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Renewable Energy as an Airport Revenue Source (2015)

Chapter: Chapter 4 - Implementing Airport Renewable Energy Projects

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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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Suggested Citation:"Chapter 4 - Implementing Airport Renewable Energy Projects." National Academies of Sciences, Engineering, and Medicine. 2015. Renewable Energy as an Airport Revenue Source. Washington, DC: The National Academies Press. doi: 10.17226/22139.
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100 Renewable energy projects are implemented in ways similar to other airport projects. The projects can affect other parties requiring stakeholder coordination and public outreach. To be successful, the projects should: • Be publicly bid and qualified private partners selected; • Obtain regulatory approvals; and • Be well managed to be successful. However, there are particularities associated with renewable energy projects. This chapter describes the key implementation steps and provides specific examples from other renewable energy projects to help airports in administering future projects. 4.1 Stakeholder Coordination Elements of the stakeholder process include public review during planning and permitting, and education and outreach throughout the life of the project. 4.1.1 Public Review Airports convene regular public meetings to discuss airport activities and authorize future work as necessary. Airport sponsors can use these regular meetings to introduce the project concept and provide status reports throughout the project life during planning, construction, and operations. These meetings will afford the airport with a high level of transparency and help identify any issues that may be raised by neighbors, tenants, or other affected parties. Should issues be raised, the airport can respond to the issue either immediately by answering questions or at a future meeting should additional research be required. The public engagement will help to solidify support for the project. Engagement with local community groups may often be addressed adequately through the regular airport public meetings. However, in some circumstances, the airport may choose to engage these groups through separate meetings to ensure that their members are sufficiently informed about a particular airport project or activity. In other instances, individual meetings may be arranged after some initial level of information exchange occurs at the regular airport meeting to expand the level of outreach. Typically, renewable energy projects are not likely to cause a concern for neighbors given their relatively non-obtrusive nature. Given its large size, a utility-scale wind turbine proposed on airport land is a logical exception and might warrant additional outreach depending on its proximity to residential areas. Implementing Airport Renewable Energy Projects C H A P T E R 4

Implementing Airport Renewable Energy Projects 101 Other stakeholders such as tenants, government agencies, and environmental groups may have interest in the proposed renewable energy project. Tenants may have questions about the potential effects of the project on their activities and/or lease agreement. Interaction with other government agencies may occur as part of regular intergovernmental coordination and coopera- tion processes. Environmental groups may be interested in particular resource impacts issues (e.g., birds and wind turbines) or carbon mitigation benefits of the project. Involvement of these groups will depend on the type of renewable energy project and the airport’s relationship with the organization. They may also be triggered by communication at the regular airport public meetings. 4.1.2 Education and Outreach Public education and outreach associated with a renewable energy project is a good vehicle for enhancing communications between the airport and the public. Renewable energy projects have a broad level of interest. Information can readily be provided by the airport to the public about the project during construction and operations to build a positive following. It is best to utilize existing communication tools and practices and integrate the communication of the renewable energy project to those rather than creating new forums to be managed, though there may be exceptions. Some options to consider are as follows. 4.1.2.1 Website The airport can build a project webpage to provide interested parties with basic information on the project including how it works, why it was constructed, and anticipated benefits. Updates can be included periodically along with links to social media that update automatically based on activity levels. These forums can also engage community comments and be a way to collect feedback on successful implementation of the project and lessons learned. 4.1.2.2 Press Releases Airports regularly issue press releases on their activities that will be picked up and published in local media and industry publications. Renewable energy projects are of interest to the public and therefore often receive wide circulation. Therefore, airports should put out press releases about the project at particular milestones including after formal announcement to proceed with the project, at the start of construction, and at the commencement of operations. 4.1.2.3 Newsletters Existing newsletters sent to community groups, tenants, and interest groups should include regular communication of the project and its benefits. If this is a regular communication tool used by the airport, brief articles and updates can help keep readers informed and engaged about the project. 4.1.2.4 Information Kiosk Many renewable energy projects can be developed with an information kiosk to provide visi- tors with information on the project and its benefits. Kiosks can be used to communicate broader information about related issues such as sustainability to provide context for the renewable energy project. The kiosk is an effective way to display real-time electricity generating data about the system which, if located on the building roof or remote section of the airfield, might not otherwise be visible. The data can also be communicated in ways that are more understandable to the general public. Examples include the system generates enough electricity to power X number of homes, or reduce enough pollution to remove Y number of cars from the road. The kiosk can also provide static information about the system’s specifications. An example of an information kiosk located at Albuquerque International Airport’s (ABQ) terminal is shown in Figure 4-1.

102 Renewable Energy as an Airport Revenue Source 4.2 Partner Selection Renewable energy projects have different business structures. Regardless, airports need to follow a public procurement process to select a knowledgeable private partner that can help the airport implement the project. Airports can work with their regular airport planning and engineering firm to prepare the bid documents; however, the structure of the bid process will depend on the role of the project partner. This section first describes the types of partners that could be procured and then describes the primary steps in the procurement process. Appen- dix F also includes three RFPs that were issued over the past year by airports for renewable energy projects. 4.2.1 Types of Private Partners There are several different types of services that airports may procure in implementing and operating a renewable energy project. 4.2.1.1 Consultant Airports may wish to conduct an evaluation of the renewable energy opportunities specific to their land and buildings. This would be a follow-up step to an initial evaluation using some of the modeling tools presented in Section 3.6. In such a case, the airport may procure for the services of a consultant to develop a renewable energy strategy or to conduct a renewable energy siting study. This work may be logically conducted as follow-up to a sustainability master plan or as part of a major multi-year airport renovation project. One benefit of such a study is that it can provide the airport with an independent roadmap on how to proceed with a renewable energy program as an exhibit to facilitate discussion. Figure 4-1. Solar project information kiosk in Albuquerque airport terminal.

Implementing Airport Renewable Energy Projects 103 4.2.1.2 Contractor If the airport is going to own the renewable energy facility, then it needs to bid for the services of an engineering, procurement, and construction (EPC) contractor to help it develop the proj- ect. For renewable energy installations, it is common to hire a turnkey installer who provides all of the equipment, installs the project, and commissions it prior to operation. For small solar PV projects, all of these services may be provided by a single electrical contractor. For large projects like a utility-scale wind turbine, there will likely be a general contractor who will oversee all of the work including site preparation, foundation design and installation, delivery of equip- ment to the site, design and construction of roadways, and integration of electrical infrastructure. The contractor and the equipment manufacturer will also stay involved with the project after construction to optimize the system’s operations and conduct initial stages of the maintenance program. Depending on the contracting arrangement and particulars of the warranties, these partners may remain involved in longer term O&M activities. 4.2.1.3 Third Party Developer If the airport seeks to lease property to a private entity to build, own and operate a renewable energy system, then it needs to select an experienced energy developer through a procurement process. The structure of the bid documents will differ if the airport is just leasing the land or also buying the electricity. When the airport is just leasing the land, it will specify in the bid pack- age the expected type of development and the available area, and request a qualified bidder and proposed lease price on a per acre basis. When the airport is also buying the electricity from the third party developer, it will require bidders to provide an annual cost for electricity through a power purchase agreement. 4.2.2 Procurement Process The procurement process is where the services required for the project are described and the eligible bidders are solicited to present their qualifications to complete the work and cost for the services. This is typically conducted through the issuance of a request for proposals (RFP) or a request for qualifications (RFQ). It is important that the solicitation package accurately and effectively communicate the services required so that the responses to the RFP/RFQ address the need. The key elements of the procurement process are described as follows. 4.2.2.1 Defining Project Scope The project scope focuses precisely on the services for which the airport seeks a partner and intends on entering into a contract. There are several major categories of projects for which airports may require services. First, the airport may seek a consultant to assess the feasibility of a renewable energy project. The project scope for such work will include evaluating the availability of renewable energy resources at the project site; reviewing available land and building locations, assessing potential candidate sites for airspace compatibility; preparing an economic analysis and considering avail- able financing options; and preparing recommendations for proceeding with next steps. The follow-on project scope will be defined by the conclusions of the feasibility study. If the air- port decides that it will own the facility itself, then it will issue a project scope of work for turnkey services to engineer, design, and construct the project. If the airport decides that it wishes to lease property to a private entity to build, own, and operate a renewable energy facility, then it will issue a project scope that details the characteristics of the project location that will be leased and type of facility that will be allowed. If the airport also seeks to purchase power from the facility, the scope

104 Renewable Energy as an Airport Revenue Source will also describe the minimum term of the intended purchase and provide a form of a contract that will govern the power purchase. In all cases, it is important that the project scope of work accurately and effectively describe the services that are sought. This will ensure that the bids that are received are comparable and address the services required by the airport. 4.2.2.2 Writing and Publishing the RFP The project scope of work is a fundamental element of the RFP as it details what services are sought. However, there are other important aspects of the RFP, including providing direction to bidders, to ensure that an eligible and qualified bidder can be selected. First, the RFP will provide general information about the airport, the administrative contact for the RFP, and context for the project. This will give bidders a broader understanding of the project. RFPs can also specify eligibility requirements and provide guidance on types of qualifications. For a renewable energy project, the RFP might specify that bidders must have installed a minimum number of renewable energy facilities to meet the eligibility requirement. The RFP may then specify the organization of the response to ensure that it can easily compare the information that it receives. It will also describe the evaluation criteria so it is clear to the bidders what aspects of the response will be important and the weight of the review if an evalu- ation score is also provided. The RFP will include a schedule for submission and evaluation. Once the RFP is published, there should be no direct communication between individual bidders and the airport to ensure that information about the bidding process is distributed openly and no preferential treatment is provided. Thus, bidders are often provided a forum and deadline for submitting questions to the airport, which are distributed with answers to all interested parties after the deadline. Deadline time and delivery location are specified and absolute to ensure that no single proposal receives any accommodations. The RFP may describe a process for short-listing bidders and/or interviewing a subset of bidders that are most qualified. A legal notice requesting proposals is often published in local newspapers and posted on the airport’s website on a page listing all of its current bid opportunities. The notice will often be distributed broadly through industry organization online newsletters, websites that list bid opportunities, and through social media. 4.2.2.3 Reviewing Proposals and Selecting the Contractor Once the airport receives the proposals, they are reviewed by an internal review team with airport expertise in planning, managing, and financing the airport activities. The reviewers will initially assess the eligibility of the bidder and completeness of the response. Then the reviewers will assess the adequacy of the response relative to the evaluation criteria. Typically, the technical Appendix F includes three RFPs issued by airports for renewable energy projects. Each RFP addresses a different business structure. F-1 is from Nashville (BNA) and it seeks a design and construction firm to provide a geothermal system that will be owned by the airport. F-2 is from Indianapolis (IND) and is an example of a straight land lease to a third party solar developer. F-3 is from Santa Barbara Airport (SBA) and is for a third party to build, own and operate a solar facility and execute a power purchase agreement with the airport to sell all of the electricity generated.

Implementing Airport Renewable Energy Projects 105 proposal and cost proposal will be reviewed and evaluated separately. In that way, the airport can determine the most technically qualified bidders without partiality to amount of the proposal, and then separately list the costs of each bid to select the bidder who is most technically qualified for the appropriate fee. The selected bidder will be notified and bid selection confirmed subject to negotiation of terms. 4.3 Contracting Process 4.3.1 Procurement for Construction Depending on the project, construction arrangements for a renewable energy project may be divided between supply agreements with equipment providers and “balance of plant” agree- ments with contractors who build the projects. Alternatively, a contractor will “wrap” all supply, procurement, and construction of the renewable energy project into its proposal. No matter how it is structured, a developer will typically look for the various contractors to provide completion guarantees, performance guarantees, and equipment warranties. This means that some combination of the contractor or equipment provider will (1) guaran- tee to complete construction of the project on time and that upon completion of construction the project will perform and produce energy at or above some pre-determined criteria; (2) guarantee that the project will perform at some pre-determined level for a period of time; and (3) warrant that the equipment and the workmanship will be free from defects. Typically, a developer will look to these contracting entities to provide some sort of guarantee of performance security to ensure that there is credit standing behind these obligations. Where applicable, the Power Purchase Agreement (PPA) generally includes performance standards such as delivery of a required minimum amount of electricity over a stated period of time and limita- tions on the amount of time that a facility can be inoperative in a given period. Airport operators should also note that affixing renewable energy projects to existing airport facilities, such as mounting a PV system on the roof of an existing terminal, can void certain existing warranties, such as a roofing warranty. Where new facilities are being affixed to existing facilities, the airport operator may wish to negotiate a risk shifting arrangement with the devel- oper to ensure that if a warranty is compromised by the project, the developer is responsible for making repairs made necessary by the development of the renewable energy facility. 4.3.2 Procurement for Power Purchasing Another issue that an airport will need to consider before entering into a PPA or another arrangement with a developer of a renewable energy facility at the airport is whether state or local law requires the airport operator to comply with applicable procurement or public bidding laws. Airports currently purchase power either through their utility service company or in blocks from a power broker. These purchases are customarily not subject to a public bidding process but rather overseen through annual budget management and approval by the airport’s govern- ing authority. Time requirements for public procurement are not consistent with the need to supply power. Long-term contracts, however, are planned investments and there may be state or local laws that trigger a public procurement. In most cases, entering into a PPA for a renewable energy project located on airport land will be subject to public procurement through the transfer of property use rights necessary for the private party to develop the project. The airport must go through a procurement process to lease or sell land to ensure that it receives the best available financial offer from the most qualified

106 Renewable Energy as an Airport Revenue Source bidder. If the airport is only leasing the land, then the financial benefit is provided by a proposed price per unit area over a designated term that must at a minimum meet the fair market value analysis prepared independently by the airport. If the financial benefit of the project is deter- mined by the PPA price and term, then the procurement for the property rights transfer will include a bid for the PPA. To ensure that the airport receives comparable bids that meet the needs of the airport, the bid package needs to provide specific information about the minimum requirements of the PPA, such as its term, and will usually include a form agreement for the PPA to ensure during the bidding process that the bidders will agree to it. The PPA should also conform to the latest FAA guidance to ensure the airport sponsor is receiving fair market value and will not be penalized should the system not produce enough power. 4.4 Regulatory Coordination and Processes The process of implementing the primary regulatory procedures—NEPA, FAA Land Use Review, and FAA Obstruction Evaluation—is summarized in the following sections. 4.4.1 NEPA Review The application of NEPA should be coordinated closely with the FAA ADO early in project planning. As described in Section 2.6.1, NEPA review will vary based on the extent of the pro- posed project development activity. As it is FAA’s responsibility to ensure that the proposed proj- ect has been implemented consistent with the NEPA regulations, the airport needs to work with the FAA to ensure that the FAA has obtained sufficient information to demonstrate compliance. Many renewable energy projects will meet the FAA’s categorical exclusion (CATEX) thresh- olds. As the first step in determining if the project is eligible for a CATEX, the sponsor needs to complete the Categorical Exclusion Justification Package which can be found on the FAA’s website under its Draft FAA Order 1050-1F (69). Preliminary evaluation should be conducted to determine if the project is consistent with any of the FAA’s CATEX listed actions. Those actions, which have been identified for past CATEX’s for renewable energy projects, are listed in Table 4-1 along with a new CATEX specific to solar and wind power projects that are part of the Draft FAA Order. A project that meets this list of categorically excluded actions is not automatically exempt from environmental review under NEPA. The responsible FAA official must also review Para- graph 5-2, Extraordinary Circumstances, before deciding to categorically exclude a proposed action. Extraordinary circumstances are factors or circumstances in which a normally categor- ically excluded action may have a significant environmental effect that then requires further analysis in an EA or an EIS. Impacts that may be determined to be classified under extraordi- nary circumstances include the following: historical and cultural resources; natural resources and wildlife; and inconsistency with local planning, traffic congestion, noise, air quality, water quality, and cumulative impacts. The CATEX documentation will need to address each of these issues. 4.4.2 Federal Airport Obligations The FAA has broad oversight at federally obligated airports. The obligations arise from the con- veyance of land or from grant agreements entered under federal legislation listed in Table 2-1. To comply with its obligations, airport sponsors must ensure during implementation that the renew- able energy project is consistent with the following standards.

Implementing Airport Renewable Energy Projects 107 4.4.2.1 Grant Assurances Compliance with grant assurances will be reviewed for any airport renewable energy project. If the airport is using AIP grants, the review of grant assurance compliance will be part of the FAA’s review and approval of the airport sponsor’s AIP application. If there is no FAA grant funding because the project will be implemented by a third party, the grant assurance review will be conducted as part of the FAA’s review of the property rights transfer. 4.4.2.2 Airport Layout Plan ALPs need to be updated every 5 years or longer if there have been no significant alterations at the airport. Interim changes to the ALP may be approved by the FAA; these are often referred to as “pen and ink” changes. Modifications to the ALP are considered a federal action and trig- ger the FAA’s evaluation to ensure that the change is consistent with NEPA. When a renew- able energy project is proposed at an airport, the sponsor will need to consult with the FAA to determine if an update to the ALP is required. The FAA’s Solar Guide recommends that solar facilities proposing to occupy a new footprint area need to be shown on the ALP while those that are collocated with an existing building do not (70). As more airports incorporate sustain- ability and renewable energy planning into their master plans, the FAA may see more ALPs with renewable energy uses designated in non-aeronautical use areas, which will facilitate FAA review of individual projects. 4.4.2.3 Fair Market Valuation As part of the FAA’s review of proposed lease agreements, it will evaluate information pro- vided by the airport sponsor to document that the value of the lease meets grant assurances associated with the airport obtaining FMV. FMV determinations for renewable energy projects will be different than for aeronautical uses such as hangar lease or non-aeronautical uses such as commercial space, and therefore, should not be compared to those uses. Typically, it will not be in the airport’s best economic interest to lease land for renewable energy that could be used for higher value uses. Demonstration of FMV will be similar to those obtained for agricultural 5-6.4 (n) Categorical Exclusions for Facility Siting, Construction, and Maintenance. Minor expansion of facilities including the addition of equipment on an existing facility where no additional land is required, or when expansion is due to remodeling of space in current quarters or existing buildings. 5-6.4 (r) Categorical Exclusions for Facility Siting, Construction, and Maintenance. Purchase, lease or acquisition of three acres or less of land with associated easements and rights-of-way for new facilities. 5-6.4 (aa) Categorical Exclusions for Facility Siting, Construction, and Maintenance. Upgrading of building electrical systems or maintenance of existing systems, such as painting, replacement of siding, roof rehabilitation, resurfacing or reconstruction of paved areas, and replacement of underground facilities. 5-6.3 (i) Categorical Exclusions for Equipment and Instrumentation. Approval of an ALP, federal financial assistance for, or FAA projects for: the installation of solar or wind-powered energy equipment, provided the installation does not involve more than three total acres of land (including the land needed for easements and rights-of-way associated with building and installing the equipment, and any trenching and cabling that would connect the installed solar or wind equipment to other parts of the airport or an existing electrical grid. Construction contracts or leases for this equipment must include requirements to control dust, sedimentation, stormwater, and accidental spills). Section # Section Name Description Table 4-1. FAA categorical exclusions for renewable energy projects.

108 Renewable Energy as an Airport Revenue Source leases. A public bidding process for a renewable energy project lease that demonstrates competi- tive price for the specified use with some comparison to other comparable alternatives (such as an agricultural lease) should suffice. 4.4.3 FAA Obstruction Evaluation Obstruction height zones are used to limit and regulate the height of objects that could other- wise cause a loss of navigable airspace, particularly within the vicinity of an airport in accor- dance with 14 CFR Part 77. This regulation (abbreviated as FAR Part 77) establishes standards and notification requirements for objects affecting navigable airspace. The regulations define a set of imaginary surfaces in the airspace around an airport. Any object (including structures, trees, movable objects, and even the ground itself) that penetrates one of the airspace surfaces is considered an obstruction. Wind turbines and power plant stack towers are examples of energy technologies that would require evaluation under FAR Part 77 whereas solar panels often are not tall enough to impinge into airspace. There are other parts of the airport design AC that also affect location of structures as obstructions on airport property including proximity to NAVAIDs (and potential for inter ference) and potential effect on air traffic control visibility. Part 77 functions chiefly as a device for notifying the FAA about proposed construction near an airport so that the agency can assess whether the object would be a hazard to flight. Project pro- ponents provide notification to the FAA using FAA Form 7460-1, Notice of Proposed Construc- tion or Alteration. Receipt of the notice enables the FAA to evaluate the effect of the proposed object on air navigation and chart the object or take other appropriate action to ensure continued safety. The FAA evaluates height concerns for land uses within the following five surface area clas- sifications: (1) approach, (2) transitional, (3) horizontal, (4) conical, and (5) departure. Part 77 specifies height and slope restrictions based on the surface area type. A graphical illustration of the Part 77 surfaces surrounding airport runways is provided in Figure 4-2. Additionally, any proposed object with a height of more than 200 feet requires notification, regardless of proximity to an airport. The U.S. Standard for Terminal Instrument Procedures (TERPS) defines another set of air- space protection surfaces for airports that utilize standard instrument procedures. The FAA uses these surfaces to design instrument procedures. In most cases, TERPS surfaces are higher than those of FAR Part 77 and less restrictive on the heights of objects. The FAA publishes (and regu- larly updates) charts showing the approved instrument approach and departure procedures for individual airports. These charts define where aircraft must fly to remain clear of obstructions near the airport. Any new object that penetrates one of the surfaces would require a modification to the procedure. While research for this guidebook suggests that the standards of review may be inconsistent between physical and non-physical impacts to airspace, it is important to note that the FAA has a rigorous process, which involves several lines-of-business with technical expertise for consid- ering potential hazards. Table 4-2 provides a listing of FAA divisions and their corresponding evaluation responsibilities. Most renewable energy projects proposed on airport property will require a formal review by the FAA’s OE/AAA Division. Any solar project located on airport property must conduct a glare analysis consistent with the Interim Solar Policy (71) and file the results with the FAA through the OE/AAA website (72). Wind turbines located adjacent to existing structures will likely rise up to the imaginary surface thresholds. Geothermal and fuel cell projects are unlikely to pen- etrate airspace, but cranes and drilling equipment required during delivery and construction may result in a temporary impact which is subject to FAA notification.

Implementing Airport Renewable Energy Projects 109 Filing with a Form 7460 is relatively simple. It can be done by accessing the OE/AAA website and inserting information on the location of the activity, height of structures, and attaching any supplemental documentation such as site plans and glare analysis that would facilitate the FAA’s review of potential airspace impacts. The FAA regulations require that applications be submit- ted a minimum of 45 days prior to construction and up to 90 days is more likely for receiving a determination. Source: Washington State Department of Transportation, Aviation Division Figure 4-2. Civil airport FAR Part 77 imaginary surfaces. Air Traffic Obstruction Evaluation Office (ATOES) FAR Part 77 requirements Air Traffic Operation Service Group (ATOSG) Coordination with air traffic control to identify any operation impacts Technical Operations (Tech Ops) Impact of NAVAIDs, electromagnetic and line-of-sight shadow interferences Flight Standards (FS) Review of proposals to determine the safety of aeronautical operations Flight Procedures (FP) Review of proposals to determine impacts on instrument procedures Airports (ARP) Identify impacts on different airport operations characteristics. Office Evaluation Responsibility Table 4-2. FAA divisions and evaluation responsibility for aeronautical studies.

110 Renewable Energy as an Airport Revenue Source 4.4.4 Connection to Electrical Grid The local utility that owns and operates the power and fuel infrastructure in the project area has required procedures for project proponents working near and interconnecting to the regional network. These include standard procedures such as notification to DigSafe for any excavation related activities. The most relevant application for renewable energy projects is interconnecting the project to the electrical grid. Because the airport must be connected both to the proposed electricity generation project to utilize the power when generating and to the grid to receive power from off-site when the renew- able energy facility is not producing, it is necessary for the proposed facility and its associated equipment to be grid-compatible and accessible to the utility company. The airport will want to contact the utility company during planning stages to discuss the pro- posed site and make sure that there are no unforeseen issues with physically connecting the project to the grid at that location. Once the project site and required facilities are confirmed, the airport can review the interconnection process that includes a formal site plan review to approve the inter- connection concept followed by a facilities plan review to engineer the associated interconnection facilities, cost and schedule. Where the proposed project is interconnecting to a single building meter, required facilities may be limited to sub-metering and shut-off switch to allow the utility the capability of disconnecting or shutting down the system in the event of maintenance activities or even a fire in the building. For utility-scale projects that connect to a substation or at another point into the electrical grid, additional facilities may be required to convert the power to a differ- ent form for transmission on the larger grid. These facilities are typically paid for by the developer but owned and managed by the utility. Meetings between the airport’s facilities team and the utility will help move along the analysis and approval process. 4.4.5 Other Relevant Permits Other permits may be required from local, state, and federal agencies depending on the affected resources and extent of impact. Most of these permits will be identified as part of the NEPA review. Some states, such as New York and California, also administer a state-level NEPA process which the project may also be subject to. Issues associated with other federal agencies such as endangered species will be addressed under the NEPA determination. Individual state permits for contaminated sites or water quality may be triggered and applications filed. Local permitting could include zoning and wetlands impacts. 4.5 Project Management Effective project management requires that one internal staff person be responsible for over- seeing and directing all of the various activities associated with planning and implementing a particular project. Project management skills are not specific to renewable energy projects; however, there will be some parties that require involvement and therefore coordination and communication. The project manager will oversee each of the processes described earlier. Effective project management includes identifying team members, communicating their responsibilities, providing a schedule for completion of interim milestones, and communicat- ing regularly with the team to ensure that the project is meeting expectations. Designating team leaders for individual tasks can help build the team structure and spread out responsibility. Task leaders might include planning, permitting, financing, procurement, and operations and

Implementing Airport Renewable Energy Projects 111 maintenance. Regular meetings with the team are useful for tracking progress and identifying challenges early when they can be effectively managed. Team leaders can then coordinate as appropriate with non-airport team members. For example, the planning team leader may be the appropriate lead contact with the FAA to ensure early and often coordination. The facilities team leader will likely already have a relationship with the utility and can speak their language. 4.6 Successful Implementation Over the past 8 years, airports have successfully implemented renewable energy projects. One of the important benefits of this guidebook is that it communicates the experience of those proj- ects to other airport readers who can apply the process and lessons learned to identifying and implementing their own projects. The case summaries presented in the next chapter discuss the various concepts described for projects that have been implemented and are now operational.

Next: Chapter 5 - Case Summaries »
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TRB’s Airport Cooperative Research Program (ACRP) Report 141: Renewable Energy as an Airport Revenue Source explores challenges airports may anticipate when considering renewable energy as a revenue source. These considerations include the airport’s geography and terrain, infrastructure, real estate, energy costs, public policy, regulatory and compliance requirements, tax credits, sponsor assurances, ownership, impacts to navigation and safety, security, staffing issues, and many others. The guidebook also includes detailed financial information on the cost and performance of projects that have been implemented by airports.

The guidebook also includes an appendix available online that provides sample a request for proposals.

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