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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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Suggested Citation:"Appendix B - Case Studies." National Academies of Sciences, Engineering, and Medicine. 2010. Guidebook of Practices for Improving Environmental Performance at Small Airports. Washington, DC: The National Academies Press. doi: 10.17226/22897.
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285 A P P E N D I X B Case Studies

Airports must spend time and resources complying with applicable environmental regulations. Because regulatory compliance is the primary environmental goal at most small airports, it may be difficult to garner the support, both top-down and within the organization, necessary to implement proactive environmental stewardship practices. Receiving support, however, is essential to implementing any proactive environmental stewardship practice. Garnering support for initiatives can be hampered misconceptions by about the initial and long-term costs of initiatives, limited knowledge about implementation requirements, and lack of understanding the benefits. Airports can overcome these obstacles in two ways: (1) changing the institutional culture of the airport through education and working to foster an environmental mindset and (2) using a specific stewardship project to garner support and educate naysayers. This case study examines how a small airport obtained support for environmental stewardship projects and how the airport management cultivated an environmental mindset. Summary of Key Issues Establishing an environmental mindset, although often overlooked, is possibly one of the most important factors for enhancing an airport’s environmental stewardship and garnering support for environmental improvements. Ultimately, support and enthusiasm for improving environmental performance at an airport leads to development of innovative solutions, effective implementation of environmental initiatives, and ongoing airport stewardship. Case Narrative – Northeast Florida Regional Airport at St. Augustine Northeast Florida Regional Airport at St. Augustine (NFRA) is owned and operated by the St. Augustine - St. Johns County Airport Authority and is located four miles north of the central business district of St. Augustine, in St. Johns County, Florida. NFRA is classified as a general aviation reliever airport, according to the 2009 FAA National Plan of Integrated Airport Systems. NFRA is located on 668 acres and has two seaplane lanes and three runways, the longest measuring 7,996 feet. For the 12-month period prior to May 30, 2009, NFRA accommodated approximately 102,000 operations. APPENDIX B-1 Garnering Support within a Small Airport Organization to Initiate Proactive Environmental Stewardship Activities Problem Statement 286 Guidebook of Practices for Improving Environmental Performance at Small Airports

• Use of pervious pavement in the terminal parking area • Construction of an eco-park on airport property • Development of a Sustainability Management Plan Implementation of these projects has required staff to obtain approval from the Airport Director and the Airport Authority Board (Board) (see Figure 3). Figure 3. Northeast Florida Regional Airport at St. Augustine organizational chart. Obtaining Airport Authority Board Support NFRA management (including the Airport Executive Director and Assistant Airport Director) targeted the Board for establishing a supportive culture for environmental stewardship, because the Board controls airport development. The following efforts were conducted to garner Board support. Environmental Stewardship Initiatives at Northeast Florida Regional Airport at St. Augustine NFRA has demonstrated a commitment to environmental stewardship through implementation of a number of proactive initiatives. These initiatives include: • Enhanced Storm Water Pollution Prevention Plan (SWPPP)/Spill Prevention Control and Countermeasure (SPCC) training • Low impact hangar development, which minimized environmental impacts by designing airport facilities around trees, resulting in an unconventional hangar layout Appendix B 287

Communicating Life Cycle Costs NFRA found that even during the economic downturn, the Board continued to authorize environmental improvements despite the increased upfront cost. To obtain Board approval of environmental stewardship projects, the project champion promoted the concepts of lifecycle costs and environmental and social benefits of the projects. NFRA management has not always had to use hard numbers to obtain approval for projects. Instead, it approached the Board with a general explanation of the potential environmental, social, and financial benefits over the life of the project. For example, when pursuing approval for use of pervious pavement in the terminal parking area, NFRA management justified increased capital costs with a financial analysis that considered lifecycle costs. NFRA management also qualitatively described the benefits and savings that would occur over the life of the project. The savings were realized from the increased durable life of the permeable pavement as well as avoidance of construction of a retention pond (required for traditional impervious pavement). Building a retention pond would have been both costly and difficult to approve due to potential wildlife attracting attributes of the pond. NFRA staff theorizes that this strategy of qualitatively describing the factors driving different costs and savings over the life of the project has been successful due to the positive and trusting relationship NFRA management developed with the Board. The Importance of Emphasizing Environmental Benefits There is a dynamic interplay between promoting the financial and environmental benefits of a project. A project’s approval process typically focuses on either costs or regulatory compliance, depending on the stakeholder(s) reviewing the project. Less tangible environmental and social benefits, however, are also important and often overlooked because they are difficult to quantify. NFRA found that promoting a project by emphasizing and continually reiterating its environmental benefits facilitated NFRA’s efforts. In NFRA’s experience, too much emphasis on the financial aspect of the project often diverts the stakeholder’s focus away from the potential environmental improvements. Some intangible benefits to highlight include expedited environmental permitting; community acceptance of the project; improved rentability and/or tenant acceptance; reduced environmental, health, and safety risks; improved work environment for employees leading to higher productivity; and enhanced relationships with the surrounding community. Case Study Project #2, Low Impact Hangar Development, described below, provides an example of implementing this strategy. Promoting Environmental Stewardship with Community Stakeholders In the recent past, environmental stewardship has gained increasing public attention in Florida and across the nation. Accordingly, environmental issues are increasingly important to elected officials. As with many airports, NFRA’s neighboring community is often concerned about its environmental impacts. Communicating Environmental Benefits For many projects NFRA must obtain environmental permits from the Florida Department of Environmental Protection, St. Johns River Water Management District, the U.S. Army Corps of Engineers (USACE), and/or the U.S. Fish and Wildlife Service (USFWS). NFRA used its proactive environmental program to enhance this permitting process. NFRA management then leveraged the success of the permitting process to receive continued support for environmental improvements from the Board. Awareness of the permitting benefits of environmental stewardship resulted in the Board members becoming more enthusiastic and increasingly supportive of initiatives that go beyond regulatory requirements, despite increased costs. This is evident through the Board’s support for the low impact hangar development project and the use of pervious pavement. 288 Guidebook of Practices for Improving Environmental Performance at Small Airports

Figure 5. A patch of preserved trees that resulted from low impact hangar development project at Northeast Florida Regional Airport at St. Augustine (16). Figure 4. A portion of the constructed seaplane dock at Northeast Florida Regional Airport at St. Augustine (16). Construction of a floating dock alongside the airfield was required for NFRA to maintain its seaplane business. (see Figure 4) The project was estimated to cost $150,000, of which approximately $25,000 - $30,000 was required to exceed compliance requirements and enhance the environmental attributes of the area surrounding the structure. These improvements resulted in proactive mitigation for potential fuel spills by providing facilities that contain the necessary equipment and materials for containing fuel spills. The improvements also proactively avoid oyster beds by constructing a floating dock to extend into the water and separate all aircraft activity from the sensitive shoreline oyster habitat. Although these benefits could not be quantified, emphasizing the importance of the initiative was necessary to obtain approval for the project. This project ultimately addressed existing environmental issues and lowered environmental risk. Case Study Project #2: Low Impact Hangar Development When planning a hangar development project in a previously forested area on airport property, NFRA implemented a policy to design the hangars around the existing trees and vegetation in order to conserve old growth trees and maintain local biodiversity. (see Figure 5) Wherever this was not possible, NFRA opted to relocate trees. Although this approach resulted in a substantial increase in capital costs and in fewer hangars being built, NFRA was able to save approximately 200 trees and avoid associated costs of clearing the site. In addition, to help justify upfront costs, NFRA is charging more use for of the new hangars. Justified in part because of the enhanced aesthetic and newer structure enabled it to match the return of investment for traditional hangar development projects. When first proposed, the hangar development was controversial and poorly received due to its intrusion and impact on the neighboring community. In addition, many of the public’s comments were related to the development’s impact on vegetation and old- Case Study Project #1: Construction of a Seaplane Dock at the Airport NFRA strives to continually promote its proactive environmental stewardship practices to assist in situations where the public voices concern or opposition to a project. Showing the public that NFRA is a leader on environmental issues also fosters continued Board support and helps gain approval on future projects. Because the Board members are publicly elected, they are held accountable by their constituents. As a result, the Board’s decisions are often tied to the needs and interests of the public. hydraulically operated doors, NFRA’s pricing Appendix B 289

Figure 6. New low impact hangars at the Northeast Florida Regional Airport at St. Augustine (17). including conducting one-on-one interaction with stakeholders, educating local community groups on the benefits of the project, and encouraging local press coverage. Ultimately, the driver for the project was public good. However, a number of other intangible benefits resulted from the project: NFRA has been recognized at the local and state level for its achievement, winning an environmental award from Florida Airports Council; the project created an aesthetically pleasing and shaded locale for the hangars, for which NFRA received positive feedback from its tenants; and finally, preserving this vegetated area allowed NFRA to continue to benefit from the ecosystem services the area provides, such as water filtration and carbon sequestration. With the first phase of the hangar development now completed, its benefits have become increasingly apparent to NFRA and its Board, which in turn motivated further environmental stewardship at NFRA. The six new hangars are illustrated in the bottom right quadrant of Figure 6. Fostering an Environmental Mindset at Northeast Florida Regional Airport at St. Augustine NFRA employed a number of strategies to foster a change in the environmental mindset within the airport. Some examples of strategies NFRA used to influence the environmental culture within the airport and community include: • To promote environmental stewardship with tenants, NFRA used training sessions, required to comply with its SWPPP, to obtain authorization to use the aircraft washrack to promote environmental stewardship. NFRA incorporates discussion of environmental best practices into training sessions. NFRA found after raising a general awareness of environmental issues, tenants more proactively alter their behaviors. • NFRA regularly invites members of the community and local organizations to use its meeting rooms. NFRA’s environmental champion will often use these opportunities to promote NFRA’s environmental stewardship activities. This in turn fosters a positive mindset within the community, and provides recognition and encouragement to NFRA. • NFRA also engages the community through ongoing internships and outreach programs with local high schools and universities. Through NFRA’s experience, shaping the environmental mindset of decision makers and airport staff takes time. As described throughout this case study, NFRA uses communication as its primary tool for enhancing the decision makers and staff environmental mindsets. NFRA continually seeks to create opportunities to share environmental stewardship practices with airport stakeholders. focus on conservation. In addition, NFRA initiated extensive public outreach to gain community support, growth trees. In response to the public’s concerns, NFRA opted to alter the design and approach of the project to enhance the conservation of environmental resources. A concerted effort and strategic approach was required in order to receive Board approval for the project. One Board member was a vocal champion for the project, which enhanced internal support for the project; and the project design team actively sought to mitigate costs while retaining the project’s 290 Guidebook of Practices for Improving Environmental Performance at Small Airports

The following sections describe some elements for other small airports to consider, based on NFRA’s experience, when seeking to garner support for environmental stewardship within its organization. Obtaining Support for an Environmental Stewardship Project Institutional change of any form cannot occur without the presence of a change agent. At NFRA, the Assistant Airport Manager is the primary advocate for environmental stewardship, but the advocate role may be other personnel depending on the resources available at the airport. There are a number of stakeholders whose support is needed to advance projects, these may include: • Airport Director • Airport Board • Airport staff • Public/local government • Tenants • Other stakeholders To receive support for specific projects, it is important to understand the motives of the stakeholders involved in the decision-making process. Although costs are often one of the most essential elements to receive support for a project, personal and political motivations can also drive decision-making within organizations. To receive support from a stakeholder, the change agent must craft the discussion to cater to the stakeholders motivations. For example, an Airport Director will often require a financial analysis of the project, the environmental officer will focus on compliance with applicable requirements / regulations, and members of an elected Board will have interests that match their constituents’ concerns. Cultivating an Environmental Mindset When seeking to implement proactive environmental stewardship practices, airports should consider developing a strategy for fostering a culture of change within the organization. Some elements to foster organizational change may include: • Designating a program champion or change agent. The change agent would be responsible for promoting environmental improvements within the organization as well as raising general awareness of environmental opportunities and performance. • Collecting and disseminating information internally. Awareness of the airport’s baseline performance enables an understanding and appreciation of opportunities and the need to reduce airport impacts. Some examples of data to collect include: - Current environmental impacts, quantified in both economic and environmental terms (e.g., energy costs, greenhouse gas emissions; water consumption, etc.). - Benefits of initiatives (e.g., economic, environmental, community relations, permitting, etc.). • Educating staff, formally through training opportunities; and informally through verbal communication and participation in initiatives. Findings and Key Considerations: Applying Lessons Learned at NFRA to Other Small Airports NFRA found that incorporating environmental considerations into its long-term planning enabled it to foster an environmental mindset that has come to shape the organization’s core. Presently, NFRA is focusing on environmental considerations by developing a long-term sustainability plan. Appendix B 291

• Providing a forum for staff and the community to share ideas. “Ultimately, environmental stewardship is a way of thinking. It is achieved by constantly finding opportunities to point out the benefits of going beyond minimum compliance.” Bryan Cooper, Assistant Airport Director at St. Augustine – St. Johns County Airport. References/Additional Resources St. Augustine/St. Johns County Airport: www.staugustineairport.com/ • Organizational Change for Corporate Sustainability. Dexter Dunphy, Andrew Griffiths, and Suzanne Benn. Routledge, New York: 2003 • The Sustainable Enterprise Fieldbook. Ed Jeana Wirtenberg, William G. Russell, and David Lipsky. Greenleaf Publishing, New York: 2009 • Green to Gold: How Smart Companies Use Environmental Strategy to Innovate, Create Value, and Build Competitive Advantage. Daniel Esty and Andrew Winston. Yale University Press, New Haven: 2006 • The Sustainability Champion's Guidebook: How to Transform Your Company. Bob Willard • Step-by-Step Guide to Sustainability Planning: How to Create and Implement Sustainability Plans in Any Business or Organization. Darcy Hitchcock and Marsha Willard. • Enhancing community interest in the airport’s environmental performance by: o Communicating the airport’s environmental performance. o Promoting environmental stewardship activities the airport is implementing. o Involving the community in airport activities (e.g., internships). • Rewarding staff for taking initiative and identifying opportunities to improve environmental stewardship. Rewards can be public recognition, monetary, or other compensation. • Incorporating environmental metrics and goals into performance reviews. 292 Guidebook of Practices for Improving Environmental Performance at Small Airports

APPENDIX B-2 Implementing an Environmental Management System to Facilitate Compliance and Reduce Environmental Impacts at Small Airports Problem Statement As operating budgets shrink, airports are still required, as a minimum, to meet regulatory requirements. In addition, local governments and elected officials sometimes expect airports to go beyond compliance and address initiatives like climate change and greenhouse gas emissions, more stringent water quality requirements, energy consumption, and reduced impervious areas. The management of these initiatives is well suited to the principals and use of an Environmental Management System (EMS). An EMS can be designed to fit a small airport and prioritize initiatives according to the management goals and environmental impacts of the airport. Summary of Key Issues An EMS is simply a set of processes and practices that will enable an airport to reduce its environmental impacts and increase its operating efficiency. An EMS provides a highly effective means for airports to manage and prioritize environmental issues. The EMS process identifies an airport’s environmental risks and systematically works to reduce them. Entities with a well-established EMS commonly report increased operational efficiencies, cost savings, reduced environmental liabilities, and increased employee morale. An EMS is a plan, do, check, act program designed to reduce an airport’s environmental impacts. Through an EMS, an organization determines its environmental impacts, forms a plan for reducing those impacts, implements the plan, tracks progress, and then reevaluates their plan. The needs for an EMS differ by airport. However, an EMS commonly provides the following: • A forum to organize and track environmental compliance and environmental initiatives across an entity with decentralized environmental responsibilities • Improvement of environmental compliance and a decrease of environmental risks • Reduction of direct and indirect environmental-related costs and increased operational efficiency • Organization of environmental initiatives that go beyond compliance • Improved regulatory relationships and opportunities for grants • Improvement of public environmental perception. The International Organization for Standardization (ISO) has developed a standard for the implementation of EMSs, and only a handful of U.S. airports have developed EMS that are certified under the ISO 14001:2004 standard. There are a number of terms that have special meaning when used in context with EMS. Table 3 provides definitions for these terms as used by EPA, ISO 14001:2004, and in this case study for reference: Appendix B 293

Table 3. Environmental Management System terms and definitions. Term EMS Definition Activity, Product, or Service Broadly covers all the possibilities for an organization to have an influence on the environment, both positive and negative, and may be referred to simply as activities or processes. ISO 14001 International standard for “Environmental Management Systems – Requirements with Guidance for Use” which provides the overall requirements for developing and sustaining an EMS that may be objectively audited for certification/registration purposes or for self declaration. ANSI/ISO 14001:2004 American National Standards Institute standard for EMS developed in 1996 and modified in 2004 in collaboration with the international version titled ISO 14001. Environment Surroundings in which an organization operates including air, water, land, natural resources, flora, fauna, humans, and their interrelation. Environmental Aspect Element of an organization’s activities, products, or services that can interact with the environment. Environmental Impact Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s environmental aspects. Environmental Management System The part of an organization’s management system used to develop and implement its environmental policy and manage its environmental aspects. It is a set of interrelated elements (organizational structure, planning activities, responsibilities, practices, procedures, and resources) used to establish and achieve environmental performance objectives. Environmental Objective An overall environmental goal, consistent with the environmental policy, that an organization sets itself to achieve. Environmental Performance Measurable results of an organization’s management of its environmental aspects. Results can be measured against the organization’s environmental policy, environmental objectives, environmental targets, and/or other environmental performance requirements. Environmental Policy The overall intentions and direction of an organization related to its environmental performance as formally expressed by senior management. It provides a framework for action and for the setting of environmental objectives and targets. Environmental Target Detailed performance requirements, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives. Internal Audit A systematic, independent, and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the environmental management system audit criteria set by the organization are fulfilled. Note: May also be referred to as EMS Audit. Procedure A specified way to carry out an activity or process. Significant Environmental Aspect An environmental aspect that an organization determines has, or has the potential to have, a significant impact on the environment. Case Narrative—Westchester County Airport The Westchester County Airport (HPN) was the third U.S. airport to receive ISO 14001:2004 certification for its EMS in 2004, and received the Environmental Achievement Award from Airport Council International-North America for its program in 2005. HPN is owned and operated by Westchester County (County), in White Plains, New York, and is considered a small hub airport by the 2009 FAA 294 Guidebook of Practices for Improving Environmental Performance at Small Airports

National Plan for Integrated Airport Systems. HPN is predominantly a general aviation airport, as described in Table 4. Table 4. Westchester County Airport National Plan of Integrated Airport Systems data. HPN Annual Operations Percent of Total Operations Air Carrier 13,478 8% Air Taxi 46,612 27% General Aviation 94,892 55% Itinerant Military 161 0% Civil 16,337 10%Local Military 30 0% Total Operations 171,510 Initially, when considering an EMS, the Airport upper management and County officials had several concerns, including: • What is an EMS? • Why do we need an EMS for the airport? • Is an EMS simply a way to achieve compliance with applicable laws and regulations? • How much will it cost? • Why do we need a consultant to do this? • Do other airports or government organizations have an EMS? • What is a certified/registered EMS? • Do we need our EMS to be registered/certified? • Will the EMS require us to make information public about the Airport we may not wish to publicize? • Will an EMS help our relationships with regulators and the public? It is likely that these concerns are similar to the concerns raised by many airports when considering an EMS. This case narrative describes the benefits and challenges experienced and overcome by HPN during the implementation of their EMS, and the answers to these questions based on their experience. Initiative Driver Runoff from portions of HPN discharges into small tributaries to the Kensico Reservoir, which provides about 90% of New York City’s and much of Westchester County’s drinking water. In 1999, community groups were concerned over claimed HPN discharges to the Kensico Reservoir, particularly that groundwater was affecting the Kensico Reservoir. The County hired Environmental Project Director, Robert Funicello to conduct an environmental audit of HPN and its tenants to determine if the Airport was in fact polluting the groundwater aquifer that serves the Kensico Reservoir, and to generally assess the status of the Airport’s environmental compliance. After considering the airport’s situation, Mr. SOURCE: FAA National Plan of Integrated Airport Systems, 2009-2013 (18). Funicello recommended the Airport implement an EMS as a better way to address concerns about HPN’s environmental impacts, for the following reasons: • An environmental audit would have provided a snapshot of HPN’s environmental compliance status, while an EMS provides an ongoing measure of HPN’s performance and a means for continually addressing concerns from the community. • An EMS provides a means for HPN to implement initiatives for environmental performance beyond compliance with their New York State Pollutant Discharge Elimination System (SPDES) permit. Appendix B 295

• An ISO 14001:2004 EMS is certified by a third party auditor, providing additional credibility to environmental results. Mr. Funicello contacted a consultant with experience implementing EMS, and invited representatives from a local industry that had recently implemented an EMS to speak with Airport upper management and County officials about an airport EMS. Based on information from the consultant and the local industry’s experience with an EMS, the County officials decided to proceed with procurement of the consultant services needed and other actions to design and implement an airport EMS. Implementation Strategy The County procured an environmental consultant to assist them in the initial implementation of the airport EMS. The decision to hire a consultant was primarily because the requirements of the ISO 14001 standard are complicated, and County staff did not have experience implementing EMS. With the assistance of their consultant, the County assembled four groups of people to oversee the airport EMS: • Technical Committee • Working Group • Advisory Committee • Steering Committee The Technical Committee currently consists of 18 members, including: • Representatives for County Departments involved in Airport Operations • Department Managers from the contractor that operates HPN • Tenants’ and Permittees’ Environmental Representatives The Technical Committee is responsible for identification of activities, products, and services conducted at HPN, including tenant and contractor operations. The Working Group is a subset of the Technical committee and consists of the: • Department of Transportation Environmental Project Director • Airport Environmental Manager • Airport Manager • Airport Assistant Manager The Working Group is responsible for preliminary identification of environmental aspects and impacts associated with the activities, products, and services identified by the Technical Committee. The Working Group also develops the criteria used for determining which aspects could potentially have significant environmental impacts. At least once every three years, the Technical Committee evaluates HPN’s environmental impacts based on the criteria developed by the Working Group to determine which aspects and impacts are considered significant. The Advisory Committee currently consists of 10 members including commissioners from eight County departments involved with operations at HPN. The Environmental Manager and Environmental Project Director communicate HPN’s significant impacts to the Airport Advisory Committee, and the Committee is responsible for communicating the significant impacts within their Department. 296 Guidebook of Practices for Improving Environmental Performance at Small Airports

The Steering Committee is responsible for review of the policy statement, criteria for determining the significance of HPN environmental impacts, and objectives and targets developed to reduce HPN’s significant negative environmental impacts. The Steering Committee consists of: • County Executive • Commissioner of the Department of Transportation • Commissioner of the Department of Health The initial development of the airport EMS started with the authoring of the Environmental Policy Statement by the Working Group with the assistance of the consultant. HPN’s Environmental Policy Statement, which was reviewed by all Committees associated with the airport EMS, and ultimately signed by the County Executive in 2002, states: The Westchester County Airport is committed to achieving excellence in environmental protection by integrating environmental values into airport activities. This will be accomplished through the continual improvement of airport-wide environmental management practices and the environmental education of employees. The principles that guide the effort to achieve excellence in environmental protection include commitments to: Conservation of Natural Resources, Sustainable Operations and Prevention of Pollution Study, identify and implement programs to preserve the natural environment, conduct sustainable operations, including conservation of energy and nonrenewable resources, and prevent pollution; Mitigation of Environmental Harm Carry out Airport operations in a safe and efficient manner that minimizes adverse environmental impacts; Compliance Fully comply with and, if feasible, exceed the requirements of all environmental laws, regulations, and all other requirements to which the Airport subscribes; and Inform the Public Make available to all interested stakeholders airport environmental performance reports. To ensure our success, the Westchester County Airport will maintain an environmental management system in conformance with the requirements of the ISO 14001 Standard. This system will include implementing programs and procedures, setting measurable objectives and targets, and monitoring and auditing our progress. The protection of the environment is essential and Westchester County is committed to achieving environmental excellence (19). The Environmental Policy Statement provides the principles by which the Airport conducts its airport EMS. The fact that the Environmental Policy Statement is signed by the County Executive and published on the HPN website illustrates the commitment of the upper management to seeing the airport EMS applied successfully. Airport staff, tenants, contractors, regulators, neighbors and community groups can see the importance the County places on its environmental performance, and the airport EMS. Appendix B 297

Initiative Outcome and Current Status The County has implemented many initiatives through the airport EMS to reduce the Airport’s environmental impacts, including the following: • Installation of storm drain markers and storm drain filters to reduce illicit discharges • Enhancement of environmental training for staff, tenants, and contractors • Identification, remediation, and closure of historic spill sites • Incorporation of material storage locations in the Airport GIS • Investigation of groundwater concerns of the community and implementation of ongoing groundwater monitoring – 52 wells sampled semi-annually • Additional monitoring of noise • Replacement of diesel and gasoline engine vehicles with electric vehicles • Conducting an air emission inventory • Source reduction and capture of aircraft deicer The primary objective for the first year of implementation of the airport EMS centered on understanding the quality of the groundwater at HPN. HPN coordinated with the New York Department of Environmental Conservation, the New York Attorney General, and other stakeholders to set up voluntary groundwater monitoring at over 50 wells at HPN. Although the groundwater monitoring results showed that the groundwater at HPN is not impacting the Kensico Reservoir, the results revealed areas of historical spills where the groundwater is affected by other pollutants. As part of subsequent objectives and targets established through the airport EMS, HPN has worked with New York Department of Environmental Conservation and the parties responsible for the contamination to remediate many of these sites. HPN continues to monitor the groundwater wells semi-annually and publishes the report on their website. Additionally, the Airport banned the use of ethylene glycol-based aircraft deicers and switched to the less toxic propylene glycol-based aircraft deicers to mitigate the risk of ethylene glycol reaching the groundwater or surface water at HPN. The Airport contracts with a company to apply deicer at a centralized deicing pad at HPN. The contractor uses deicing trucks that use a combination of pressurized air and fluid to remove snow and ice, and has recently started efficient mixing of Type I deicer to minimize the amount of propylene glycol in the mix sprayed on the aircraft to the amount required by FAA to provide the proper freezing point depression depending on the outside air temperature. The Airport then collects runoff contaminated with aircraft deicers and discharges it to the sanitary sewer, or hauls it away for treatment. The Airport also implemented the use of catch basin inserts to prevent fuel and oil spills from reaching the storm water system. As a result of HPN’s detailed groundwater monitoring program that was established, maintained, and reported through the airport EMS, and the way HPN addressed the findings of the groundwater monitoring through subsequent airport EMS objectives, the many citizens’ concerns have been addressed, and most citizen groups now feel more confident that HPN will actively identify and address future groundwater and other environmental concerns. The Airport also enhanced its noise program as part of the airport EMS in an attempt to reduce the number of noise complaints filed by neighbors. Additional noise monitors were added and HPN tenants participate in a voluntary curfew to reduce aircraft noise at night. Every year the Airport gives Spirit of Noise Abatement awards to tenants that follow the voluntary restraint from flying hours (12:00 to 6:30 am) and do not trigger a high-range noise event. HPN has a noise complaint hotline and publishes a monthly noise newsletter with results from the month’s noise monitoring to keep citizens informed of the efforts the Airport and its tenants are making to reduce noise. 298 Guidebook of Practices for Improving Environmental Performance at Small Airports

In 2007, HPN prepared an air emissions inventory to understand HPN’s relationship to the issue of air pollution and climate change. As part of the airport EMS HPN has developed an air emissions inventory management plan to maintain compliance with regulatory requirements, anticipate and prepare for future regulatory requirements, develop strategies for managing greenhouse gasses, and report HPN’s environmental performance. The County replaced the Airport GSE fleet of diesel and gasoline vehicles with electric-powered vehicles in 2009 through the Voluntary Airport Low Emissions program and the airport EMS. This initiative sparked an article in the New York Times, and HPN received a letter from the local Sierra Club congratulating it for the reduction in air emissions. An important element of the airport EMS is the environmental work orders. Any staff member, tenant, or contractor may file an environmental work order, and these work orders must be addressed by the environmental staff and be summarized annually for management review. Typical examples of work order include the following: • Need more properly labeled recycling bins • Waste container needs a lid • Procedure for operation of deicing pad needs revisions ISO 14001:2004 Certification The County decided to apply for ISO 14001 certification for its airport EMS for several reasons: • Being certified gave the program permanency. Once HPN was certified the first year, there was public pressure to maintain that certification. If HPN failed to be certified in the future, it would have to explain to the public why it was unable to maintain the certification. • In order to be ISO 14001 certified the EMS must be audited by a third party certified ISO auditor annually. The third party verification gives credibility to HPN’s environmental results, especially skeptical community groups. • The ISO 14001 certification provided additional assurance to the public that HPN is environmentally responsible. The County hired an environmental consultant with experience implementing EMS to assist with the initial implementation. The consultant assisted the Airport with understanding the ISO 14001:2004 process, developing the environmental policy statement, identifying HPN’s aspects and impacts, assessing the significance of the impacts, and preparing for the ISO 14001:2004 audit. Once Airport staff was comfortable with the process, they were able to conduct subsequent assessments of HPN’s impacts on their own. The County continued to use the consultant for several years to conduct compliance audits in preparation for their annual ISO 14001:2004 audits. Perceived Benefits The airport EMS provides a framework for the Airport to: • Systematically identify the environmental impacts associated with HPN activities, products and services, • Coordinate staff responsibilities for implementing initiatives to reduce negative impacts, and • Track progress on environmental objectives. The working group meetings involve personnel from many Departments in the County that otherwise would not communicate regularly on environmental issues. The airport EMS has facilitated this communication, allowing other important non-airport EMS information to be easily disseminated across Appendix B 299

the departments. The environmental work orders allow employees to feel empowered. Any employee can file one, and it must be addressed by the environmental staff. Because of the additional emphasis placed on environmental work, the way environmental performance is tracked, and the fact that staff get to meet with upper management through the airport EMS, morale has increased for staff with environmental responsibilities as they feel their work is important to the organization. The airport EMS allows the Airport to continually improve its environmental performance and monitor the status of its compliance with environmental regulations. Through the EMS the Airport is proactive regarding environmental impacts at HPN rather than reactive. The EMS allows the Airport to identify and manage risks, and anticipate and handle environmental concerns before they become an environmentally regulatory or public issue. The EPA conducted an intensive multi-media audit of HPN after implementation of the airport EMS. The audit revealed no violations. Since HPN is more aware of its environmental performance and compliance status it is better able to meet all regulatory requirements. Through the EMS, the Airport’s relationship with state and federal regulators has improved significantly. The reporting system set up as part of the EMS allows the Airport to be transparent in reporting its environmental performance. The Airport’s aspects, impacts, objectives, and targets are published on its website, and the County publishes a monthly newsletter detailing the noise data from the past month. Environmental impacts from operations and development at HPN are often hot button issues for the local County election. This past election was the first in many years where HPN was not a significant issue in the election. The electric vehicles save HPN approximately 100,000-gallons of fuel annually, and significant dollars after the cost of electricity. The newer vehicles also require less cost for maintenance than the diesel and gasoline vehicles did. Switching to electric vehicles eliminated the second-largest source of criteria air pollutants at HPN. Obstacles Encountered Although most HPN staff support the airport EMS, there have in the past been a few that opposed it. Dealing with problem employees has been a challenge for HPN, but routine training and active involvement by environmental staff and management have kept such staff problems to a minimum. Numerous tenants and contractors operate on HPN property and are included in the airport EMS. Ensuring tenants and contractors operate in compliance with environmental laws and encouraging them to participate in airport EMS initiatives is difficult since they are not under direct control of the County. The County occasionally has difficulty with contractors because they are more transient than tenants and their operations often have the potential to significantly impact the environment. HPN staff has discontinued the use of one area for construction mobilization because it is near an environmentally sensitive area to mitigate the risk of spills and leaks from contractor’s equipment from affecting that area. Again, regular inspection of contractor’s sites and training keeps HPN informed of tenant and contractor operations and identifies potential compliance issues before they become a problem. In an effort to promote the airport EMS to tenants and contractors, HPN requires all contractors to undergo environmental training before they are permitted on HPN property. The airport EMS training typically takes about an hour, and is incorporated into the required FAA safety and TSA security training program for contractors. The training requirement, as well as the airport EMS best management practices and initiatives applicable to contractors are specified in the County bid solicitations for work at the Airport. Contractors are aware of the requirements and can take them into account when they submit for a 300 Guidebook of Practices for Improving Environmental Performance at Small Airports

project. All staff, tenants, and contractors are also given a card that contains information about the airport EMS, including the answers to these airport EMS frequently asked questions: • What is the Environmental Policy? • Who do I call in case of a spill? • What is my role in the airport EMS? • What is an environmental work order? • Is there anything special about ISO? • Will an ISO auditor talk to me? • What do I need to know about the airport EMS? • Who can I ask if I have questions about the airport EMS? Critical Success Factors Several actions by the County contribute to the success of the airport EMS, including: • Getting buy-in from upper management before rolling out the program establishes the importance the County placed on successful implementation of the airport EMS • Involving staff from a broad range of Departments in the Technical Committee facilitates horizontal communication through the organization • Transparency in reporting environmental performance to the public enhances the public opinion of HPN • Strategic selection of initiatives to target hot button items fosters public support • Obtaining ISO 14001:2004 certification provides permanency to the program • Utilizing environmental work orders empowers staff to participate in the airport EMS After the initial implementation of the program, HPN strives to keep their staff, tenants, contractor that operates HPN, and other contractors actively involved in the airport EMS. In an effort to maintain excitement about the program the County has implemented several programs, including: • Annual Spirit of Noise Abatement Awards for tenants that do not fly during the voluntary curfew hours of 12:00 a.m. – 6:30 a.m. and do not cause a high range noise event • Speakers that present the benefits of airport EMS to staff. Food is typically provided at these events to encourage attendance Communication from upper management to key personnel of the importance the airport is placing on the success of the EMS and its initiatives is critical to achieving active staff participation. Estimated Level of Effort Overall, there are currently 30 people in the committees involved in the planning, development, and implementation of the airport EMS including County representatives, Tenant representatives, and representatives from the Contractor that operates the airport. The Technical Committee meets quarterly and the other committees conduct annual reviews of the activities, aspects, impacts, significant criteria, objectives, and targets. The Environmental Director devotes approximately two and a half days per week to the airport EMS. The Airport Environmental Manager supervises the airport EMS full time and directs environmental staff at HPN with airport EMS responsibilities. HPN environmental staff in addition to the Environmental Director: • Environmental Manager • Noise Officer • Environmental Officer • Environmental Data Specialist Appendix B 301

• Three Environmental Technicians • Two Environmental Mechanics Table 5 summarizes the tasks involved with maintaining the airport EMS and the frequency that the tasks are performed. Table 5. Airport Environmental Management System tasks. Task Frequency Develop Environmental Policy Statement Once Review aspects and impacts Triennially Review and modify criteria for determining significance Triennially Determine significant aspects and impacts Triennially Review HPN activities, services, and products Annually Develop new Objectives and Targets Annually Conduct internal audit in preparation for ISO 14001:2004 audit Annually Participate in third party audit for ISO 14001:2004 certification Annually Measure performance against Targets Monthly/Quarterly/Annually Meet with Working Group to discuss airport EMS Quarterly Address Environmental Work Orders Ongoing Implement Environmental Objectives Ongoing Estimated Costs The County Airport has not received outside funding for the development or implementation of the airport EMS. The airport EMS is funded through Airport revenues. The initial contract with the environmental consultant from March 2001, through March 2003, for development and operation of an EMS to meet the ISO 14001 standard was for $485,000. The initial contract was extended at no additional cost to December 2004, and the airport first received ISO 14001 certification in August 2004. The consultant’s contract was extended twice through December 2007, for a total of $350,000 for compliance audit and other work. The County estimates that it spends between $50,000 and $100,000 on the airport EMS annually, including salaries and an $8,000-$10,000 external audit for ISO certification. This is in addition to any capital costs associated with specific initiatives, such as construction of a deicing pad, groundwater well installation, noise monitoring equipment, and recycling costs. In retrospect, the County feels that these costs and the cost of the consultant were well justified considering the benefits they see from the airport EMS. Findings and Key Considerations The County has enhanced the reputation of HPN and facilitated improved environmental performance through its airport EMS. The County has received positive feedback from the community, local officials, regulators, and staff for the airport EMS. Because of the airport EMS, the Airport’s relationship with state and federal regulators and the public has improved significantly and the Airport considers its improved environmental performance, avoidance of regulatory problems, and these improved relationships well worth the cost of implementing the airport EMS. Many initiatives have reduced the environmental impacts at HPN and the Airport plans to continue to implement additional initiatives in the future. The Airport has maintained its ISO 14001:2004 certification every year since it was first certified in 2004. 302 Guidebook of Practices for Improving Environmental Performance at Small Airports

Planning The ISO 14001:2004 standard is somewhat complex, and there are many requirements involved in implementing an airport EMS that meets the ISO 14001:2004 standard. The County decided to hire a consultant to assist with the initial implementation of the airport EMS because County staff were not familiar with airport EMS. Airports implementing an EMS may want to consider involving an environmental consultant experienced in EMS if airport staff is unfamiliar with the ISO 14001:2004 standard, particularly if the airport is considering ISO 14001:2004 certification. Gaining buy-in from upper management and publishing an Environmental Policy Statement signed by the County Executive illustrated to employees and the public that the County was serious about the environment and the success of the airport EMS. Obtaining upper management support is key to achieving success. Support from upper management effectively sends the message to all staff that the airport EMS is an important initiative and the airport is serious about the success of the program. Establishing airport EMS committees with staff from various County Departments and including upper management established lines of communication. Effective communication is key in implementing an airport EMS, as it facilitates flow of information vertically along the chain of command and horizontally across departments, encouraging active participation in the program at all levels, and empowering staff to become involved. Implementation Successful implementation means meeting the County’s goals for the airport EMS, including: • Ongoing knowledge of HPN’s environmental compliance status —The airport EMS program requires regular measurement of HPN’s performance with regard to environmental compliance and the airport EMS objectives and targets. • Continuous identification of and mitigation of risks for non-compliance—Through coordinated annual reviews of HPNs activities, services and products, the County identifies areas of environmental risk, and can take steps to mitigate those risks. • Improving HPN’s public image with the respect to the environment—HPN publishes its objectives, targets, aspects, impacts, monthly noise reports, and semi-annual groundwater monitoring reports on its website, improving the public confidence in HPN environmental program. Because of this enhanced confidence the public is less critical of other HPN projects. • Reducing HPN’s negative environmental impacts—HPN eliminated the second largest source of criteria air pollutants with its electric vehicles. HPN prohibited the use of ethylene glycol-based aircraft deicers and reduced the amount of deicer that reaches surface water. HPN remediated and closed historical spill sites. • Improved communication and coordination within the County Departments and with the tenants and contractors—Staff from eight County Departments, tenants and contractors serve on the environmental committees established under the airport EMS. • ISO 14001:2004 certification—HPN has maintained its ISO 14001:2004 certification since 2004 when it was first certified. Ongoing Maintenance After the initial implementation of the program, HPN strives to keep their staff, tenants, contractor that operates HPN, and other contractors actively involved in the airport EMS. HPN’s continued success Appendix B 303

with their airport EMS is a result of several key actions taken by HPN staff during the planning, implementation, and maintenance of the program: • The initial roll out of the EMS came as a directive from the County Executive through the Environmental Policy Statement. This illustrated to airport staff, tenants, and contractors the importance the airport placed on the success of the EMS and its initiatives. • Continued ISO 14001:2004 certification establishes permanency for the program to the public. • In addition to maintaining regulatory compliance, HPN targets its objectives towards issues identified by staff and community groups concerned about the environment. This maintains the positive relationship with staff and the community. • The County maintains a policy of transparency with regard to its environmental performance and its EMS program. This enhances public opinion of the airport and serves to garner support from the community for airport projects. • The airport uses environmental work orders, lunch time speakers, and awards to maintain staff motivated about implementing EMS initiatives. Additional Resources • ISO 14000 standard www.iso.org/iso/iso_catalogue/management_standards/iso_9000_iso_14000/iso_14000_essentials.htm • Westchester County Airport http://airport.westchestergov.com/ • EPA www.epa.gov/ems/ • ACI-NA Environmental www.aci-na.org/committees/enviro_main and www.aci-na.org/index/issues_enviro_main • Federal Government Guidance www.fedcenter.gov/programs/ems/ • FAA Regional EMS Implementation Guide www.faa.gov/airports/environmental/policy_guidance/media/regional_ems_implementation_guide.pdf • All-Electric Vehicles Bought for Airport. New York Times, January 23, 2009. http://www.nytimes.com/2009/01/25/nyregion/westchester/25airportwe.html?_r=1&fta=y 304 Guidebook of Practices for Improving Environmental Performance at Small Airports

APPENDIX B-3 Establishing a Small Airport Sustainability Program Case Study Problem Statement Airports can enhance environmental performance and meet future demands for clean water and energy by developing, through comprehensive planning, an approach to sustainability which considers environmental, social, and economic elements. Airport sustainability is defined by Airports Council International—North America as “a holistic approach to managing an airport so as to ensure the integrity of the economic viability, operational efficiency, natural resource conservation and social responsibility (EONS) of the airport” (2). A more detailed introduction to sustainability is included in Chapter 9. Sustainability represents an “approach” to planning, rather than an end goal. With the understanding that the health of our environment and communities is valuable, integrating environmental and community considerations into decision making can result in substantial cost savings. These cost savings are often achieved through enhanced efficiency and/or through reduced resource demand. Opportunities for enhanced efficiency and innovative planning arise when decision making seeks to minimize use of financial and environmental resources, and enhance social well-being. Because a sustainability approach is integrated with airport planning, it can be applied to airports of any size, reflecting the fundamental needs and capacities of the individual airport. Airports seek to incorporate sustainability into their planning processes for a number of different reasons. As documented in the Sustainable Aviation Resource Guide (1), these drivers include the following: • Rising and fluctuating energy and water costs • More abundant enabling technologies • Aging infrastructure • Growing stewardship philosophy • Airline industry financial pressures • Green and environmental mandates • Political desires Airports planning for sustainability can take many forms, including the following: • Sustainability master plans • Stand-alone sustainability management plans • Sustainability management systems • Facility design and construction guidelines incorporating sustainability • Integration of sustainability into capital improvement plans Appendix B 305

Summary of Key Issues Developing a sustainability plan is an effective way to incorporate environmental stewardship into all aspects of airport operations, capital improvements programming, and the cultural fabric of airport management and operations. As noted by the Sustainable Aviation Guidance Alliance (1), some benefits to incorporating a sustainability approach to airport planning include: • Reduced life cycle costs of capital assets • Reduced operating costs • Reduced environmental footprint • Optimization of new and better technologies • Reduced costs of asset development • Enhanced bond ratings • Reduced environmental, health, and safety risks • Improved work environment for employees leading to higher productivity • Better customer service and satisfaction • Enhanced relationships with the surrounding community Until recently, large airports have primarily undertaken sustainability planning projects. However, an increasing number of small airports have initiated sustainability programs due to the potential benefits, outlined above, that can be achieved without substantial capital costs. One of the primary obstacles for implementing projects that respond to the sustainability needs of a small airport is the limited potential for economies of scale. As a result, small airports must carefully identify relevant projects and weigh the triple bottom line benefits – social, environmental, and economic – of potential initiatives. Case Narrative—Double Eagle II Airport The City of Albuquerque’s Aviation Department operates two airports: Albuquerque International Sunport (ABQ), which is primarily a commercial service airport and Double Eagle II Airport (AEG or the Airport), which is a general aviation reliever airport, as defined by the Federal Aviation Administration’s National Plan of Integrated Airport Systems (2009-2013). The City of Albuquerque’s Aviation Department sustainability program addresses the activities of ABQ and AEG. Because the Albuquerque Aviation Department operates both airports, it has planning resources that other small airports may not have. However, the sustainability framework set forth in the plan is designed to be applied within smaller business units of the Aviation Department, such as AEG. This case study focuses on the general aviation airport and identifies lessons learned by the City of Albuquerque Aviation Department that are applicable to small airports. AEG is located on 4,361 acres situated 8 miles northwest of the Albuquerque central business district and 13 miles northwest of ABQ. AEG has two runways, Runway 04/22, which is 7,400’ long and 100’ wide and Runway 17/35 which is 6,000’ long and 100’ wide. In 2009, AEG had 128 based aircraft and 80,000 annual aircraft operations. The following case study provides an in-depth look at the development, successes, and challenges of the sustainability management system that the City of Albuquerque Airport Department developed and implemented. 306 Guidebook of Practices for Improving Environmental Performance at Small Airports

Initiative Driver(s) The City of Albuquerque Aviation Department undertook the development of a department-wide plan for addressing sustainability as a result of two motivating factors: • The City of Albuquerque was currently in the process of developing a city-wide mandate addressing sustainability. The Aviation Department wanted to demonstrate leadership by proactively initiating a sustainability program prior to any City-wide mandate. • The Aviation Department felt that incorporating sustainability into its planning and development was the right thing to do. Developing its own sustainability plan enabled the Aviation Department to organize itself and identify opportunities to enhance its sustainability activities independently of the city’s larger initiative. Had the Aviation Department waited for the city’s sustainability mandate to go into effect, AEG perceived it would have had less control over the direction and focus of its sustainability efforts. Implementation Strategy Elements of the City of Albuquerque Airport Department Sustainability Management System The City of Albuquerque Aviation Department’s sustainability management system outlines a number of elements designed to incorporate sustainability into the decisions of each of the Aviation Department’s business units. These business units include: Operations and Maintenance, AEG, Planning and Development, and Finance and Administration (see Figure 7). The elements of the City of Albuquerque Aviation Department sustainability management system are the following: • Develop a sustainability policy • Document existing sustainability practices • Set goals and objectives • Perform a gap analysis • Achieve management commitment to sustainability • Develop tools for financial analysis • Delineate staff roles and responsibilities • Establish performance metrics • Develop a communications program • Train staff on incorporating sustainability into daily activities • Continually evaluate and improve the sustainability program The City of Albuquerque Aviation Department’s sustainability program enables decentralized implementation of sustainability principles by establishing a management structure that clarifies responsibilities, objectives and goals, and distributes accountability throughout the organization (see Figure 7). Although the program establishes an overall goal and vision for the entire aviation system, focused goals and objectives are set by Asset Managers of the Aviation Department’s various business units. As a result, environmental stewardship activities can be catered to match departmental needs and capabilities. This approach makes sustainability planning relevant and accessible for AEG. Appendix B 307

Figure 7. Proposed project organization for Double Eagle II Airport.

Sustainability Planning at Double Eagle II Airport The sustainability management system identifies an approach for AEG to incorporate sustainability into its operations, planning, development, and construction. Ultimately, the AEG Manager who oversees all operational activities at AEG is responsible for implementing the sustainability program. Specifically, the plan identifies the following responsibilities for the AEG Manager, which are intended to guide decision-making at AEG: • Establish annual environmental goals for AEG • Manage energy and fuel expenditures at AEG • Implement sustainable operational practices • Monitor and report on the results from sustainability strategies • Incorporate sustainability objectives into daily decision-making • Apply triple-bottom-line and life-cycle cost analyses in all capital requests To support the development of initiatives that meet the airport’s sustainability goals, AEG also conducts pilot projects. These projects enable the airport to gauge the feasibility and magnitude of improvements the initiative would have. Initiative Outcome and Current Status Environmental Goals for AEG As part of implementing the Sustainability Management System, AEG identified sensitive environmental areas as well as aspects of the airport’s operations and development that have environmental impacts: • Energy use • Waste management and recycling • Potential lead issues (that could result from pending EPA regulation) • Stormwater With an understanding of the critical current and future environmental issues associated with AEG’s operations, the Department of Aviation developed sustainability practices to minimize AEG’s impact in those environmental areas. AEG Sustainability Initiatives Resulting from the Sustainability Management System Although AEG’s sustainability activities are part of a larger effort that includes all of the Aviation Department’s business units, AEG typically does not implement the same initiatives as ABQ because of differing environmental and community contexts, as well as differing airport functions. For example, ABQ focused on expanding multimodal transportation opportunities for passengers and airport employees. However, due to its isolation a similar program is not as applicable for AEG. Instead, initiatives are focused on areas of greatest concern for AEG specifically, which includes energy use, waste management, and stormwater. The improvements that AEG has initiated to-date include: 1. Conversion of fuel used for AEG’s vehicle fleet to biodiesel fuel (B20 and E85). This fuel conversion was initiated to minimize AEG’s dependence on fossil fuels and to reduce air emissions. Appendix B 309

However, because of increased maintenance costs, AEG is looking to revert back to using regular unleaded fuel for the fleet vehicles. 2. Conversion of Runway Lights to Low Emitting Diode Lights (LED). A Life Cycle Cost Analysis (LCCA) for this initiative demonstrated the conversion of runway lights to LED would save AEG close to $73 per fixture each year, resulting in a 2.2-year return on investment. In addition, environmental benefits resulting from this project included savings of 15.9 metric tons of carbon dioxide per year, equivalent to the yearly emissions of 2.9 passenger vehicles or the emissions from the yearly electricity use of 1.5 homes. 3. Leadership in Energy Efficiency and DesignTM (LEED) Certification of Airport Maintenance Facility. The City is seeking to achieve the Gold certification level. Examples of strategies AEG used to meet LEED standards are listed on AEG’s website. The final upfront costs for seeking LEED certification were 10 to 20 percent higher than a conventional project approach. A critical component of this project addressed stormwater retention. The project incorporated the design of a stormwater capture system that will reduce water pollution by minimizing the contaminants leaving the site and removing pollutants from stormwater runoff. All stormwater leaving the AEG site will flow through four major retention ponds that allow the water to be naturally treated and stored to avoid unhealthy runoff to streams in large storm events. 4. Energy Meter Mapping. One significant effort conducted at AEG was to identify and map all of the electrical meters at AEG using a geographic information system. As a result of the energy meters inventory, the Airport discovered it was being charged for more electricity than it was actually using. Correcting electricity charges resulted in significant cost savings for AEG. 5. Establishing a recycling program. AEG is currently in the process of establishing a recycling program despite a low volume of waste resulting from airport operations. AEG is also evaluating the feasibility of sourcing its energy from renewable sources. AEG is considering leasing land to an outside company to construct a 10 mega watt solar array. The owner of the system would supply 100 percent of AEG’s electricity and would sell the remaining back to the grid. This arrangement is enhanced by the Airport’s small size: supplying electricity for the Airport would represent only a small fraction of the total electricity the system could produce, thereby allowing the company managing the system to profit from the remaining electricity produced. This initiative is pending an agreement with the local utility provider that would allow the system’s owner to resell excess electricity produced to the local grid, thus making the installation financially viable. Perceived Benefits The sustainability initiatives that AEG has undertaken as a result of its sustainability management plan resulted in substantial reductions in energy consumption and financial savings associated with reduced resource consumption. In addition, AEG anticipates that its new LEED certified maintenance facility will result in a number of environmental and social benefits, such as reduced use of electricity, potable water, and raw materials, reduced waste generation, and enhanced employee health and productivity. Finally, initiating sustainability planning in advance of any potential city mandates demonstrated AEG’s leadership and commitment to sustainability, and offered AEG increased flexibility in the direction and focus of its sustainability efforts. Obstacles Encountered: Challenges of Implementing the Sustainability Management System at AEG Although still in the early phases of implementation, AEG has identified a number of challenges encountered in applying the sustainability program, including the following: 310 Guidebook of Practices for Improving Environmental Performance at Small Airports

• Due to AEG’s location and the nature of its operations, it has fewer opportunities to implement sustainability initiatives, especially when compared to its larger counterpart, the Albuquerque International Sunport. AEG’s small number of operations and isolation from local population centers limit the environmental and social issues associated with airport operations. However, AEG benefits from being part of a larger airport system and the associated economies of scale to justify airport improvements. • AEG’s small size also impedes the ability of sustainability measures to result in the necessary financial returns to justify the investment. For example, because AEG has limited passenger traffic and few administrative staff, increasing its recycling rates would only result in a small reduction of landfill waste. As a result, the effort and financial costs associated with increasing recycling rates do not result in the financial returns that larger recycling programs at other airports and organizations may provide. However, AEG opted to implement a recycling program despite the limited financial return because the program has social and environmental benefits, and offers a visible example of its efforts to plan for sustainability. • The cost to maintain an environmental initiative can prohibit the continued implementation of the sustainability measure. The environmental benefits resulting from use of biofuel, for example, were not great enough to offset the increased cost. Although sustainability initiatives often result in social and environmental benefits without monetary value, the financial constraints of small airports will often dictate the choice of the project to be implemented. As a result, AEG often approaches sustainability projects by conducting a pilot phase to obtain information on the financial viability and other intangible benefits of the project. • Establishing a culture of sustainability is a critical component to implementing sustainability. A sustainability management system establishes a framework to approach sustainability, but does not address the organizational mindset changes necessary to incorporate sustainability into decision making. The Aviation Department sought to encourage culture shifts through friendly competition amongst airport staff, highlighting of public interest in sustainability issues, and stressing that implementing sustainability initiatives is the right thing to do. Critical Success Factors Analytical Tools for Applying Sustainability Two primary analytical components of the sustainability program for which each asset manager, including the AEG Airport Manager, is responsible include: • Triple Bottom Line Analysis—One of the most important aspects of a sustainability program is a shift in the decision-making process to consider environmental and social factors in addition to economic concerns. It is important to understand that one factor need not come at the expense of another. In some cases, evaluating a project based on environmental and social concerns will spur innovation that ultimately reduces overall costs over the life of the project. The goal of a triple bottom line approach to decision-making is to optimize economic, environmental, and social capital. AEG conducted a triple bottom line analysis to decide whether to replace cleaning agents with ionized water. Ionized water is environmentally beneficial because it eliminates chemical waste that is found in traditional cleaning products. Additionally, ionized water is socially beneficial because the janitorial staff is no longer exposed to chemicals, which enhances working conditions. Lastly, the triple bottom line analysis determined that although transitioning to a new cleaning mechanism would result in increased costs, in the long run, the change would result in financial savings due to the reduced amount of cleaning supplies needed at AEG. • LCCA – LCCA is the calculation of the total cost of ownership of an asset as the sum of all costs incurred in the initial planning and development stage, the operational stage, and the end-of-life stage. LCCAs are used to determine the total cost of implementing an environmental initiative, thereby Appendix B 311

enabling a cost comparison of different alternatives. An LCCA conducted for the conversion of taxiway lighting to LEDs demonstrated the financial viability of the project (a 2.2 year return on investment). AEG used these tools to provide quantitative measures of sustainability, and applied them to projects of all types and sizes. Changes in Environmental Mindset Shifts in environmental mindset at AEG and at ABQ have been essential to the successful implementation of sustainability initiatives. Although the sustainability plan provided a framework for action, changes in the organizational culture of the Aviation Department lead to the innovation and enthusiasm necessary for incorporating sustainability into airport planning. Funding Mechanisms AEG utilized a number of different funding sources to implement the initiatives resulting from the sustainability program recommendations. These funding sources included: • Reduced purchase costs by utilizing economies of scale resulting from joint purchases with ABQ • American Recovery and Reinvestment Act of 2009 to convert runway lighting to LEDs • Airport capital funds In addition, leasing of land is a potential funding source for AEG, and it plans to use this for the installation of a solar energy system. Estimated Level of Effort The sustainability management plan was completed by an external consultant and intended for the entire aviation department of the City of Albuquerque. The plan identified specific roles and responsibilities that AEG could undertake with its limited staff resources. Nonetheless, AEG received support from the entire Aviation Department team, as identified on Figure 7. Estimated Costs The cost of the planning effort was not shared with the research team. In addition, the costs of the project may not be relevant to other small airports because it covered the operations and activities of the entire Aviation Department of the City of Albuquerque. Some costs associated with the individual sustainability initiatives that resulted from the Sustainability Management Plan are discussed above. Findings and Key Considerations Through development of a sustainability management plan, AEG identified airport-specific sustainability goals, received tools to incorporate sustainability into its decision making, and identified a number of projects to enhance environmental, social, and economic aspects of airport operations and development. Planning The planning component of the project consisted of the development of the sustainability management plan. Although the plan itself was intended to capture the operations of the entire Aviation 312 Guidebook of Practices for Improving Environmental Performance at Small Airports

Department, the decentralized approach to managing sustainability enabled AEG to pursue a program that suited its operations, environmental, and social conditions, as well as AEG’s financial considerations. Those elements of the plan that were most instrumental to the initiation of sustainability initiatives at AEG include the following: • Developing a sustainability policy • Setting goals and objectives • Achieving management commitment to sustainability • Developing tools for financial analysis • Continually evaluating and improving the sustainability program An important aspect of developing the sustainability plan at AEG was to concurrently build an environmental mindset within the airport. Shifts in mindset were achieved through competitions within the Aviation Department and through regular interactions among those leading the sustainability efforts of each business line of the Aviation Department (see Figure 7). Implementation An integral component to successfully implementing the sustainability management plan at AEG was identification of the critical current and future environmental issues associated with AEG’s operations and development of goals in each of these areas. AEG then sought to meet those goals and minimize its impact in those environmental areas. Because AEG sought to develop an understanding of its baseline conditions, it was able to cater the sustainability strategies to the specific environmental and community context of the Airport, as well as to its differing airport functions. Specifically, one of the primary challenges AEG faces is its smaller environmental footprint and a difficulty to achieve sufficient economies of scale to justify investments. To overcome these obstacles, AEG prioritized projects that fit within the financial constraints of the airport and that offer environmental, social, and economic benefits of value. Ongoing Maintenance AEG strives to keep its staff, tenants, and contractors actively engaged in sustainability planning. The sustainability management plan provides a framework for continued incorporation of sustainability into AEG’s decision making. Analyses such as the LCCA and the triple bottom line provide tools for AEG to continue to effectively incorporate a long-term sustainable view into airport planning and development. Additional Resources • Double Eagle II Airport www.cabq.gov/airport/double-eagle-ii-airport • Sustainability at Albuquerque International Airport www.cabq.gov/airport/sustainability-at-sunport • Double Eagle II Airport - LEED www.cabq.gov/airport/double-eagle-ii-airport-leadership-in-energy-and-environmental-design-leed • TRB—ACRP Transportation Research Circular E-C138: Critical Issues in Aviation and the Environment, September 2009 www.aci-na.org/static/entransit/trb_aviation_environment_sept09.pdf • ACRP Synthesis 10: Airport Sustainability Practices http://onlinepubs.trb.org/onlinepubs/acrp/acrp_syn_010.pdf Appendix B 313

• ACRP Research Results Digest 2: Model for Improving Energy Use in U.S. Airport Facilities http://onlinepubs.trb.org/onlinepubs/acrp/acrp_rrd_002.pdf • ACRP Project 02-13: Development of a Guidebook of Practices for Improving Environmental Performance at Small Airports (in development) http://144.171.11.40/cmsfeed/TRBNetProjectDisplay.asp?ProjectID=2576 • ACRP Project 20: Strategic Planning in the Airport Industry http://onlinepubs.trb.org/onlinepubs/acrp/acrp_rpt_020.pdf • Sustainable Aviation Guidance Alliance (SAGA) www.airportsustainability.org/ • Sustainable Aviation Resource Guide: Planning, Maintaining and Implementing a Sustainability Program at Airports www.airportsustainability.org/sites/default/files/SAGA%20Final2.pdf • Database of Sustainable Initiatives www.airportsustainability.org/database • Airports Council International-North America Joint Environmental and Technical Committee, Airport Sustainability Working Group www.sustainableaviation.org/ • DRAFT Sustainable Initiatives Index, ACI Sustainability Working Group, March 14, 2006 www.sustainableaviation.org/pdfs/ACI%20Index%20031506.pdf • Airport Sustainability – A Holistic Approach to Effective Airport Management www.sustainableaviation.org/pdfs/ACC%20-%20Sustainability%20White%20Paper.pdf • Sustainable Initiatives – Index of Weblinks www.sustainableaviation.org/Links.htm • www.sustainableaviation.org/pdfs/ACI%20Weblinks%20031406.pdf • Going Greener: Minimizing Airport Environmental Impacts. Airports Council International- North America, Washington, D.C., 2009 www.aci-na.org/static/entransit/enviro_brochure.pdf AIRPORT PROGRAMS Example Airports in the U.S. • Fort Lauderdale/Hollywood International Airport – Environmental Initiatives, Green Airport Initiative, and Environmental References www.broward.org/airport/community_environment.htm • Naples Municipal Airport —– Sustainability, Conservation and Social Responsibility Plan www.flynaples.com/images/docs/general/final%20sustainability%20plan%205-14-09.pdf • St. Augustine-St. Johns County Airport - Sustainability Management Plan www.staugustineairport.com/index.aspx • MASSPORT - Sustainability Plan www.mass.gov/envir/Sustainable/initiatives/PDF/mpa_finalplan_10_29_04.pdf • MASSPORT – Logan International Airport LEED Registered Project: Terminal B Addition www.usgbc.org/LEED/Project/project_detail_step_1.asp?PROJECT_ID=83 http://egov.cityofchicago.org/webportal/COCWebPortal/COC_EDITORIAL/December2003Sustaina bleDesignManual.pdf • Port of Oakland Sustainability Program, 2003 www.portofoakland.com/pdf/sustaina.pdf • • Port of Oakland—Oakland International Airport: Green Airport Initiatives www.oaklandairport.com/green_airport.shtml City of Chicago - O’Hare Modernization Program Sustainable Design Manual 314 Guidebook of Practices for Improving Environmental Performance at Small Airports

• Oregon Department of Transportation, Sustainability Plan, Volume 1: Setting the Context, September 2008 www.aci-na.org/static/entransit/oregon_Sustain_Plan_Volume1.pdf • Portland International Airport- Recycling program http://www.sustain.pdx.edu/hm_feature_pdx_compost.php • Sacramento County Airport System – Green Airport Initiative http://www.epa.gov/ttn/airinnovations/2005conference/Wed4/5-GregRowe.pdf • Seattle Tacoma International Airport – Sustainability Initiatives www.portseattle.org/ • Seattle Terminal Radar Approach Control facility at Seattle-Tacoma International Airport - Gold LEED certification www.djc.com/news/en/11159540.html • Seattle Tacoma International Airport – Recycling Program www.ecy.wa.gov/pubs/0107030.pdf • Fresno-Yosemite International Airport – Solar Installation www.fresno.gov/DiscoverFresno/Airports/default.htm • South Bend Regional Airport – List of current and planned sustainability initiatives www.sbnair.com/ • San Francisco International Airport – “Green SFO” Environmental webpage & Reports: www.flysfo.com/web/page/about/green/index.html • San Diego International Airport Environmental Initiatives & Sustainability Policy: www.san.org/sdcraa/airport_initiatives/environmental/ • San Diego International Airport - Recycling Program: www.san.org/sdcraa/airport_initiatives/environmental/recycling.aspx Example International Airports • Athens International Airport, Greece www.hochtief-airport.com/airport_en/23.jhtml • Amsterdam International Airport, Netherlands www.greenroofs.com/chic_sustainability.htm • Auckland International Airport, New Zealand www.auckland-airport.co.nz/Annual2005/downloads/enviro_sustainability_ar05.pdf • Bristol International Airport, United Kingdom (UK) www.bristolairport.co.uk/upload/sustainability_appraisal.pdf • Dusseldorf International Airport, Germany www.hochtief-airport.com/airport_en/24.jhtml • East Midlands Airport, UK Environmental Initiatives: www.eastmidlandsairport.com/emaweb.nsf/Content/Environment • East Midlands Airport, UK Community Initiatives: www.eastmidlandsairport.com/emaweb.nsf/Content/Community • Hamburg Airport, Germany www.hochtief-airport.com/airport_en/25.jhtml www.manairport.co.uk/web.nsf/Content/SustainabilityEnvironment • Munich Airport, Germany www.munich-airport.de/media/download/general/publikationen/en/nachhalt-2008_en.pdf • • Narita International Airport, Japan www.naa.jp/en/environment/index.html Manchester Airport, UK Appendix B 315

• Sydney Airport, Australia www.hochtief-airport.com/airport_en/26.jhtml • Tirana International Airport, Albania www.hochtief-airport.com/airport_en/27.jhtml • Vancouver International Airport www.yvr.ca/authority/airmail/archive_details.asp?id=161 Other Aviation and Non-Aviation Sustainability Resources • Waste Management: NRDC Report: Trash Landings: How Airlines and Airports can clean up their Recycling Programs www.nrdc.org/cities/recycling/airline/contents.asp • Climate Change / Greenhouse gases: ACI Greenhouse Gas Emissions Guide: www.aci.aero/aci/aci/file/ACI_Priorities/Environment/2009/ACI%20Guidance%20Manual%20- %20Airport%20Greenhouse%20Gas%20Emissions%20Management.pdf • Pew Center on Global Climate Change – Adaptation Planning: What U.S. States and Localities are doing www.pewclimate.org/docUploads/State-Adapation-Planning-02-11-08_0.pdf • Building Commissioning: Berkley University research on cost-benefits of building commissions (not airport specific): Evan Mills. 2009. "Building Commissioning: A Golden Opportunity for Reducing Energy Costs and Greenhouse-gas Emissions" http://cx.lbl.gov/2009-assessment.html • U.S. Green Building Council Leadership in Energy Efficiency and Design www.usgbc.org/DisplayPage.aspx?CategoryID=19 316 Guidebook of Practices for Improving Environmental Performance at Small Airports

APPENDIX B-4 Developing an Airport-wide Storm Water Pollution Prevention Program Problem Statement While small airports have less air traffic than large airports, the structural and facility requirements of aviation result in vast impervious areas needed for runways, taxiways, and ramps. Not only does this result in large volumes of storm water runoff, but these small airports and their tenants also conduct industrial activities (e.g., maintenance, fueling, deicing, and construction of new facilities) that can adversely affect storm water quality. Summary of Key Issues Discharges of sediments or other pollutants in storm water as a result of airport construction or industrial activities can lead to odor, foam, oily sheens, and other impairments to surface water quality, and airport infrastructure improvements that add impervious area may result in increased risk for flooding downstream if not mitigated. Water quality regulations are often developed on a state level and many state regulations mirror federal mandates contained within the Multi-sector General Permit for Industrial Activities and the General Permit for Construction Activities. Additionally, the EPA recently issued a Construction and Development Effluent Limitation Guideline (ELG) and a Proposed Airport Deicing ELG. Airports of all sizes have to deal with these regulatory programs (either federal or state equivalents) and many have taken steps to mitigate their potential impacts on storm water runoff quality. In addition to the water quality compliance concerns related to airport activities, increases in the risk of downstream flooding and discharge of sediment and pollutants can lead to community complaints and media reports on environmental problems at the airport. These public relations issues can make it difficult to get local approval for airport development projects, increase regulatory involvement at the airport, and lead to political pressure to incorporate environmental stewardship practices. Alternatively, an airport- wide storm water pollution prevention program that includes a comprehensive training program; pollution prevention considerations in planning, maintenance, operations, development and construction; proactive consideration of environmental regulations; coordination with regulators; and airport involvement in community and watershed groups can foster relationships with the community and regulators, facilitate approval of airport projects, and generate positive media for the airport. This case study will examine storm water best management practices (BMPs) implemented by small airports to eliminate, control, or reduce pollutants in storm water runoff. It will examine the methods used to overcome difficulties commonly faced by small airports including implementing initiatives with limited budget, facilitating tenant buy-in and conformance with BMPs, and maintaining BMPs with limited staff. Case Narrative—Naples International Airport Located on the Bay of Naples in Florida, the Naples Municipal Airport (APF) is operated by the City of Naples Airport Authority (NAA) and is considered a non-hub airport by the 2009 FAA National Plan of Integrated Airport Systems with operations and characteristics listed in Table 6. Appendix B 317

APF Annual Operations Percent of Total Operations Air Carrier 0 0% Air Taxi 6,793 6% General Aviation 72,134 65% Itinerant Military 102 0% Civil 31,513 28%Local Military 52 0% Total Operations 110,594 Initiative Driver Initiative 1—Water Quality Development in the Naples Bay Watershed led to degradation of the water quality in the Bay. The South Florida Water Management District plans evaluate the use of a database to track water quality data, incorporate existing and future storm water quality data into GIS, and implement a water quality model. The water quality model will be used to quantify the effect of water quality on specific sensitive receptors. The results will be used to identify high water quality areas for conservation purposes, and recommend actions to solve problems and meet watershed goals. Initiative 2—Storm water Quantity The large network of canals and development of the Naples Bay area led to excess freshwater flows that are affecting the salinity of the bay. South Florida Water Management District identified several action steps to help restore the natural timing and quantity of freshwater flow into Naples Bay. Action steps include developing a salinity model, and considering the use of aquifer storage and recovery wells, canal rerouting and storm water recycling to reduce discharge, increase recharge, and improve discharge flow timing. South Florida Water Management District is also considering a requirement for onsite retention of storm water. Initiative 3—Watershed Master Planning and Implementation South Florida Water Management District plans to assist local governments with updating storm water master plans so that they include appropriate storm water retrofits, and recycling and recharge of storm water initiatives; and facilitate pursuit of federal funding for water quality improvement projects. Initiative 4—Habitat Assessment, Protection and Restoration There have been losses to historic aquatic life and reduction in the beneficial use of the Naples Bay Watershed. South Florida Water Management District plans to develop a map of available habitat areas within the watershed; develop habitat protection strategies; facilitate habitat restoration, stabilization, and enhancement; and control exotic vegetation to protect and enhance existing habitat. SOURCE: FAA National Plan of Integrated Airport Systems, 2009-2013 (18). Table 6. Naples Municipal Airport National Plan of Integrated Airport Systems Data. The Florida Department of Environmental Protection is developing Total Maximum Daily Loads (TMDLs) for impaired water bodies in Florida. The South Florida Water Management District is assisting the Florida Department of Environmental Protection with development of TMDLs in Southern Florida. South Florida Water Management District developed a Surface Water Improvement and Management Plan for the Naples Bay watershed in 2007 to address specific water quality and water quantity concerns in the watershed in advance of the TMDLs (18). The Storm Water Improvement and Management Plan includes strategies and action steps to protect the ecological, aesthetic, recreational, and economic value of Naples Bay through the implementation of four initiatives. 318 Guidebook of Practices for Improving Environmental Performance at Small Airports

Runoff from APF discharges into the Naples Bay watershed. It is important for the airport improvements and operations to follow the strategies and action steps identified in the Naples Bay Storm Water Improvement and Management Plan where possible. Tenants at APF were planning to add additional infrastructure at the airport on their leaseholds. NAA realized that to participate in Storm Water Improvement and Management Plan Initiative 2, each tenant that was adding infrastructure would need to implement measures to add storm water retention to handle storm water from the additional impervious surfaces created as a result of the new facilities. Implementation Strategy Instead of each tenant creating separate storm water retention facilities, APF decided to consolidate the storm water management efforts and implement airport-wide storm water retention facilities to accommodate the final build-out of the airport. Consolidating storm water management efforts provided the Airport with several benefits: • Decisions about what measures would be used to manage storm water • Implementation of a cohesive program instead of piecemeal measures on each leasehold • Integration of new storm water management needs into the existing system • Control over which sites were used for storm water retention Initiative Outcome and Current Status In 2001 and 2002 APF conducted several projects to increase and improve the storm water discharges: • Construction of four water retention lakes and interconnecting culvert systems • Redesign of five existing lake outfalls • Redesign of three drainage ditch outfalls The lakes provided storm water retention and sedimentation, and the interconnecting culvert systems and drainage ditch outfall redesigns improved storm water detention and filtration. These projects improved the storm water flow from the airport. The airport hired an environmental consultant to survey potential development areas for wetlands, historic resources, exotic/invasive species, and threatened and endangered species prior to the design of the new facilities to identify any mitigation that would be needed to prepare the sites for development. The consultant also conducts annual reviews to identify exotic/invasive species for removal and to ensure that wetlands and uplands areas are maintained. Because of concerns about attracting birds to the new retention lakes, special design elements like steep banks were included in the lakes to prevent specific wading birds from entering the lakes. The water retention areas are also designed in a cascade system to facilitate removal of sediment. Since 2001, the Airport has installed more new infrastructure to improve drainage on the airfield: • Drainage culvert under Runway 23 to improve storm water drainage on the airfield • Additional retention ponds adjacent to Runway 23 approach to control runoff and sediment • System of drainage ditches and culverts to improve drainage and water detention along Taxilane E After coordinating on airport-wide storm water management efforts, the Airport decided to coordinate management of other storm water quality initiatives. The airport constructed a consolidated rental car wash and fueling station. Prior to the consolidated facility, two of the rental car tenants had car washes, and waste water from the car washes was discharged to a leach field. The consolidated facility recycles used wash water in the car wash. Appendix B 319

During the reconstruction of the ramp in front of the general aviation terminal, the airport added three oil water separators to the ramp to facilitate capture of oil and fuel spills on the ramp. Fountains were installed in airport ponds to improve oxygen levels in the ponds reducing odors, and increasing the aesthetic value of the ponds. The airport uses water from the airport ponds for irrigation, saving potable water, and reducing runoff from the airport. The airport operations staff actually received calls from the community interested in installing similar fountains. By coordinating storm water quality initiatives, the airport and tenants: • Encourage tenant involvement/participation • Facilitate compliance with current and expected future environmental regulations • Participate in the Naples Bay Storm Water Improvement and Management Plan by recycling storm water, improving infiltration, filtering runoff and retaining storm water • Save money from consolidated operations • Reduce storm water runoff to Naples Bay • Control sediment and other pollutants in airport storm water runoff In addition to infrastructure improvements, APF implemented several procedural and policy measures to decrease the risk of storm water pollution from spills and leaks, reduce erosion and sedimentation, and improve the quality of storm water leaving the airport. NAA has proprietary fueling rights, and the Airport does not have a fixed based operator. NAA allows tenants to conduct self-fueling, but helps to ensure that they provide the airport with satisfactory storm water pollution prevention plans (SWPPPs) and spill prevention control and countermeasure (SPCC) plans for their operations. The tenant lease agreements contain a clause that addresses storm water management, and the airport conducts annual training with the tenants. The airport conducts regular clearing of vegetation from airport ditches to facilitate flow of runoff, remove exotic/invasive species, and reduce wildlife attractants. Perceived Benefits Airport staff attends weekly meetings to review regulatory news and attends the Florida Airports Council conferences to learn about upcoming regulations. When the Airport staff learned about proposed requirements to include secondary containment for fuel trucks, they included containment measures in the construction of their loading/unloading area. When constructing the ramp containment fuel loading/unloading area, they oversized the load/unload secondary containment area so that they could park their fuel trucks at that location when it was not in use. The area serves as secondary containment for airport fuel trucks. This proactive approach to incorporating compliance with anticipated future regulations in current infrastructure improvements saved the airport what may have been an expensive retrofit, or construction of a separate secondary containment parking facility for its fuel trucks. The airport also coated the secondary containment structures in the fuel farm with poly-urea to prevent leakage through cracks in the concrete should a spill occur in the secondary containment area. Area businesses heard about the coated secondary containment and visited the airport to find out more about this pollution prevention measure. By implementing a cohesive storm water program the Airport experienced numerous benefits: • Collective airport negotiation on storm water retention projects with FAA, EPA, Florida Department of Environmental Protection, and the Fish and Wildlife Service regarding conflicting requirements for wildlife and wildlife habitat at the airport, instead of separate negotiation by each tenant for storm water retention associated with each new development project. • Upgrade of existing storm water retention areas to reduce wildlife attractants 320 Guidebook of Practices for Improving Environmental Performance at Small Airports

• Cost savings from coordinated storm water retention efforts, which allowed the airport to make additional capital improvements to sidewalks and roadways • Pond excavation material used to construct a berm that blocked view of and sound from the airfield from the road from that improves community relations • Completion of a full revision of the Airport Environmental Resource Permit per Florida airport development requirements • Achievement of full compliance with FAA required safety areas • Increase in storm water capacity and improved flow from the airport reducing flooding potential • Improved public relations from supporting the Naples Bay Storm Water Improvement and Management program • Received 2003 Airports Council International – North America Environmental Achievement Award • Avoidance of costly retrofits or construction of separate facilities by proactive consideration of potential future regulatory requirements The airport director recognizes sustainability as an important initiative, and in 2009, NAA published a Sustainability, Conservation and Social Responsibility Plan. The plan identifies the many ways that APF is an environmental steward. The plan summarizes environmental projects, and provides an opportunity to brainstorm on new environmental projects. It also seeks input from staff and the community on new ideas. Unlike many other airports, AFP is not regularly the subject of community complaints about storm water pollution, and is not a highlighted target for improvement in the Naples Bay Storm Water Improvement and Management Plan or a key issue in the development of the TMDLs. This absence of concern over storm water discharges from APF is a tribute to the success of the Airport’s storm water pollution prevention program. Obstacles Encountered Although the airport coordinated storm water retention efforts and consolidated tenant fueling and washing activities, they made a conscious decision to not consolidate National Pollutant Discharge Elimination System (NPDES) permit coverage. Initially the tenants were all included in the airport’s permit coverage, and the airport was responsible for ensuring tenants complied with the airport NPDES permit requirements. The airport determined that their permit should not include tenant industrial activities that the airport does not control. The airport’s NPDES permit now covers airport industrial activities, including the airport run fueling station and wash stations, and their general aviation ramp. Each tenant with industrial activities is required to apply for separate coverage under the Florida NPDES permit. Forcing tenants to obtain permits for their own activities ensures tenants are held accountable for their own storm water pollution prevention, without requiring the airport to incorporate additional training or inspections for tenants in its pollution prevention program. NAA also experienced some difficulties in the redesign of some of its storm water retention ditches that were heavily vegetated. The vegetation was obstructing flow, and may have been attracting wildlife. The airport was concerned that some of the areas had become wetlands, or potential habitat for wildlife, including endangered or threatened species. The airport hired a consultant to conduct a wetland inventory and determine if the areas would be considered protected wildlife habitat for any threatened or endangered species. Once the airport had assessed the status of the ditches, they then had to handle conflicting federal regulations: FAA regarding wildlife attractants at airport, and EPA regarding the protection of wetlands and threatened and endangered species habitat. Initially the airport was unable to reach an agreement with one agency that would be acceptable to the other agency. To resolve conflicts between these agencies, the airport director held a meeting with all stakeholder agencies to reach a resolution on how to handle the ditches. In the end the airport and agencies agreed on a plan to clear the ditches in areas near runways and create wildlife habitat and wetlands in areas away from the airport runways. Appendix B 321

Critical Success Factors Coordinating negotiation with FAA, EPA, Florida Department of Environmental Protection, and the Fish and Wildlife Service to resolve conflicting regulations regarding vegetation in the airport ditches allowed the airport to construct water retention and filtration lakes and ditches to improve drainage and storm water quality, remove exotic species to reduce wildlife attractants in ditches, and become compliant with FAA safety regulations. By constructing the airport rental car wash and fueling facility, the airport generates revenue from car wash fees and fuel sales. The tenants are relieved of the burden of operating and maintaining car wash and fueling facilities. Water is conserved through recycling of the wash water, and waste water is no longer discharged to airport leach fields. Monitoring of anticipated future regulations allows the airport to be proactive in incorporating future requirements into their designs to avoid costly retrofits, or construction of additional facilities. Estimated Level of Effort The airport does not have dedicated environmental staff. Airport environmental projects, including development of the Sustainability, Conservation and Social Responsibility Plan are coordinated by the Airport Director, Director of Development, and Director of Operations as part of their responsibilities. Environmental assessments, including wetlands inventories, threatened and endangered species surveys, and exotic/invasive species surveys are conducted by environmental consultants. Estimated Costs APF funds smaller storm water projects from airport operating revenue. Larger projects have been funded through FAA grants and other outside funding sources. The airport spent an estimated $80,000 of airport operating revenue on the ditch clearing initiative. The new storm water retention ponds cost between 8 million dollars and 10 million dollars and were funded by FAA, Florida Department of Transportation, City of Naples and Collier County. Other initiatives generate revenue or save the airport money. The airport generates revenue from the sale of fuel and the car wash use fees. The pond water is used for irrigation, which allows the airport to avoid spending money on potable water for irrigation. By incorporating the secondary containment requirements for mobile refuelers into the design of the load/unload rack, the airport avoided the cost of constructing separate secondary containment measures. Case Narrative—Columbus Regional Airport Authority The Columbus Regional Airport Authority (CRAA) operates three airports in central Ohio, Port Columbus International Airport (CMH), Bolton Field Airport (TZR) and Rickenbacker International Airport (LCK). CMH is a medium size hub by the 2009 FAA NPIAS, LCK has primarily military and cargo operations, and TZR is primarily general aviation. LCK and TZR benefit from the resources available through the airport authority including a dedicated energy and environment manager. LCK and TZR present different storm water pollution prevention challenges from CMH due to the general aviation operations at TZR, the sensitive watersheds where the airports are located, environmental contamination from historical military use at LCK, and the cargo and intermodal operations at LCK. This case study focuses on LCK and TZR. 322 Guidebook of Practices for Improving Environmental Performance at Small Airports

Initiative Driver Originally developed in 1942 as the Lockbourne Air Base, LCK was used as a testing and training facility for the US military during World War II, the Korean War, and the Vietnam War. Since the closure of the Base in 1980, ownership of the airport and associated Base property has been transferred to CRAA, and the airport is used jointly for civil and military operations. Recently, CRAA partnered with a developer to determine an approach for redeveloping portions of the former Base property as a logistics center. CRAA realized that there were environmental liabilities in some areas on the former Base as a result of military operations. The Federal Government investigated and cleaned 327 sites at LCK, including investigation of sediments in the ditch system at the Airport; and CRAA knew that the developer would want to conduct all appropriate inquiry into the cleanup and current status of these sites prior to purchasing former Base land for Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA) protection. As land owner, CRAA needed to facilitate cleanup of any remaining contaminated sites, and provide documentation on prior cleanup activities to the developer prior to property reuse. Because the land had been operated by several branches of the military and used for several purposes, identifying the potential environmental risks, status of all military cleanup activities, and determining an appropriate method for remediating sites without affecting the area’s sensitive natural environmental resources, including wetlands and a watershed with a total maximum daily load (TMDL) program required significant coordination. Implementation Strategy CRAA divided the property into campuses, and identified the environmental features on each campus. Environmental features included anything that might affect the site’s development, including natural features like wetlands and threatened and endangered species; and manmade environmental liabilities like unexploded ordnance, and contamination from former military fueling operations. CRAA developed a database and map of environmental sites at LCK. The database included a description of each site, the party responsible for the cleanup, if necessary, and the current status of the site. This information was very helpful when the developer’s consultant came to CRAA with questions from their all appropriate inquiry process about the status of sites. Air Force investigation of the ditch system at LCK determined that although contaminated sediments were present in the ditches, concentrations were low enough that remedial action was not required to clean up the ditches. Special procedures were implemented to avoid re-entrainment of ditch sediment during construction. CRAA also developed guidance for contractors on identifying environmental contamination during construction, and the necessary steps for handling contaminated soils, sediment, storm water, and groundwater should construction activities uncover previously unidentified environmental issues. The guidance was designed to prevent personnel exposure to unknown contamination, and to prevent spread of polluted soils or groundwater to un-contaminated soils, groundwater or surface waters. CRAA also conducted a natural resources inventory to identify any protected natural resources that needed to be considered during development of the land. Wetlands were present in some of the areas identified for development, and CRAA identified a site near LCK that contained wetlands that the State of Ohio was interested in restoring. CRAA worked with the State of Ohio to develop the Mackey Ford wetland mitigation site, which includes 20 acres of wetlands. The site, which includes wetlands plants transplanted from LCK, was constructed and will be maintained by CRAA for the first five years and is ultimately owned and managed by the State of Ohio. This project was a win for the airport in that it allowed development of land at LCK and removed wetlands from within FAA safety area; and a win for the State of Ohio as CRAA conducted the restoration of the Mackey Ford wetland. Because the wetland is nearby the airport, it provides flood protection, water quality improvements and water quantity management for the same watershed that the original airport wetlands served. Appendix B 323

Figure 9. Oversized ditches near Rickenbacker Airport. (23) Initiative Outcome and Current Status In addition to coordinating management of environmental features during the development of the Base property, with approval from the Ohio Department of Transportation, the airport was able to include several water quality features in the design of Rickenbacker Parkway. The roadway includes pervious curbs upstream of inlets that allow sediment in runoff to be filtered through pervious areas before it reaches the storm water inlets. Vortex-type sedimentation units were installed in inlets to remove additional sediment from runoff. Construction of Rickenbacker Parkway involved relocation of a portion of a jurisdictional stream. The portion of the stream that was relocated was part of the ditch system identified as having contaminated sediments. CRAA coordinated removal and disposal of the sediments prior to stream relocation. The relocated stream is designed with a natural flow pattern, and CRAA conducts annual monitoring to ensure the new segment meets EPA required wetland and stream mitigation standards for vegetation. Figure 8 illustrates a portion of the ditch system. The U.S. Army Corps of Engineers (USACE) will also be removing an interceptor in the stream and reshaping it to a more natural meandering channel as the project continues. Farmland on the airport was developed for warehouses, and because of water quality concerns in the Walnut Creek Watershed, Ohio Environmental Protection Agency was concerned about the addition of new impervious areas. One of the warehouses was built with oversized ditches and detention ponds to accommodate additional storm water infiltration and treatment, illustrated in Figure 9. In addition to the storm water quality and flow rate reduction benefits, the oversized ditches and detention ponds were actually the least expensive design choice. Dry detention basins were also incorporated in the new airport parking lot, for required detention for the parking lot. In addition to new infrastructure projects, CRAA implemented several policy and procedural initiatives as part of their storm water programs at LCK and TZR. CRAA has a comprehensive construction storm water guidance document which is provided to contractors as part of the construction documents made available for each project. This document provides guidance on best management Figure 8. Rickenbacker Parkway ditch system. (23). practices for reducing storm water quality impacts from construction activities. CRAA maintains copies of tenant SPCC plans for tenants that have fuel storage that require an SPCC plan. Training is coordinated with annual operations staff meetings, and staff members from all shifts are included in the same meeting. This facilitates communication between staff on environmental and other airport operations issues. Because of the low staff turnover at LCK and TZR, environmental training is 324 Guidebook of Practices for Improving Environmental Performance at Small Airports

typically about an hour, and includes review of spills from the previous year, and any new issues. Annual pollution prevention team training and deicing winter time training is conducted at the tenant snow removal meeting. Training includes a review of the airport features and runoff, and the procedures for reporting spills. CRAA provides a compact disk of the PowerPoint presentation from the pollution prevention training to the tenants when they send annual site compliance inspection letters. The tenants often use the compact disk as part of their own training programs. CRAA is working on an integrated training agenda to organize airport and airport authority-wide training. Under this new program, the Manager of Energy and Environment is responsible for identifying storm water training opportunities and staff that should receive training and attend seminars, EPA classes, environmental events, and expos. The new training program also includes an on-line calendar to coordinate scheduling. Perceived Benefits Creating an inventory of natural environmental features and environmental liabilities protected these environmental features during development and helped ensure safety of employees and the environment during work around environmental liabilities. The database also facilitated transfer of this property to the developer, saving CRAA money in negotiations about environmental issues. Coordinating training events with operations meetings and involving staff members that do not normally communicate facilitates cross communication of issues and efficient use of training budget. In addition to benefits from a coordinated program on development projects and coordinated training, the airport also benefits from coordination with the City of Columbus on storm water utility fees for TZR. The City of Columbus offers an off-set to the fee if the airport maintains its own ditches and storm water infrastructure. CRAA maintains the ditches at all three of its airports, and the ditch maintenance program, which includes regular mowing and vegetation management, provides several benefits: • Control over access to airport ditches located within secure areas • Control over the appearance of the ditches • Regular removal of beaver dams to reduce ponding and standing water that impedes flow, promotes erosion, and attracts wildlife • Reduced fees for TZR and CMH • Additional credit for oversized detention facility at TZR Public use areas are exempt from the City of Columbus storm water utility fee, and CRAA worked with the City of Columbus to exclude TZR’s runways and taxiways from the fee. The City of Columbus bills CRAA based on the City of Columbus geographic information system maps, so CRAA meets with the City of Columbus GIS staff when updates are made to the base maps to ensure they have the most up to date airport maps. CRAA conducts annual storm water pollution prevention inspections of the tenant operations as part of the requirements of their NPDES permit. Unlike at APF, where the airport and tenants maintain separate permit coverage, CRAA’s individual NPDES permit at LCK, and the general NPDES permit coverage at TZR include tenant operations. This occurs because the Ohio Environmental Protection Agency would not accept individual tenant coverage. Because tenants are covered under the airport’s permit, the Obstacles Encountered airport is responsible for ensuring the tenants comply with the requirements in the permit, including complying with best management practices identified in the airport storm water pollution prevention plans. The Manager of Energy and Environment conducts annual site compliance inspections at tenant Appendix B 325

facilities as part of the requirements of the airports NPDES permits. CRAA then sends compliance inspection letters to the tenants. These letters include a checklist from the inspection and identify any issues noted and measures required to address issues. The airport finds that it is a challenge to enforce corrective action on a large number of tenants with varying levels of environmental awareness. CRAA has taken several steps to protect the airport authority from tenant environmental liabilities. CRAA made an effort to include environmental language in tenant leases, and newer leases include clauses for restoration of the property, including potentially conducting sampling and remediating any environmental contamination caused by the tenant. Lease language is often specific to the tenant’s operations, including fueling, maintenance, deicing, or other operations where there is an environmental risk. Although some airport leases are much older, and do not contain the same environmental language, all tenants are subject to the CRAA rules and regulations. There is a section on deicing, environmental, health, and pollution in the rules and regulations which includes several pollution prevention measures: • Requirements for proper disposal of trash and construction debris to avoid spills and leaks • Restrictions on using fill and discarding waste on airport property • Prohibition of fuels, grease, oil, dopes, paints, solvents, acid, flammable liquids or other contaminants or pollutants in the airport sanitary system, storm system, open water, or soil • Procedures for reporting a spill to CRAA and to the Ohio Environmental Protection Agency • Designation of spill cleanup responsibility and expenses to the responsible party • Requirements to conduct deicing in CRAA-approved areas • Response and reporting procedures for deicing material spills • Enforcement and penalties for violations When airport tenants violate environmental rules and regulations, or when issues are repeatedly identified in annual site inspections, tenants are issued a letter including their lease and the airport rules and regulations reminding them that compliance is required. The rules and regulations also provide for monetary penalties and for termination of the lease agreement should the airport find significant issues. Critical Success Factors CRAA benefits from coordination with watershed groups for Walnut Creek. Watershed groups have the ability to influence the community’s or the regulator’s perspective of the airport. CRAA finds it beneficial to coordinate with watershed groups to understand the watershed action plan, and keeps the group informed about the airport development plans. Although local watershed groups are typically less sensitive to the cost of environmental mitigation measures, by working with watershed groups, low cost solutions may be developed that meet the airport’s needs and satisfy the watershed group’s concerns. Positive team work efforts with watershed groups can have a positive impact on how the community and regulators view the airport’s environmental initiatives. CRAA used to regularly hire consultants to conduct storm water training, construction site inspections, and storm water pollution prevention inspections. Under the direction of their new Vice President for Planning and Construction Administration, the airport authority is working to get internal staff more involved in airport engineering and environmental projects. By developing a more rounded internal staff, CRAA project managers will conduct construction site inspections, and CRAA environmental staff will conduct storm water pollution prevention inspections and training. Use of internal staff members instead of consultants to conduct inspections forces airport staff members to engage tenants in identification of storm water pollution risks more often. Conducting environmental Estimated Level of Effort 326 Guidebook of Practices for Improving Environmental Performance at Small Airports

work in-house saves CRAA money, as inspections can be conducted as part of routine site visits, and annual storm water pollution prevention training requires only a few hours from the environmental staff. Estimated Costs The largest annual cost for CRAA is the cost of sampling for compliance with their NPDES permits. The airport spends $15,000 annually for a consultant to conduct sampling at LCK and TZR. The airport spends a few thousand dollars every five years to update their SPCC plans. Other ongoing storm water pollution prevention programs are conducted in house by CRAA’s Environmental, Safety and Health supervisor. The wetlands project was a significant capital cost to CRAA at LCK. CRAA agreed to pay the State of Ohio $112,000 to develop 22.33 acres of wetlands in the Mackey Ford wetland mitigation site just west of the airport. CRAA constructed and will manage the wetlands for the first five years, and the State will take ownership and management of the wetlands after the initial five-year period. CRAA paid a contractor and consultant around $111,000 to build the wetlands, and is spending $75,000 to $100,000 to manage the wetlands during the initial five-year period. Findings and Key Considerations Planning Both CRAA and NAA realized significant benefits from careful and coordinated planning of environmental programs. By incorporating environmental requirements into leases and airport rules, tenants are required to participate in storm water pollution prevention. Coordinating with local watershed groups informs the airport about the watershed plans, and informs the watershed group and the community about the airport’s development plans and environmental mitigation measures. Keeping abreast of anticipated future regulations allows airports to consider incorporating requirements of those regulations during current construction projects to avoid costly retrofits or construction of separate facilities. Implementation By coordinating with tenants on projects, airports can facilitate negotiations with regulators regarding conflicting regulations as one entity for consolidated storm water mitigation measures. Coordinating airport-wide solutions also saves the airport and tenants money, and allows the airport to exercise more control over how tenants manage storm water discharges. Coordination with local communities to implement storm water projects community wide help develop solutions that benefit both the airport and the community, and provide for a means for implementing wetlands and ponds outside FAA’s safety areas. Investment in storm water quality infrastructure in new facilities has a positive impact on the community’s and regulator’s perception of the airport. Ongoing Maintenance Development of airport staff to identify environmental concerns reduces the airport’s reliance on outside environmental consultants, and facilitates early identification of concerns before spills or leaks can reach receiving waters. An integrated training program that involves employees that do not normally communicate facilitates knowledge sharing, and is a more efficient use of training budget. Maintaining a database and map of environmental features, including natural features and known liabilities facilitates transfer or lease of property, protects natural features during development, and manages environmental liabilities. Appendix B 327

Additional Resources • Naples Municipal Airport www.flynaples.com • Naples Municipal Airport Sustainability, Conservation, and Social Responsibility Plan www.flynaples.com/images/docs/general/final%20sustainability%20plan%205-14-09.pdf • International Storm Water BMP Database www.bmpdatabase.org • Columbus Regional Airport Authority http://columbusairports.com/ • Columbus Regional Airport Authority Rules and Regulations for doing business with the airport, including environmental rules http://columbusairports.com/business/CRAA-Rules.pdf • Columbus Regional Airport Authority Storm Water Management for Construction Activities Guidance Manual http://columbusairports.com/construction/Storm%20Water%20Management%20for%20Construction %20Manual.pdf • Columbus Regional Airport Authority Capital Program Sustainable Design Guidance Manual www.columbusairports.com/construction/CRAA-Capital-Program-Guidance-Manual.pdf 328 Guidebook of Practices for Improving Environmental Performance at Small Airports

APPENDIX B-5 Implementing Renewable Energy Systems at Small Airports In recent years, many airports of all sizes have experienced a decrease in commercial aviation demand. With rising fuel costs, even general aviation facilities and other smaller airports have scaled back operations and incurred additional costs to operate. The EPA has recently and aggressively re-evaluated and strengthened existing air quality regulations for many pollutants commonly emitted at airports. Further, aviation has been implicated as a significant contributor to the global levels of greenhouse gases (GHG), and many airport sources of GHG could potentially face regulation in the future. Taken together, all of these factors present an immediate pressure on airport owners and operators to reduce operations and maintenance costs associated with the purchase and use of fuel and energy, whether via mobile sources such as aircraft and ground support equipment (GSE), or via stationary sources such as power generators and heating-ventilation-air conditioning (HVAC) equipment operating in public use areas. Many agencies, including FAA, strongly advocate the installation of renewable energy systems at airports as a means of achieving operational cost reductions and scaling back airport fuel and power demand. The goal of this Case Study is to provide some insight into the requisite steps an airport would take to implement a renewable energy system, including planning, implementation, operations and maintenance considerations, and staff demands. The return on investment (ROI), or simple payback, of these systems can vary considerably, highlighting the need for a careful assessment of available resources and other considerations throughout the decision-making process. This case study will focus on the installation of photovoltaics (PV), or solar energy systems, at small hub commercial service airports such as Tallahassee Regional Airport (TLH) and Santa Barbara Municipal Airport (SBA), to provide details on available options and methods, and to demonstrate what can be expected throughout the process. Case Narrative—Tallahassee Regional Airport (TLH) Initiative Driver Due to persistent main terminal roof leaks and water intrusion problems, TLH staff initiated a Terminal Rehabilitation Project approximately 10 years ago. A component of this project involved repairing a 22-year old section of the roof that was lined with cracked and breaking concrete tiles. About eight years into the planning process, TLH had the idea to include PV into the new roof structure, furthering an initiative in place by the City of Tallahassee local government to develop renewable energy programs in the community. It was evident to planners and staff that such a measure may fit within the budget of the Terminal Rehabilitation Project as well as improve the community’s opinion of the airport. Appendix B 329

Implementation Strategy For the Terminal Rehabilitation Project as a whole, airport officials note that they had to apply for standard building permits. Since TLH announced that it planned to incorporate PV panels into the new terminal roof, they have been approached by many third party vendors and engineers offering to install an extensive solar panel array at the airport. The airport has declined this approach because they would have to somehow garner funds to cover the costs of installing and maintaining the larger array, as well as brokering the energy produced with the local power authority. Instead, TLH has opted for a more cost-effective approach that fits into the budget of the Terminal Rehabilitation Project (see Figure 10). They currently plan to purchase and install amorphous silicon thin-film PV laminates to the new roof section, once constructed. The new section is located on the back side of the public area, above the baggage claim. Approximately 10% of the total roof surface area is planned to be covered with the PV laminates. The airport investigated a range of size/capacity laminates: 25 kiloWatt (kW), 50 kW and 75 kW. Notably, because some components of the project have already exceeded budget, the airport has elected to purchase the 25 kw option, and plans to re-evaluate purchasing a higher capacity system later in the process. In addition, the airport has determined that other portions of the terminal buildings are compatible with the technology, and is not averse to expanding the PV array to these sections in the future, given sufficient budget. Engineers have recommended to the airport that a PV array would work more efficiently if the roof were slanted to a greater degree, but doing this is also currently out-of-budget. Nonetheless, the PV laminates generate energy that is immediately available to the facility, and never enters the area power grid, which would potentially incur surcharges, taxes or other fees assessed by the local power authority. Importantly, TLH had to secure an electrical permit to tie the PV laminates into the terminal’s current electrical configuration. However, the airport is quick to note that this process incurs very minimal additional costs, and does not involve much more than drilling holes and running wires through the new roof structure to connect the systems. Moreover, maintenance of the systems would only involve periodic wiring inspections and keeping the array clean of dust, soot and debris. Once completed and installed, TLH plans to showcase the benefits of the technology to airport patrons and staff by installing a liquid crystal display monitor in the terminal area that delivers real-time statistics on the PV system’s performance and generated energy. TLH hopes that this measure will further improve public relations with the airport and garner additional support for the City’s renewable energy initiatives. Initiative Outcome and Current Status TLH believes the PV array will be up and running upon completion of the terminal roof construction. Bids to construct were opened in early March 2010, with the desired construction start date on or around Figure 10. Tallahassee Regional Airport terminal and airfield. (Source: Tallahassee Regional Airport, 2010) (24). 330 Guidebook of Practices for Improving Environmental Performance at Small Airports

July 1, 2010. If the desired schedule is maintained, construction could be completed as early as spring, 2011. Perceived Benefits In October 2009, TLH stated that the planned PV array could potentially supply up to 30% of the terminal’s energy consumption. Again, the airport also believes that a marked improvement in public relations is attainable through showing voluntary participation with the City’s renewable energy initiatives. TLH staff admits that they have not yet fully investigated project eligibility within the U.S. Green Building Council Leadership in Energy and Environmental Design (LEED) program, which provides guidance and evaluation of renewable energy and other sustainable design features. However, because the LEED program evaluates sustainable building design using more categories than energy efficiency, and because the airport’s target is small compared to other LEED projects, the airport finds it unlikely that the project is eligible for LEED certification or ratings. Obstacles Encountered/Critical Success Factors As of this writing, the only obstacles identified throughout the implementation process pertain to the cost of purchasing and installing the technology, and the fact that the airport’s return on investment significantly depends on the level of grant funding secured. This issue is further discussed in the “Estimated Costs” section below. TLH is quick to acknowledge that funding is the most critical success factor to implementation. Estimated Level of Effort TLH currently has no full-time environmental support staff. The airport’s Capital Program Administrator also serves as Environmental Manager, performing the associated job tasks part-time. Job tasks include environmental compliance and planning. As such, the staff has strongly depended upon the aid of engineers and consultants to guide the airport through the planning, design, and construction process. The Capital Program Administrator also highly recommends consulting with an electrical engineer often when developing a solar energy system. Estimated Costs The Terminal Rehabilitation Project is expected to cost around 4 million dollars to implement. Purchase and installation costs for the PV array range from approximately $125,000 for the 25 kW option to between $350,000 and $400,000 for the 75 kW option. Accordingly, acquiring funds to cover these costs is essential to the project’s success. According to TLH staff, much of the Terminal Rehabilitation Project has been funded by Passenger Facility Charges levied by the airport upon its patrons and other users. In addition, TLH has initiated the grant application process for FAA’s Airport Improvement Program (AIP) grant, which can provide necessary federal funds “for the planning and development of public-use airports that are included in the National Plan of Integrated Airport Systems (FAA, 2010). The airport has stated that it received some grant funding through the Florida Department of Transportation for the Terminal Rehabilitation Project, which included a five-year application and approval process. Notably, however, this funding was awarded to the project as a whole and not necessarily on the merits of its solar energy component. Appendix B 331

Figure 11. Photovoltaic array at Consolidated Rental Car Facility at Santa Barbara Municipal Airport (Source: Lynn Houston, Santa Barbara Municipal Airport, 2010) (26). A significant factor in implementing a renewable energy system is the simple payoff associated with the action, also referred to as the ROI. The expected ROI for the action, given a few assumptions and alternatives, is summarized in Table 7 below. As shown, the ROI expected for this project greatly improves if the airport can secure funds through the Energy Efficiency and Conservation Block (EECB) Grant. Table 7. Expected return on investment for the Photovoltaic laminates. ROI Payback Horizon (years) Energy Capacity (in kW) Annual Savings Electricity Rate ($/kWh) With Energy Efficiency and Conservation Block Grant Without Energy Efficiency and Conservation Block Grant 25 $3,200 8.6 40 50 $6,500 19.1 34 75 $9,700 $0.11 23.8 34 The Energy Efficiency and Conservation Block Grant has been established by the Florida Energy and Climate Commission, made possible by a portion of American Recovery and Reinvestment Act of 2009 funds allocated to the State of Florida for renewable energy projects and other sustainable activities. Total funds secured by the State through this program total over 30 million dollars, however many of these funds have already been allocated or assigned. TLH is currently developing an application to receive some of the Energy Efficiency and Conservation Block funding reserved for smaller scale renewable energy projects. Case Narrative—Santa Barbara Municipal Airport (SBA) Initiative Driver As part of their new main terminal construction, SBA wanted to include a rental car storage and quick turnaround facility, where rental cars would be taken to be serviced, cleaned, fueled, and returned to the rental area. However, there was insufficient space in the existing main terminal area to accommodate the new planned facility. Throughout the planning process, SBA decided to construct the facility in a separate area. The quick turnaround facility is not planned to be a public use area because all car rental counters and associated areas that patrons would frequent shall remain connected to the main terminal area. Because the facility was to be newly constructed, and because the City Council of Santa Barbara wished to attain LEED Silver ratings on all newly constructed buildings, SBA staff decided to incorporate an extensive array of sustainable design features into the quick turnaround facility, including on-site renewable energy generated via a PV array (see Figure 11). SOURCE: RS&H for Tallahassee Regional Airport, 2010 (25). 332 Guidebook of Practices for Improving Environmental Performance at Small Airports

Implementation Strategy Overall, the building is approximately 10,000 square feet in size, with a 4,500 square foot fuel island canopy and a 12,000 gallon aboveground fuel storage facility. There is sufficient space to store around 300 rental cars. The PV array installed at SBA comprises 816 total panels, with 520 mounted onto the roof and 296 onto a self standing canopy covering the car storage lot, with each panel measuring 53’’ x 35’’ x 2’’. SBA chose the Sanyo brand HIT Double bifacial solar panels capable of capturing energy on both the top and bottom face, each with a rated power of 195 watt. Because the panels generate power as direct current, SBA also had to purchase two Solectria brand power inverters (PVI 95 kW) to convert the energy to alternating current, a form that can be readily used by the building infrastructure. SBA officials have conveyed that the process was relatively straightforward and unremarkable compared to other construction projects they’ve conducted. Because they began the project planning with sustainability in mind, SBA involved LEED experts and support staff very early in the process. Initiative Outcome and Current Status The selection process for engineers, consultants, and other contractors began in 2006. Construction of the facility began in 2008 and was finished in November 2009. The PV array is fully operational and has begun generating power and revenue for the airport. Importantly, even though SBA designed the building with the hopes of attaining the LEED Silver rating (between 33 and 38 points out of a possible total score of 69), the project received an improved rating of LEED Gold (between 39 and 51 points). Of note, the “Energy and Atmosphere” scoring category, under which on-site renewable energy components are evaluated, constitutes up to 17 points of the total score. Benefits In sum, the panels constitute a 159,120 watt alternating current system with an expected output of approximately 200,315 kWh per year. Notably, the building is forecast to consume about 208,425 kWh of electricity per year. SBA officials have established a website that displays real time monitoring of the energy produced by the PV array, the energy used at the facility, and the quantity of GHG saved by using solar power. Figure 12 compares the output of the PV system versus the power demand of the building, in kWh, for the period of March 28th to April 28th 2010. As shown, on most days the energy produced by the PV array meets a large percentage of the building’s power demand, and sometimes generates surplus power. During this time interval, the PV energy produced accounts for between 42 and 303% of the building’s daily power demand, with an average of 116%. Appendix B 333

Figure 12. Solar power output at Santa Barbara Municipal Airport, 3/28/2010 – 4/28/2010 (Source: Fat Spaniel Monitoring Site, Santa Barbara Municipal Airport, 2010) (27). Obstacles Encountered/Critical Success Factors SBA officials identified two main factors deemed critical to the successful implementation of the quick turnaround facility. First, it was important to secure input from the rental car agencies servicing SBA early in the planning process, to properly gauge their needs and demands for the quick turnaround facility, and account for them in the design process. Secondly, SBA officials stated that involvement of the LEED design team from the start of the design and implementation phase had a large bearing on the project’s LEED Gold rating. Estimated Level of Effort Notably, SBA staff remarked that the level of effort required to produce the sustainably designed QTA was no greater than that of other improvements in place or planned at the airport. In terms of environmental support and sustainable design staff, SBA currently staffs two full-time planners, one full- time environmental compliance manager, and one full-time design engineer that assists the compliance manager as needed. Estimated Costs From an operational standpoint, SBA officials are still finalizing cost estimates. In terms of design and construction costs, the bulk of the airport’s expenditures were allocated to the construction of the facility. Specifically, $773,000 was allocated to the facility’s design, $6,697,000 to construction, and $881,000 to construction support, for a grand total of $8,351,000. Notably, the PV array comprised $1,100,000 of the $8,352,000 design and construction costs. 334 Guidebook of Practices for Improving Environmental Performance at Small Airports

SBA states that they neither applied for nor received any grants or other funding assistance to implement the project. The implementation and construction costs of the quick turnaround facility were completely absorbed by the Consolidated Rental Car Facility Customer Facility Charge program in place at the airport. Simply put, the Consolidated Rental Car Facility Customer Facility Charge program assessed a $10 surcharge on every rental contract executed at the airport to support the planned infrastructure improvements. It is expected that the PV array will yield an approximate ROI of 19 years, based on a conservative 4% annual increase in power rates and an assumed 1% degradation in the output capacity of the PV panels per year. However, the PV array is grid-tied and net metered by the local power authority (Southern California Edison), and any excess PV power generated at the facility is eligible for credit by Southern California Edison. Consequently, the ROI payoff may occur sooner than 19 years. In addition, it is expected that the project will receive reimbursement from the California Solar Initiative in the form of a performance based rebate. Specifically, the project is slated to receive a rebate of $0.32/kWh generated for the first five years of its operation. Because the expected output is approximately 200,315 kWh per year, as much as $320,504 (200,315 kWh/year * 5 years * $0.32/kWh) can be recovered through the rebate program, which can also lower the expected 19-year ROI considerably. Findings and Key Considerations Planning Based on TLH’s experience, construction planning can take as long as 10 years, and acquisition of funds can take up to five years. Because SBA’s project required no outside funding, and because the PV array was occurring in a newly constructed area rather than being tied into existing infrastructure, the process took considerably less time. Either way, starting such components of the planning process as early as possible is highly recommended to ensure a successful renewable energy venture. With a limited staff, small airports might not have the resources available to assign these tasks to environmental support or planning staff, and accordingly contracting with outside consultants and engineers to assist in the process is also very important. The utility of this approach is echoed in the experience of both airports, albeit SBA had a larger available budget and slightly greater staff resources to work with. Overall, the fact that both airports involved consultants and sustainable design engineers early in the process, and were able to fund the project using airport revenue, factored largely into their project’s relatively quick and successful realization. From a planning standpoint, making a renewable energy project cost-beneficial hinges directly upon the level of funding the airport can secure, whether through its own budget (SBA) or through a combination of its own budget and available state and federal grants (TLH). Implementation The case studies presented herein have provided valuable insight into implementation strategies. TLH’s venture was in part successful because they were able to integrate the renewable energy project into a larger, necessary infrastructure improvement, making them eligible for additional funding through grant programs. The airport was also prudent in selecting an alternative that provided them with some energy savings within the constraints of the available budget. Overall, the directed-revenue approach realized by SBA using their Consolidated Rental Car Facility Customer Facility Charge program, and by TLH using passenger facility charges, provided budgetary Appendix B 335

latitude that facilitated implementing the PV projects. Moreover, TLH’s experience has demonstrated that careful planning and implementation can allow for the project to be expanded in the event that additional funding is secured. Ongoing Maintenance In the case of the TLH PV array, ongoing maintenance is expected to be minimal. Because the SBA project utilizes a more traditional, roof-mounted PV array, the associated maintenance costs could potentially be greater. Generally speaking, airports wishing to engage in similar activity should be conservative in allocating funds to maintenance and upkeep when conducting their cost-benefit analysis. Additional Resources • More information on FAA AIP Program http://www.faa.gov/airports/aip/ • More information on the City of Tallahassee Solar Energy Projects http://www.talgov.com/you/electric/solar.cfm • More information on State and Federal Energy Efficiency and Conservation Block Grants http://myfloridaclimate.com/climate_quick_links/florida_energy_climate_commission/arra_funding_ and_opportunities http://www.eecbg.energy.gov/ • More information on the LEED Program http://www.usgbc.org/DisplayPage.aspx?CategoryID=19 • More information on TLH http://www.talgov.com/airport/ • More information on PV Technology http://www.solarpanelinfo.com/ http://us.sanyo.com/HIT-Power-Double/HIT-Double-Bifacial-Photovoltaic-Module http://us.sanyo.com/dynamic/product/Downloads/solarPower_HIT_Double_195_Data_Sheet- 13054720.pdf http://www.solren.com/PVI_60KW_PVI82KW_PVI95KW.pdf • More information on SBA’s PV Monitor http://siteapp.fatspaniel.net/siteapp/simpleView.jsf?eid=329264 • More information on the California Solar Initiative Rebate Program http://www.gosolarcalifornia.org/csi/apply.html • More information on SBA http://www.flysba.com/ 336 Guidebook of Practices for Improving Environmental Performance at Small Airports

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TRB’s Airport Cooperative Research Program (ACRP) Report 43: Guidebook of Practices for Improving Environmental Performance at Small Airports outlines federal environmental regulations and requirements, and identifies activities in which airport operators can be proactive in promoting environmental stewardship.

As a quick reference, summary graphics provide information pertaining to the cost and savings as well as the necessary knowledge and amount of time to implement a particular activity. In addition, there are five case studies that discuss environmental initiatives already undertaken at airports that can serve as a guide for other airports.

The report includes the collection of environmental stewardship practices in a searchable, filterable spreadsheet format on a CD-ROM, which is packaged with the report.

The CD-ROM included as part of ACRP Report 43 is also available for download from TRB’s website as an ISO image. Links to the ISO image and instructions for burning a CD-ROM from an ISO image are provided below.

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Errata

1) ACRP Report 43 contained incorrect information in Figure 2. The corrected version of Figure 2 is available online in PDF format.

2) On page 18 of the print version of the report the first two lines of text were inadvertently omitted. The online version of the report has been corrected.

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