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53 tion of an EIS. Section II supra provides guidance for the level of detail required, depending on where the airport sponsor is in the NEPA process. Technical consultants will play an integral role in developing the required documentation. Section III.B supra provides guidance for overseeing tech- nical consultants, with the guidance tailored to where the airport sponsor is in the NEPA process. For example, certain tasks (e.g., EIS preparation) must be performed by the federal government and cannot be performed by the airport sponsor. Therefore, an EIS contractor is to work on behalf of the FAA, whereas an EA consultant works on behalf of the airport sponsor. These and other nu- ances are addressed in Section III.B. Since the airport sponsor is typically responsi- ble for shepherding the NEPA process, it needs to be aware of all procedural requirements for public participation, including when the airport sponsor must make environmental studies available for public review, and when it must hold public hear- ings. Section III.E supra addresses the FAA crite- ria for public hearings and when they must be held, depending on the type of environmental re- view and whether special-purpose environmental laws are implicated. Requirements for the airport sponsor (or FAA) to publish environmental review documentsâto make them available for public reviewâvary depending on the scope of the pro- ject, its anticipated environmental impact, whether it implicates special-purpose environ- mental laws, and the status of the review (i.e., whether it is âdraftâ or âfinalâ). These publication requirements are addressed in Section III.D su- pra, and must be satisfied regardless of whether anyone has requested the documents. A related but different question is what to do when the pub- lic requests environmental review documents (e.g., preliminary drafts) that are not required to be published under NEPA or special-purpose laws. Whether preliminary drafts are public re- cords often depends on whether the documents were communicated between the airport sponsor and the FAA (which may depend on whether the technical consultant is working on behalf of the airport sponsor or on behalf of the FAA). These and other nuances are addressed in Section III.C. Most importantly, the airport sponsor must keep in mind that, regardless of who takes the lead role in environmental review, the airport sponsor will always ultimately have to get the FAAâs approval for any significant airport devel- opment project. Therefore, effective coordination of the process with the FAA is important at all stages of development planning and environ- mental review. Consultation with the FAA should begin when the airport sponsor first identifies a proposed development project to address its pre- liminary formulation of âpurpose and need.â The FAA may be able to suggest modifications (e.g., to the statement of purpose and need), alternatives to the proposed development project, or mitigation measures that will make the project more likely to withstand environmental review. For example, the FAA may be able to suggest changes that will make the project less likely to require an EIS (e.g., by introducing mitigation measures to re- duce environmental impacts below significance thresholds) or more likely to qualify for stream- lined environmental review (e.g., by reframing the purpose and need to focus on aviation safety or security). V. NEPA QUESTIONNAIRE A copy of the survey questionnaire that was used in performance of this study follows. The survey was delivered to the 400 airport sponsors who received the largest amounts of airport de- velopment grant funds from the FAA between 2004 and 2011.
