has
incorporated
this
revision.

d.
EPA
is
not
requesting
this
information
since
we
do
not
believe
that
it
will
be
available
data.

e.
In
the
airport
diagram
and
in
Part
A,
Section
3,
Question
2,
EPA
requests
information
on
the
destination
of
snow
melt.

Airline:

f.
EPA
has
revised
the
list
of
deicing
areas
based
on
commenters
suggestions.

g.

­
EPA
has
revised
the
questionnaire
to
request
ADF
amounts
purchased.

­
EPA
has
questions
that
assess
whether
the
airline
deices
their
own
aircraft
and/
or
other
airline's
aircraft.

­
The
respondents
have
been
instructed
to
provide
available
data.

­
EPA
has
added
Type
III
ADF
to
the
list.

­
EPA
has
clarified
that
the
%
concentration
is
for
ADF
"
as
purchased"
not
"
as
used".

­
EPA
has
incorporated
the
directions
to
"
check
all
that
apply"

where
appropriate.

h.
EPA
is
not
requesting
this
information
since
we
do
not
believe
that
it
will
be
available
data.
Questionnaire
Section
No./
Topic
Comment
Response
60
Section
3/
Wastewater
Containment
Airport:

a.
Replace
"
operate
stormwater
containment
system"
with
"
implement
containment
measures"
(
Q.
1).

b.
For
WW
sources
(
Q.
2):

­
Remove
airport
parking/
roadways
as
these
areas
are
not
in
scope
for
questionnaire
and
are
municipal
operations.

­
Add
guidance
re:
other
potential
ADF
sources
that
are
not
deicing
areas
(
e.
g.,
snow
dumps,
utility
vaults,
adjacent
taxiways
and
runways)

c.
For
collection/
containment
methods
(
Q.
2):

­
Replace
detention
ponds
with
"
containment
ponds/
basins"
as
airports
may
have
ponds
for
flood
control
as
well
as
separate
ponds
for
ADF.

­
Change
drainage
system
(
too
broad)
to
"
stormwater
drainage
system".

­
Replace
collection
tanks
with
"
aboveground
storage
tanks/
vaults".

­
Differentiate
between:
(
1)
dedicated
collection
systems
and
retrofits
of
conventional
storm
drainage
systems;
(
2)
temporary
and
permanent
mechanisms
(
e.
g.,
diversion
valve
with
pond/
tank
vs.

block
and
pump).
Airport:

a.
EPA
has
simplified
this
language
to
read,
"
use
containment
measures"
(
Q.
1).

b.

­
EPA
has
incorporated
this
revision.

­
EPA
has
incorporated
the
revised
deicing
areas
and
has
added
snow
dumps
to
this
question.

c.

­
EPA
has
incorporated
this
revision.

­
EPA
has
incorporated
this
revision.

­
EPA
has
incorporated
this
revision.

­
EPA
has
incorporated
this
revision.

Section
3/
Segregation/
Recycling
of
Glycol­
Contaminated
WW
a.
Q.
3:
Rephrase
question
to
say
"
Does
the
airport
attempt
to
segregate
stormwater
based
on
actual
or
expected
glycol
concentration?
"

b.
Q.
4:
Discharge
destination
of
segregated
WW:

­%
total
WW
requires
mass
balance
which
is
not
endorsed;
should
request
only
known
annual
average
discharges
sent
to
various
locations.
See
Best
Estimate
comments
a.
and
b.

­
limited
amount
of
data
available
for
ultimate
fate
of
ADF.

­
See
(
f)
for
WW
flow
schematic
re:
requesting
airport
definition
of
high/
low
glycol
concentration.
a.
EPA
has
reworded
this
question
to
clarify
what
information
is
required.

b.

­
EPA
is
not
requesting
mass
balance
information
in
the
questionnaire.
EPA
has
added
questions
to
clarify
whether
an
airport
segregates
deicing
stormwaters
into
high
and
low
concentration
streams
and
what
percentage
of
glycol
in
the
stormwater
meets
each
category.
Questionnaire
Section
No./
Topic
Comment
Response
61
Section
4/
WWT
a.
Clarify
that
only
methods/
technologies
for
reducing
pollutant
loads
from
deicing
operations
are
requested
(
e.
g.,
eliminate
O/
W
separators
and
sedimentation
ponds).
See
e.
in
Definitions.

b.
Clarify
if
recycling
is
included
in
WWT
section
(
airport
association
supports
inclusion).

c.
Q.
3
WWT
Diagram:
What
is
meant
by
utility
wastewater?

d.
Q.
4:
Delete
technologies
that
are
not
designed
or
will
not
treat
glycols,
acetates,
or
other
ADF.

e.
Q.
5:
O&
M
Costs:

­
Provide
cost
estimation
methodology
­
Request
all
capital
and
indirect
costs
,
not
just
O&
M
­
Ask
if
costs
represent
new
construction
or
a
retrofit
a.
EPA
considers
deicing
stormwater
collection
or
detention
in
a
tank,
pond,
or
lagoon
to
be
a
form
of
treatment
and
is
requesting
information
on
those
types
of
units.
EPA
has
clarified
this
issue
in
the
Deicing
Stormwater
Treatment/
Recovery
section
of
the
questionnaire.

b.
EPA
has
clarified
that
recycling
is
to
be
included
in
the
WWT
section.

c.
EPA
has
deleted
use
of
the
term
"
utility
wastewater".

d.
EPA
has
narrowed
the
list
of
unit
types
applicable
to
this
section
to
those
known
to
be
in
use
at
airports.
Any
unknown
technologies
can
be
reported
on
using
the
"
Other"
category.

e.
Q.
5:

­
EPA
has
not
provided
a
cost
estimation
technology
that
airports
must
use
and
is
instead
requesting
whether
unit
capital
costs
are
available.
If
needed,
EPA
will
request
specific
unit
cost
information
as
a
follow
up
to
the
questionnaire.

Section
4/
Analytical
Data
a.
Ask
if
data
derived
from
EPA
protocols.

b.
Request
to
differentiate
between
outfall
and
in­
stream
data.

c.
Clarify
that
data
should
not
be
attached
but
may
be
requested
later
if
needed.
a.
EPA
has
incorporated
this
revision.

b.
EPA
has
incorporated
this
revision.

c.
EPA
has
clarified
that
data
should
not
be
attached
but
may
be
requested
later
as
needed.
Questionnaire
Section
No./
Topic
Comment
Response
62
Sections
3
and
4/

Pollution
Prevention
Airport:

a.
Should
request
P2
information
from
airlines
or
tenants.

b.
Remove
questions
re:
aircraft
deicing
c.
Difficult
to
quantify
decrease
of
ADF;
could
quantify
pollutant
loading
reduction
for
specific
period
of
time
(
5
or
10
years).

d.
P2
Practices
(
Q.
1):

­
Clarify
that
practices
apply
only
to
airports
that
perform
deicing
activities.

­
Add
"
proactive"
to
practices.

­
1C:
Substitution
of
less
toxic
chemicals:
Rephrase
as
this
is
making
an
assumption
about
toxicity
of
various
chemicals;
ask
about
more
benign
alternatives.

e.
Practice­
Specific
Information
(
Q.
2):

­
Few
airports
will
have
information
for
2d­
h.

­
Delete
question
re:
fresh
water
requirement
(
f.)
as
it
is
not
relevant
or
appropriate.

Airlines:

f.
P2
Practices
(
Q.
1):

­
Substitution
of
less
toxic
chemicals,
use
of
centralized
aircraft
deicing
facility,
and
collection
of
contaminated
runoff
for
recycling
do
not
meet
P2
definition.

­
C,
D,
E
are
not
applicable
to
airlines
­
Metered
application
of
ADF
is
unclear
and
violates
FAA
requirement
if
implies
limiting
amount
applied.

­
Does
"
use
of
centralized
aircraft
deicing
facility"
include
any
centralized
location
or
does
it
reference
"
pad"
as
indicated
in
Section
2.

­
Include
additional
P2
practices
(
e.
g.,
enhanced
weather
forecasting,
custom
blending
ADF,
manual
removal
of
snow).

g.
Practice­
Specific
Information
(
Q.
2):

­
Delete
information
that
is
not
applicable
or
available
to
airlines
(
i.
e.,
b,
c,
e,
f­
h).

­
All
P2
implementation
costs
or
savings
are
not
available.

­
Reduce
response
to
this
question
to
narrative
descriptions.

h.
Future
P2
Plans
(
Q.
3):
Expand
to
include
practices
considered
but
rejected
as
infeasible
or
too
costly
if
available.
Airport:

a.
and
b.
EPA
has
included
a
section
requesting
pollution
prevention
data
from
both
airports
(
in
the
airport
questionnaire)
and
airlines
(
in
the
airline
questionnaire).
EPA
has
tailored
these
sections
based
on
the
type
of
respondent.

c.,
d.,
and
e.
EPA
has
incorporated
industries
suggestion
that
this
section
request
pollution
prevention
information
in
an
open
ended
format
and
respondents
are
not
required
to
provide
impact
information
where
it
is
not
existing
and
available.

Airlines:

f.

­
EPA
has
revised
the
definition
of
pollution
prevention
to
be
more
inclusive
of
the
types
of
practices
used
by
the
airport/
airline
deicing
industry.

­
EPA
has
incorporated
this
revision.

­
EPA
has
revised
this
terminology
to
eliminate
this
concern.

­
EPA
has
revised/
clarified
the
definitions
of
pollution
prevention
and
aircraft
deicing
pads.

­
EPA
has
incorporated
these
additions
to
the
P2
section.

g.

­
EPA
has
incorporated
these
deletions.

­
EPA
has
incorporated
industries
suggestion
that
this
section
request
pollution
prevention
information
in
an
open
ended
format
and
respondents
are
not
required
to
provide
cost
information
where
it
is
not
existing
and
available.

h.
EPA
has
added
a
question
to
allow
airlines
to
identify
pollution
prevention
practices
that
were
considered
but
rejected
as
infeasible
or
too
costly.
Questionnaire
Section
No./
Topic
Comment
Response
63
Late
Comment:

Alliance
of
Residents
Concerning
O'Hare
Airport
and
Airline:

a.
Ask
about
all
airport/
aircraft
related
operations
performed
by
all
parties
on
and
off
airport
property.

b.
Ask
about
ground
water
pollution
monitoring
practices
to
ensure
no
drinking
water
contamination.

c.
Ask
about
the
amount
of
deicing/
anti­
icing
fluid
that
runs
off
of
the
planes
during
takeoff.

d.
Ask
what
the
percentage
of
total
gallons
of
fluid
use
becomes
vaporized.

e.
Ask
what
the
operational
state
is
of
aircraft
during
deicing
(
e.
g.,

all
engines
idling,
engines
off,
etc.)

f.
Ask
what
measures/
practices
are
used
to
make
the
determination
to
open/
not
open
a
bypass
valve
during
the
deicing
season.

g.
Ask
if
different
deicing
practices
are
used
for
military
aircraft
using
the
airports
premises.

h.
Ask
how
much
fluid
is
typically
held
over
from
the
end
of
one
deicing
season
to
the
next.

i.
Ask
whether
mixed
snow/
fluids
are
placed
in
areas
by
plows
and
going
into
the
correct
runoff
drains.
Airport
and
Airline:

a.
EPA
is
asking
both
airports
and
airlines
to
describe
their
deicing/
anti­
icing
operations.
EPA's
questions
are
specific
to
the
airport
and
do
not
extend
to
operations
that
are
not
performed
at
the
airport.

b.
EPA
has
added
a
question
to
the
airport
questionnaire
requesting
information
on
whether
groundwater
is
withdrawn
from
the
airport's
groundwater
aquifer
for
drinking
water
use.
This
information
will
help
EPA
to
determine
whether
groundwater
contamination
is
a
potential
environmental
impact
from
airport
deicing/
anti­
icing
operations.

c.
EPA
is
not
requesting
this
information
since
we
do
not
believe
that
it
will
be
available
data.
EPA
will
gather
through
literature
search
any
studies
done
to
assess
this
amount.

d.
EPA
is
not
requesting
this
information
since
we
do
not
believe
that
it
will
be
available
data.
EPA
will
gather
through
literature
search
any
studies
done
to
assess
this
amount.

e.
EPA
does
not
believe
that
they
require
information
on
the
operational
state
of
aircraft
being
deiced.

f.
EPA
is
requesting
information
on
stormwater
system
diversion
valves
and
when
they
are
used.

g.
EPA
will
collect
information
concerning
military
aircraft
deicing
operations
through
other
mechanisms.
The
airport
questionnaire
will
identify
those
airports
that
include
military
bases
with
aircraft
deicing/
anti­
icing
operations.

h.
EPA
is
requesting
information
on
airline
ADF
purchase
since
industry
has
indicated
that
the
airlines
do
not
keep
accessible
information
on
ADF
usage.
EPA
has
added
a
question
to
the
airline
questionnaire
requesting
information
on
the
disposition
of
unused
ADF.

i.
In
the
airport
diagram
and
in
Part
A,
Section
3,
Question
2,
EPA
requests
information
on
the
destination
of
snow
melt.
Questionnaire
Section
No./
Topic
Comment
Response
64
ACI­
NA
and
AAAE
Comments
on
EA
Questions
in
the
Airport
Questionnaire
(
Part
A,

Section
1)
General:

a.
EPA
already
has
the
information
being
requested
through
the
additional
questions
at
its
disposal.

b.
Questions
that
relate
solely
to
water
quality
issues,
discharges
to
groundwater,
or
assimilative
capacity
of
receiving
waters
appear
contrary
to
the
scope
of
the
ELG.

Specific:

a.
Use
the
term
"
industrial
stormwater
outfalls"
in
place
of
"
outfalls"
to
clarify
that
municipal
stormwater
outfalls
are
not
included
in
the
scope
of
the
ELG.

b.
The
term
"
type
of
surface
water"
is
ambiguous
and
confusing,

provide
additional
explanation.

c.
Airports
that
operate
under
a
multi­
sector
permit
do
not
typically
have
latitude
and
longitude
coordinates
for
each
outfall
or
data
on
receiving
waters.
Collecting
this
data
will
be
time
consuming
and
personnel
intensive.

d.
Modify
the
question
regarding
deicing
stormwater
discharge
to,

"
which
outfalls
discharge
stormwater
from
areas
designated
for
airfield/
aircraft
deicing".
General:

a.
EPA
does
not
have
the
information
requested
in
the
questions,

and
the
commenter
did
not
identify
the
data
sources
in
which
the
Agency
has
this
information.
EPA
appreciates
that
the
commenter
recognizes
the
Agency's
interest
in
collecting
accurate
information.

b.
The
answers
to
these
questions
will
inform
EPA's
environmental
and
benefits
assessments
for
this
rule.
EPA
typically
informs
itself
of
the
benefits,
if
any,
of
the
regulatory
options
it
considers
in
establishing
effluent
guidelines.
This
is
consistent
with
CWA
Section
304(
b)(
2)(
B)
that
authorizes
EPA
to
consider
"
such
other
factors
as
the
Administrator
deems
appropriate."
33
U.
S.
C.
§
1314(
b)(
2)(
B).
EPA
thinks
it
is
good
public
policy
to
inform
itself
as
to
what,
if
any,
environmental
benefits
may
occur
from
rulemaking.
Such
information
gathering
is
also
consistent
with
Executive
Order
12866.

Specific:

a.
EPA
asks
for
information
on
all
outfalls
in
this
one
question
in
order
to
obtain
data
on
the
overall
management
structure
for
stormwater
and
wastewater
discharges
at
the
airport
(
e.
g.,
what
wastewater
and
stormwater
streams
are
managed
in
combination).

Other
questions
in
the
questionnaire
focus
solely
on
outfalls
that
discharge
deicing
stormwater.

b.
EPA
has
modified
the
question
to
clarify
the
types
of
surface
water
categories
included
in
this
question.

c.
EPA
only
requests
information
that
is
already
available
for
completion
of
the
questionnaire
and
does
not
require
respondents
to
undertake
time
consuming
and/
or
personnel
intensive
analyses
in
order
to
generate
new
information
with
which
to
complete
the
survey.

d.
For
the
purposes
of
the
environmental
assessments,
EPA
is
interested
in
information
on
all
outfalls
that
are
known
by
an
airport
to
discharge
deicing
stormwater,
including
those
outfalls
that
are
known
by
an
airport
to
discharge
stormwater
from
areas
specifically
designated
for
airfield/
aircraft
deicing
.
EPA
has
retained
the
original
question.
Questionnaire
Section
No./
Topic
Comment
Response
65
ACI­
NA
and
AAAE
Comments
on
EA
Questions
in
the
Airport
Questionnaire
(
Part
A,

Section
1)
Specific
(
cont):

e.
Distinguish
between
aircraft
deicing
and
airfield
deicing
in
the
data
collection
efforts.

f.
Site
maps
will
be
contained
in
the
airport's
SWPPP.

g.
EPA
should
eliminate
the
question
requesting
receiving
water
total
flow
since
an
estimate
of
assimilative
capacity
of
downstream
receiving
waters
using
data
from
this
question
is
likely
to
be
grossly
inaccurate
and
contrary
to
the
scope
of
the
ELG.

h.
EPA
should
delete
the
question
concerning
engineered
modifications
to
receiving
waters.

i.
The
groundwater
question
seeks
information
outside
the
scope
of
the
ELG.

j.
The
request
for
information
on
characterization
studies
for
an
airport's
receiving
surface
water
body
is
outside
the
scope
of
the
ELG
and
overly
burdensome.

k.
Recommend
the
Agency
ask
during
which
months
does
aircraft
deicing
or
pavement
deicing
typically
occur,
or
whether
the
airport
discharges
deicing
stormwater
that
has
been
temporarily
retained.
Specific
(
cont):

e.
EPA
has
modified
questions
and
the
location
of
questions
in
both
the
airport
and
airline
questionnaires
to
help
distinguish
between
aircraft
deicing
operations
and
airfield
deicing
operations.

In
the
deicing
stormwater
system
diagram
(
requested
in
the
airport
questionnaire),
airports
are
asked
to
identify
the
flow
of
deicing
stormwaters
from
the
various
areas
of
the
airport
at
which
deicing
occurs.
In
many
cases,
a
source,
such
as
the
airport
gates,
may
contribute
stormwaters
from
both
aircraft
deicing
and
apron/

pavement
deicing
operations
and
so
a
clear
split
between
these
two
types
of
stormwaters
is
not
applicable.

f.
EPA's
request
for
a
site
map
allows
the
respondent
to
indicate
that
the
required
diagram
is
included
in
the
airport
SWPPP.

g.
EPA
will
use
this
information
to
help
characterize
the
nature
of
the
water
bodies
receiving
deicing
stormwater
discharges.
This
information
will
inform
EPA's
environmental
and
benefits
assessment
for
this
rule.
EPA
typically
informs
itself
of
the
benefits,
if
any,
of
the
regulatory
options
it
considers
in
establishing
effluent
guidelines.
This
is
consistent
with
CWA
Section
304(
b)(
2)(
B)
that
authorizes
EPA
to
consider
"
such
other
factors
as
the
Administrator
deems
appropriate."
33
U.
S.
C.
§
1314(
b)(
2)(
B).

EPA
thinks
it
is
good
public
policy
to
inform
itself
as
to
what,
if
any,
environmental
benefits
may
occur
from
rulemaking.
Such
information
gathering
is
also
consistent
with
Executive
Order
12866.

h.
EPA
has
incorporated
this
deletion.

i.
Deicing
fluids
have
the
potential
to
impact
groundwater
sources
of
drinking
water.
The
answers
to
these
questions
will
inform
EPA's
environmental
and
benefits
assessment
for
this
rule
as
discussed
in
the
response
to
g.

j.
EPA
does
not
believe
that
this
question
is
overly
burdensome.

The
question
asks
respondents
to
provide
basic
information
on
studies
already
known
to
the
respondent
and
does
not
require
the
respondent
to
generate
new
information.
See
response
to
g.

k.
EPA
has
included
a
question
on
typical
deicing
months
for
the
airport.
EPA
has
also
included
a
question
requesting
information
on
the
months
when
specific
outfalls
discharge
deicing
stormwaters.
Questionnaire
Section
No./
Topic
Comment
Response
66
Miscellaneous
Airline:

a.
Questionnaire
does
not
recognize
that
fundamental
function
of
aircraft
deicing
is
safety
which
is
regulated
by
FAA.
Airline:

a.
EPA
is
aware
that
the
fundamental
function
of
aircraft
deicing
is
safety
and
fully
supports
that
function.

Summary
of
Comments
on
the
Public
notice
for
the
Proposed
Information
Collection
for
Airport
Deicing
Operations
and
EPA's
Response
­
Economic
Sections
Survey
Section
No./
Topic
Comment
Response
Airline,
Part
B,
Q.
2.
Airline
annual
operating
costs
for
deicing
services.
Industry
states
it
doesn't
track
deicing
cost
data
in
the
form
EPA
requested,
and
it
would
be
extremely
burdensome
to
do
so.
Industry
offered
to
provide
airport­
specific
deicing
budget
data
instead.
In
response
to
industry
comment,
EPA
is
now
requesting
deicing
budget
rather
than
deicing
cost
data.
EPA
has
developed
a
new
question,
which
should
be
significantly
less
burdensome,
that
asks
the
respondent
to
characterize
the
percent
of
own
aircraft
deiced
by
the
airline,
other
airlines,

and
FBOs.

Airline,
Part
B,
Q
3.
Is
your
airline
a
co­
permittee
for
this
airport's
NPDES
permit?
Industry
states
that
it
is
easier
for
the
airport
to
answer
this
question.
EPA
deleted
this
question,
and
will
now
obtain
this
information
from
the
airport
survey.

Airline,
Part
B,
Q
4.
Does
your
airline
provide
deicing
services
to
other
airlines
at
this
airport?
Industry
states
this
question
would
be
very
burdensome
to
answer
since
they
don't
track
this
data
in
the
form
EPA
requested.
In
response
to
industry
comment,
EPA
deleted
this
question
from
the
survey.

Airline,
Part
B,
Q
5.
Does
your
airline
typically
perform
aircraft
deicing
operations
at
the
gate
or
use
a
centralized
pad
at
this
airport?
EPA
deleted
this
question
from
the
economics
section
of
the
survey;
similar
information
can
be
obtained
from
the
technical
section.

Airline,
Part
B,
Q
6.
Were
deicing
operations
of
average,

above
average,
or
below
average
intensity
at
this
airport
in
the
2004/
2005
deicing
season?
Industry
states
this
question
would
be
very
burdensome
to
answer
since
they
don't
track
this
data
in
the
form
EPA
requested.
This
question
was
intended
to
help
interpret
deicing
cost
data.
EPA
deleted
this
question
from
the
survey
since
it
is
now
collecting
deicing
budget
data
instead
of
cost
data.
Presumably
deicing
budgets
are
set
for
an
expected
intensity
of
deicing
operations
at
each
airport.
Survey
Section
No./
Topic
Comment
Response
67
Airline,
Part
B,
Q
7.
What
percentage
of
the
direct
costs
of
aircraft
deicing
by
your
airline
accounted
for
by
the
following
items.
Industry
states
this
question
would
be
very
burdensome
to
answer
since
they
don't
track
this
data
in
form
EPA
requested.
Instead,
industry
offered
to
provide
a
narrative
describing
significant
components
of
the
deicing
budget.
EPA
deleted
this
question
from
the
survey
and
will
use
the
data
industry
can
provide
to
characterize
components
of
deicing
costs.

Airline,
Part
B,
Q
10.
For
deicing
fluid,
please
provide
the
quantity
and
value
of
fluid
used
by
this
airline
at
this
airport.
Industry
stated
this
would
be
very
burdensome
to
answer
since
they
do
not
directly
track
deicing
fluid
usage.
Also,
the
value
of
deicing
fluid
purchased
is
sensitive
business
information.
EPA
deleted
this
question
from
the
survey.

Airline,
Part
B,
Q
11.
Using
the
FAA
definition
of
"
hub"
airports,
at
how
many
airports
does
this
airline
have
deicing
services?

Airline,
Part
B,
Q
12.
Please
provide
the
percentage
of
aircraft
deicing
fluid
(
ADF)

used
and
the
percentage
of
deicing
costs
incurred
at
airports
where
this
airline
maintains
its
own
deicing
facilities.
Industry
stated
this
would
be
extremely
burdensome
to
answer
these
questions
and
responses
may
also
be
inaccurate,
since
airlines
do
not
routinely
classify
airports
using
FAA
hub
definitions.
EPA
deleted
these
questions
from
the
survey,
and
will
now
use
BTS
airport
activity
data
to
characterize
route
structure
and
extrapolate
deicing
compliance
costs
and
ADF
usage.

Airline,
Part
B,
Q
14.
Please
provide
the
following
information
on
this
airline's
route
structure
from
this
airport.
Industry
stated
this
would
be
very
burdensome
to
answer.
Also,
route
structure
is
sensitive
business
information.
EPA
found
it
could
obtain
the
route
structure
data
in
detail
from
BTS
databases,
and
therefore
deleted
the
question
from
the
survey.

Airline,
Part
B,
Q
15.
Are
this
airline's
routes
primarily
hubbased
or
point­
to­
point?
Industry
stated
this
would
be
very
burdensome
to
answer.
EPA
modified
the
question
to
only
ask
if
the
specific
airport
receiving
the
survey
is
an
operational
hub
for
the
airline.
Survey
Section
No./
Topic
Comment
Response
68
Airline,
Part
B,
Q
16.
airline's
total
operating
revenues
Airline,
Part
B,
Q
18.
airline's
total
operating
expenses
Airline,
Part
B,
Q
19.
airline's
operating
profit
Airline,
Part
B,
Q
20.
airline's
net
income
Industry
stated
this
would
be
very
burdensome
to
answer.
EPA
determined
it
can
obtain
the
necessary
financial
data
from
BTS
databases.

Airline,
Part
B,
Q
17.
What
percentage
of
operating
revenues
were
accounted
for
by
[
the
following]
service
types?
Industry
stated
this
would
be
very
burdensome
to
answer.
EPA
recognizes
that
this
question
would
be
burdensome
for
industry
to
answer,
and
therefore
chose
not
to
further
pursue
it.

Airline,
Part
B,
Q
21.
How
many
persons
are
employed
by
this
airline
at
this
airport?
Industry
stated
this
would
be
very
burdensome
to
answer.
EPA
chose
not
to
pursue
this
question
to
reduce
the
burden
to
industry.

Airline,
Part
B,
Q
22.
Is
this
airline
wholly
or
partly
owned
by
another
airline?

Airline,
Part
B,
Q
23.
Does
this
airline
have
code­
sharing
arrangements
with
other
U.
S.

airlines?
Industry
stated
this
would
be
very
burdensome
to
answer
and
is
sensitive
business
information.
EPA
determined
it
can
obtain
sufficiently
accurate
information
from
publicly
available
sources
to
characterize
code­
sharing
and
ownership
patterns.

Airline,
Part
B,
Q
24.
On
what
percentage
of
routes
does
this
airline
have
code­
sharing
arrangements?

Airline,
Part
B,
Q
25.
What
percentage
of
this
airline's
operating
revenues
are
accounted
for
by
routes
with
code­
sharing?
Industry
stated
this
would
be
very
burdensome
to
answer.
EPA
recognizes
that
these
questions
would
be
burdensome
for
industry
to
answer,
and
therefore
chose
not
to
further
pursue
them.

Airport,
Part
B.
Financing
Suggested
adding
the
time
frame
for
which
AIP
funds
are
committed.
EPA
added
the
question.
Survey
Section
No./
Topic
Comment
Response
69
Airport,
Part
B,
Section
3,
Q.
5.

Sensitivity
of
airline
service
to
changes
in
landing
fees
Suggested
moving
question
to
airline
survey.
EPA
believes
airports
are
most
appropriate
entity
to
answer
this
question
because
airline
management
can
only
respond
for
itself
whereas
airport
management
has
perspective
on
overall
traffic
at
the
airport
(
which
is
EPA's
concern).
EPA
believes
airport
management
can
answer
this
question
since
the
issue
was
raised
by
airport
management
during
a
site
visit.
During
subsequent
site
visits
EPA
has
asked
other
airport
managers
the
same
question
and
they
have
been
able
to
answer
it.
EPA
added
CBI
box
to
question
so
airport
management
will
not
feel
it
is
disclosing
Airport,
Part
B,

Section4,
Q.
3.

Growth
in
flight
operations
Question
better
suited
for
airlines
to
answer.
EPA
deleted
question
from
airport
survey.
