Document reference:

420831 | D7 | G3

 

Information class:

Standard

 

This document is issued for the party which commissioned it and for specific purposes connected with the above-captioned project only. It should not be relied upon by any other party or used for any other purpose.

We accept no responsibility for the consequences of this document being relied upon by any other party, or being used for any other purpose, or containing any error or omission which is due to an error or omission in data supplied to us by other parties.

This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it.

 

 

 

Contents

Glossary

1       Introduction

1.1      Background

1.2      EP Requirements

1.3      Updated EM&A Requirements

1.4      Structure of this Plan

2       Emissions Reduction Strategies and Actions

2.1      Introduction

2.2      Emissions Reduction Strategies

2.3      Emissions Reduction Actions

3       Airport Operation Related Emissions Control Measures

3.1      Introduction

3.2      Banning Idling Engines

3.3      Promoting Increased Use of Electric Vehicles

3.3.1         Phase 1

3.3.2         Phase 2

3.3.3         Phase 3

3.4      Promoting Increased Use of Electric Ground Services Equipment

3.4.1         Phase 1

3.4.2         Phase 2

3.4.3         Phase 3

3.5      Development of Airside EV and e-GSE Charging Infrastructure

3.6      Adopting Fuel-efficient Airside Vehicles

3.7      Utilizing Clean Diesel and Gasoline at the Airfield

3.8      Summary

Annex

I.        Operational Air Quality Monitoring and Audit Plan

Tables

Table 3.1: Airport Operation related Emissions Reduction Measures at HKIA

Figures

Figure 1.1: Runway Operation Configuration

Photos

Photo 3.1: Aircraft connected to FGP and PCA at parking stands

Photo 3.2: Electric saloon vehicles operating at airside of HKIA

Photo 3.3: Electric airside passenger buses currently in operation at HKIA

Photo 3.4: Autonomous electric tractor introduced for use at HKIA for baggage delivery

Photo 3.5: Electric GSE provided by AAHK at airside of HKIA


 

 

 

Glossary

3RS

Three-runway System

AAHK

Airport Authority Hong Kong

AET

Autonomous Electric Tractor

AOEC

Airport Operation related Emissions Control

APU

Auxiliary Power Unit

AQOs

Air Quality Objectives

AQMS

Air Quality Monitoring Station

ASRs

Air Sensitive Receivers

AVL

Airside Vehicle Licence

DEP

Director of Environmental Protection

e-GSE

Electric-powered Ground Service Equipment

EIA

Environmental Impact Assessment

EIAO

Environmental Impact Assessment Ordinance

EM&A

Environmental Monitoring and Audit

EP

Environmental Permit

EPD

Environmental Protection Department

EV

Electric Vehicle

FGP

Fixed Ground Power

GSE

Ground Services Equipment

HKIA

Hong Kong International Airport

HKUST

Hong Kong University of Science and Technology

I-2RS

Interim Two-Runway System

LPG

Liquefied Petroleum Gas

MM

Mott MacDonald

NO2

Nitrogen Dioxide

NOx

Nitrogen Oxides

NRMM

Non-road Mobile Machinery

PCA

Pre-conditioned Air

RHO

Ramp Handling Operator

T2

Terminal 2

 


1        Introduction

1.1        Background

Under the Environmental Impact Assessment Ordinance (EIAO), the Environmental Impact Assessment (EIA) Report and the Environmental Monitoring and Audit (EM&A) Manual (Register No.: AEIAR-185/2014) prepared for the “Expansion of Hong Kong International Airport into a Three-Runway System” (hereafter referred to as the “3RS Project” or the Project) have been approved by the Environmental Protection Department (EPD), and an Environmental Permit (EP) (Permit No.: EP-489/2014) has been issued for the Project.

The Project is planned to be located on a new land formation area immediately north of existing Hong Kong International Airport (HKIA) in North Lantau, covering a permanent footprint of approximately 650 ha. As stated in the approved EIA for the 3RS Project (hereafter as “3RS EIA Report”), the Project primarily comprises:

    New third runway with associated taxiways, aprons and aircraft stands;

    New passenger concourse building;

    Expansion of the existing Terminal 2 (T2) building; and

    Related airside and landside works, and associated ancillary and supporting facilities.

As presented in the approved 3RS EIA Report, the runway operational configuration will be implemented in phases as shown in Figure 1.1 below. Upon completion of the new third runway and associated taxiways and with operation familiarisation of the third runway started on 8 July 2022 and formal commencement of operation started since 25 November 2022, the previous north runway is temporarily closed for modification works. During this period as described in the approved 3RS EIA Report, the existing South Runway and the new third runway (which is designated as the new North Runway) is currently in operation, which is hereafter referred to as the interim two-runway system (I-2RS) operation. Upon completion of all essential infrastructure and facilities, the airport will be operated under the 3RS, which is hereafter referred to as the 3RS operation.

Figure 1.1: Runway Operation Configuration

Interim 2RS (I-2RS) Operation

3RS Operation

The operational phase air quality impact assessment undertaken as part of the 3RS EIA had assessed the potential air quality impact on air sensitive receivers (ASRs) identified within 5km from the project boundary based on the highest aircraft emission scenario under normal operating conditions of the Project in accordance with the EIA Study Brief requirements. 

As summarised in Section 5.3.7.1 of the approved 3RS EIA Report, no non-compliance against the Air Quality Objectives (AQOs) has been predicted at all the identified ASRs during the operation of the Project.  Nevertheless, the Airport Authority Hong Kong (AAHK) has been implementing a number of measures and initiatives aimed at further reduction in air emissions from airport activities and operations at HKIA, and these efforts are expected to continue in the current I-2RS and subsequent 3RS operation.  Pursuant to EP Condition 2.24, this Airport Operation related Emissions Control (AOEC) Plan is prepared to detail the measures to be taken to minimise and control the emissions due to the airport operation and AAHK is required to deposit this AOEC Plan with the Director of Environmental Protection (DEP, or hereafter referred to as the Director) no later than 3 months before the operation of the Project. 

Mott MacDonald (MM) has been appointed by AAHK as the Consultant to provide consultancy services for the 3RS Project, which include, among others, the preparation of this Plan.

 

1.2        EP Requirements

This AOEC Plan has been prepared to fulfil the EP Condition 2.24, which is reproduced below:

The Permit Holder shall, no later than 3 months before the operation of the Project, deposit 3 hard copies and 1 electronic copy of an Airport Operation related Emissions Control Plan with the Director, detailing the measures to be taken to minimize and control the emissions due to the airport operation including but not limited to adopting fuel-efficient airside vehicles, promoting increased use of electric vehicles and electric ground services equipment, banning all idling vehicles on the airside and utilizing clean diesel and gasoline at the airfield.

 

1.3        Updated EM&A Requirements

In addition to the requirements set out under EP Condition 2.24 as presented above, AAHK has made a commitment in Section 2.2 of the Updated EM&A Manual to undertake air quality monitoring and audit (AQM&A) on a regular basis during the 3RS operation.  As described in Section 2.2.3.3 of the Updated EM&A Manual, the detailed AQM&A requirements should be presented as part of the AOEC Plan and this is set out in Annex I of this Plan.

 

1.4        Structure of this Plan

Following this introductory section, Section 2 has summarised AAHK’s emissions reduction strategies and actions taken to minimise and control airport operation related emissions.  Further details of the measures that are already implemented, in progress or planned for implementation at HKIA are set out in Section 3.

 

 

2        Emissions Reduction Strategies and Actions

2.1        Introduction

Background air quality in Hong Kong including the districts near HKIA has been improving and these are well reflected via the air quality monitoring data obtained in recent years at HKIA’s air quality monitoring stations (AQMS) and also at EPD’s air quality monitoring station in Tung Chung.  Relevant data can be found in Appendix A of Annex I.

Yet, in line with the Government’s strategy of shifting the focus to enhancing air quality to foster a healthier and more liveable environment for the community, AAHK has been implementing a number of additional measures and initiatives aimed at further reduction in air emissions from the daily operations and activities at HKIA.

The emissions reduction strategies and actions that have been planned by AAHK for implementation at HKIA and that fulfil the requirements of EP Condition 2.24 are summarised below. 

 

2.2        Emissions Reduction Strategies

AAHK is responsible for the operation and development of HKIA where various operational functions are outsourced to franchisees, tenants and government departments. Therefore, AAHK’s approach to air quality management has been to reduce air emissions that are under AAHK’s direct control (i.e., emission related to AAHK’s operations, vehicles and equipment), and to facilitate emissions reduction which AAHK can guide or influence.  The latter includes airside vehicles operated by our business partners at HKIA and also aircraft movements on the ground.

To facilitate the identification of major sources of air pollutants in HKIA’s operation and evaluation of possible measures that may be implemented to further minimise and control emissions, AAHK has engaged and worked with the Hong Kong University of Science and Technology (HKUST) since 2007 to analyse the available air quality data, and also identify and study the main sources of air emissions associated with HKIA’s operation.  These consultancy studies have allowed AAHK to gain a better understanding of the air quality performance of different aspects of airport operations, and have facilitated the development of relevant emissions reduction actions by AAHK in the past years, focusing on those additional measures and initiatives that AAHK may take to reduce air emissions that are under AAHK’s direct control, guide or influence in relation to the airport operation and these are further described below.

 

2.3        Emissions Reduction Actions

As described in Section 5.3.7.1 of the approved 3RS EIA Report, while no non-compliance against the AQOs is predicted at the identified ASRs, AAHK has been implementing a number of measures and initiatives aimed at further reduction in air emissions from airport activities and operations.  These measures are aligned with the requirements set out under EP Condition 2.24. The key measures and initiatives are summarised below and the relevant details are presented in Section 3:

    Banning of idling vehicles and Ground Services Equipment (GSE) with running engines on airside of HKIA since 2008;

    Banning the use of auxiliary power units (APU) on aircraft at frontal stands since 2014;

    Introduction and gradual implementation of AAHK’s Airside Vehicle Electrification Programme since 2012;

    Introduction and gradual implementation of AAHK’s GSE Pooling Scheme, with the use of electric-powered GSE (e-GSE) where models are commercially available in the market since 2018;

    Installation of Electric Vehicle (EV) and e-GSE charging infrastructure on airside of HKIA to meet the operational needs of EV and e-GSE;

    Phasing out of old, non-fuel efficient airside vehicles via defining relevant airside vehicle licence related requirements and the implementation of the above-mentioned AAHK’s Airside Vehicle Electrification Programme; and

    Provision of biodiesel and liquefied petroleum gas for use by vehicles on the airside of HKIA, and continue to explore the use of alternative low carbon fuels by the vehicles and GSE at HKIA.

 

 

3        Airport Operation Related Emissions Control Measures

3.1        Introduction

This section presents details of the airport operation related emissions control measures that are implemented, in progress, or planned for implementation at HKIA.  The measures planned by AAHK align with those required under the EP Condition 2.24.

 

3.2        Banning Idling Engines

As described in Section 5.3.7.1 of the approved 3RS EIA Report, except for certain vehicles and operations that are exempted, AAHK introduced a ban of idling vehicle engines on the airside since May 2008.  The ban covered idling vehicles and Ground Services Equipment (GSE) with running engines on the airside, and the airport community was consulted before the introduction of the ban.

On the other hand, AAHK has implemented a ban on use of Auxiliary Power Units (APU) on aircraft at frontal stands since December 2014 to reduce emissions from burning of jet fuel.  Without compromising aircraft’s needs for electrical power and cabin cooling when parked, AAHK installed fixed ground power (FGP) and pre-conditioned air (PCA) systems at frontal stands (see Photo 3.1) for use by airport business partners, organised trials and developed operational procedures to support the implementation of the APU ban.  AAHK also provided mobile PCA units for use at remote stands for reducing air emissions.

Photo 3.1: Aircraft connected to FGP and PCA at parking stands

 

3.3        Promoting Increased Use of Electric Vehicles

AAHK developed and implemented an Airside Vehicle Electrification Programme and developed a relevant implementation roadmap to reduce air emissions associated with the airport operation.  The Programme consists of three phases and targets the following listed vehicle types:

    Phase 1 – saloon vehicles;

    Phase 2 – remaining Class 1 vehicles with gross vehicle weight of up to 3 tonnes (i.e., non-saloon type private cars)

    Phase 3 – airside vans, mini-buses and buses

3.3.1         Phase 1

In 2012, AAHK announced an Airside Saloon Vehicles Replacement Plan and rolled out a relevant Airside Electric Vehicle (EV) Incentive Scheme to facilitate the phase out of old diesel/ petrol powered saloon vehicles in the airside.  Under the Plan, AAHK announced a policy change on the airside vehicle licensing regime by specifying that:

    All newly registered saloon vehicles must be of EV type from July 2013;

    Fossil fuel powered saloon vehicles will not be issued with an airside vehicle licence (AVL) if the vehicle reaches 9 years of age or after June 2017, whichever comes earlier.

Working with the airport business partners, the first phase of the Airside Vehicle Electrification Programme was successfully completed, with all saloon cars replaced with EV models since 2017 (see Photo 3.2).

Photo 3.2: Electric saloon vehicles operating at airside of HKIA

 

 

 

3.3.2         Phase 2

Phase 2 of the Airside Vehicle Electrification Programme focuses on replacement of all airside fossil fuel powered private vehicles with a gross weight of less than 3 tonnes with EV models, with the following targeted timeline:

    All newly registered private vehicles with a gross weight of less than 3 tonnes must be EV models from July 2019;

    Existing fossil fuel powered private vehicles with a gross weight of less than 3 tonnes will not be issued with an AVL if the vehicle’s licence issued by Transport Department or its AVL reaches 7 years from the first issuance date from January 2021;

    All AVLs issued to fossil fuel powered private vehicles with a gross weight of less than 3 tonnes will be expired from end December 2022.

Phase 2 of the Airside Vehicle Electrification Programme commenced in July 2019 as planned with end December 2022 adopted as the targeted date for completion of programme.  Yet, there were some EV supply problems that were experienced as a result of the COVID-19 pandemic and the targeted date for completion of the Phase 2 Programme was updated to end 2023.

3.3.3         Phase 3

Subject to the availability and reliability of electric commercial vehicles in the market, AAHK has planned to progressively phase out the existing fleet of vans, mini-buses and buses operating at the airside of HKIA and replace them with electric models commencing from 2024.  This process has already started early for operating buses when AAHK introduced the use of 10 electric passenger buses and also 6 electric staff buses for use at HKIA since July 2020 (see Photo 3.3).

AAHK has also been spending efforts to identify opportunities that may allow increased use of electric vehicles. In end December 2019, after testing for more than one and a half years, AAHK has become the first airport in the world that has applied the use of autonomous electric tractor (AET) technology into live airport operations for baggage delivery (see Photo 3.4).

Photo 3.3: Electric airside passenger buses currently in operation at HKIA

 

 

Photo 3.4: Autonomous electric tractor introduced for use at HKIA for baggage delivery 

 

3.4        Promoting Increased Use of Electric Ground Services Equipment

With a view to improving operating efficiency and reducing air emissions, AAHK rolled out a GSE Pooling Scheme at HKIA in July 2018.  The Scheme enables ramp handling operators (RHOs) serving client airlines to rent critical GSE, of which 95% are electric-powered GSE (e-GSE), from AAHK.  The Scheme consists of three phases.  Phase 1 was already fully implemented while Phase 2 has already commenced since April 2022.  When Phase 3 of the Scheme is fully implemented upon commencement operation of the 3RS, AAHK will own up to about 1,000 units of GSE, with at least 95% as e-GSE, and become the world’s first international airport to adopt GSE Pooling to such a scale.  Examples of e-GSE introduced for use at HKIA are illustrated in Photo 3.5.

3.4.1         Phase 1

The GSE Pooling Scheme was first conceived when AAHK initiated a review of aircraft ramp handling processes, which included an in-depth analysis of arrival baggage delivery performance in 2016.  The findings revealed timely provision of GSE is one of the most important factors affecting HKIA’s service standards. Likewise, the deployment of GSE from flight to flight across the apron increasingly led to traffic congestion during peak periods throughout the day. This not only affected the on-time performance of arriving baggage and departing flights, but also led to increased air emissions, especially when the RHOs have been using many aged diesel-powered GSE.

Under the new AAHK’s ownership model, all critical GSE are standing by at every parking stand and the need for mobilizing GSE is minimized. This not only brings benefits in terms of reduced emissions and energy use, but also reduced unnecessary traffic on apron road and traffic congestion. Moreover, with 95% of GSE being electric-powered, exposures of workers and other receptors to NOx, particulates and other pollutants are significantly reduced. 

Phase 1 of the GSE Pooling Scheme was implemented at Midfield Apron and this was extended to cover North Satellite Concourse and remote bays at West Apron subsequently.  Under Phase 1, AAHK procured and owned over 250 GSE, of which 95% are electric-powered GSE, for rental use by RHOs.  In addition to procuring the GSE, AAHK also funded the installation of chargers, established two GSE maintenance workshops, provided training, and developed a detailed GSE Pooling Scheme Operations Handbook to provide guidelines to the relevant partners for operation of the Scheme.

3.4.2         Phase 2

A contractor has been recruited by AAHK for implementation of Phase 2 of the Scheme that took place at the apron area of Terminal 1 since April 2022.  Critical GSE for passenger aircraft turnaround, including conveyor belt loaders, lower deck loaders, etc. will be acquired under Phase 2 of the Scheme and all of the GSE are targeted to be of the electric type.  When fully implemented, the total size of the GSE fleet owned by AAHK in the Phases 1 and 2 GSE Pooling Scheme will be scaled up to over 500.

3.4.3         Phase 3

Phase 3 of the GSE Pooling Scheme will be implemented at the planned Terminal 2 Concourse (formerly known as Third Runway Concourse) for the 3RS operation.  It is expected that most of the GSE procured will be of the electric types when increasing number of reliable e-GSE models are available in the market. 

Photo 3.5: Electric GSE provided by AAHK at airside of HKIA

 

 

3.5         Development of Airside EV and e-GSE Charging Infrastructure

From the implementation of the first phase of AAHK’s Airside Vehicle Electrification Programme in 2012, AAHK has been progressively enhancing its EV charging infrastructure.  Currently, there are already more than 400 number of normal EV chargers and also more than 30 number of quick EV chargers installed for use at the airside of HKIA. The total number of EV chargers are planned to be increased to over 1,300 to support the 3RS operation by 2030.

On the other hand, to facilitate the increased use of e-GSE at HKIA, including the effective operation of the    e-GSE procured by AAHK for use in AAHK’s GSE Pooling Scheme, AAHK has been increasing the number of e-GSE chargers for use at HKIA.  Currently, there are already more than 180 e-GSE chargers installed for use at the apron area of HKIA and the total number is expected to be increased to more than 400 in 2025.

3.6        Adopting Fuel-efficient Airside Vehicles

The Air Pollution Control (Non-road Mobile Machinery) (Emission) Regulation (hereafter referred as the “NRMM Regulation”) came into operation on 1 June 2015, where all NRMMs, except those exempted, are required to comply with prescribed emission standards, via a permitting system. All airport vehicles operating at the airside of HKIA, including vans, buses and GSEs are classified as NRMMs and are subject to permitting control under the Regulation.

As all vehicles within the airside of HKIA are required to obtain an AVL, AAHK took the opportunity to revise its AVL requirements to dovetail with the requirements stipulated under the NRMM Regulation.  For ensuring compliance with the NRMM Regulation, AAHK will only issue AVL to those airside vehicles (equipped with compression-ignition or positive-ignition engine) if it bears a valid approval or exemption label issued under the NRMM Regulation.  Besides, issued AVL will be repealed on the date when the approval or exemption is revoked under the NRMM Regulation.

Besides, as already described in Section 3.3 above, AAHK has developed a roadmap and specified relevant requirements to promote the increased use of EV and the required phase out of old, non-fuel efficient vehicles.  The key measures introduced include:

    Fossil fuel powered saloon vehicles were not issued with an AVL when the vehicle reached 9 years of age or after June 2017, whichever came earlier;

    Existing fossil fuel powered private vehicles with a gross weight of less than 3 tonnes were not issued with an AVL when the vehicle’s licence issued by Transport Department or its AVL reached 7 years from the first issuance date from January 2021;

    All AVLs issued to fossil fuel powered private vehicles with a gross weight of less than 3 tonnes will be expired by end December 2023 as the targeted date as described in Section 3.3.2.  

3.7        Utilizing Clean Diesel and Gasoline at the Airfield

Currently, to promote the use of cleaner fuel, biodiesel and also liquefied petroleum gas (LPG) fuelling points are already made available by AAHK at the airside of HKIA for use by vehicles.

For the longer term, while AAHK has developed relevant implementation roadmap and formed relevant policies and requirements to promote the increased use of EV and e-GSE in the airport operation, it is expected that there will still be some vehicle types, including commercial vehicles, service vehicles, medium and heavy goods vehicles, etc., and also specific GSE types for which relevant electric models are still at an early stage of development and hence are not yet commercially available for use.  While AAHK will continue to identify and explore the possible use of zero emission vehicles for the above-mentioned vehicle types, to meet the operational need of these vehicles while taking into account the need to further reduce air emissions, including carbon emissions, AAHK has planned to undertake trials to test the use of alternative low carbon fuels for vehicles and GSE at HKIA and will introduce their use at HKIA if the trial results are successful. 

3.8        Summary

Table 3.1 has summarised the various measures and initiatives that are implemented, in progress or planned for implementation at HKIA.  The listed measures, including those that have been implemented, will be applicable to both the current I-2RS and subsequent 3RS operation. The implementation schedule of those measures that are in progress or planned for implementation, including the target completion dates, have also been presented as part of the summary table to facilitate the subsequent monitoring of progress.
 

Table 3.1: Airport Operation related Emissions Reduction Measures at HKIA

Measures

Sections containing the details

Status

Implementation Schedule

Banning Idling Engines

 

Banned idling vehicles and GSE with running engines on the airside since May 2008, except for certain vehicles and operations that are exempted.

Section 3.2

Implemented

Completed

Banned the use of APU on aircraft at frontal stands since December 2014.

Section 3.2

Implemented

Completed

Promoting Increased Use of Electric Vehicles

 

Completed Phase 1 of AAHK’s Airside Vehicle Electrification Programme, with all saloon cars replaced with EV models since 2017.

Section 3.3.1

Implemented

Completed

Implementing Phase 2 of AAHK’s Airside Vehicle Electrification Programme that focuses on replacement of all airside fossil fuel powered private vehicles with a gross weight of less than 3 tonnes with EV models.

Section 3.3.2

In progress

Targeted for completion by end of 2023

Implementing Phase 3 of AAHK’s Airside Vehicle Electrification Programme that focuses on phasing out the existing fleet of vans, mini-buses and buses operating at the airside of HKIA with EV models, subject to their market availability and reliability.

Section 3.3.3

Planned

2024 – 2030*

Promoting Increased Use of Electric Ground Services Equipment

 

Completed Phase 1 of AAHK’s GSE Pooling Scheme that was implemented at Midfield Apron and extended to cover North Satellite Concourse and remote bays at West Apron.

Section 3.4.1

Implemented

Completed

Implementing Phase 2 of AAHK’s GSE Pooling Scheme that will take place at the apron area of Terminal 1.

Section 3.4.2

In progress

2022 – 2023

Implementing Phase 3 of AAHK’s GSE Pooling Scheme at the planned Terminal 2 Concourse (formerly known as Third Runway Concourse).

Section 3.4.3

Planned

2024 – 2030*

Development of Airside EV and e-GSE Charging Infrastructure

 

Completed installation of EV and e-GSE charging facilities to support the implementation of Phase 1 of both the AAHK’s Airside Vehicle Electrification Programme and GSE Pooling Scheme.

Section 3.5

Implemented

Completed

Installing additional EV and e-GSE charging facilities to support the implementation of Phases 2 and 3 of both the AAHK’s Airside Vehicle Electrification Programme and GSE Pooling Scheme.

Section 3.5

In progress

Targeted for completion by 2030**

Adopting Fuel-efficient Airside Vehicles

 

Revised AVL requirements to dovetail with the requirements stipulated under the NRMM Regulation 

Section 3.6

Implemented

Completed

Phasing out old, non-fuel efficient vehicles

Section 3.6

In progress

Targeted for completion by 2030

Utilizing Clean Diesel and Gasoline at the Airfield

 

Provision of biodiesel and liquefied petroleum gas for use by vehicles at the airside of HKIA

Section 3.7

Implemented

Completed

Explore the use of alternative low carbon fuels for vehicles and GSE at HKIA

Section 3.7

In progress

Ongoing

* Exact target completion dates of Phase 3 of both the Airside Vehicle Electrification Programme and GSE Pooling Scheme would be subject to the availability and reliability of electric commercial vehicles and GSE in the market.

** Exact target completion date for full development of the airside EV and e-GSE Charging Infrastructure would be subject to the implementation programme of Phase 3 of both the Airside Vehicle Electrification Programme and GSE Pooling Scheme.