Guidebook of Practices for Improving Environmental Performance at Small Airports (2010)

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7CHAPTER 2 Establishing an Effective Environmental Program Establishing an effective environmental program can be accomplished within the typical capabilities, financial resources, and environmental expertise of most small airports. With a clear vision, proper organization, and persistence, small airports can implement effective environmental programs as diverse as those at much larger facilities. However, taking on too much and expecting perfection at the onset will almost certainly result in frustration and disappointment. How to begin is a frequent question posed by small airports seeking to improve upon their environmental programs. Following the “Plan-Do-Check- Act” (P-D-C-A) cycle, illustrated in Figure 1 made popular as a business process improvement strategy by Dr. W. Edwards Deming is one demonstrated approach. In the environmental arena, P-D-C-A is commonly associated with the International Organization for Standardization (ISO) 14001 Environmental Management System (EMS) standard. The EMS standard prescribes the implementation of specific management system elements within each of the four P-D-C-A phases. While similarities exist, the suggested environmental program improvement tasks presented by phase in this chapter are not intended to conform to the ISO 14001 standard or result in a functional EMS. The suggestions represent key iterative tasks commonly found in effective airport environmental programs. 2.1 Plan The “Plan” phase of the P-D-C-A cycle is where an airport’s overall environmental program should be defined or refined. Questions that must be answered include: • What are the guiding principles of the environmental program (i.e., how does the airport want to be viewed environmentally)? • Which environmental laws and regulations are applicable to airport operations? • What are the objectives of the environmental program (i.e., what must the airport do to achieve and maintain its desired environmental image)? • How will the environmental program be structured to meet its environmental objectives and maintain consistency with its guiding principles (i.e., who is responsible for doing what)? Preparing a Clear Environmental Policy While a seemingly insignificant task, setting the guiding principles of an airport’s environmental program is a challenging and sometimes time-consuming process. The guiding principles, often documented in a mission statement or “A good plan today is better than a perfect plan tomorrow.” George S. Patton Helpful Hint For more information on EMS implementation, refer to the Westchester County Airport Case Study in Appendix B-2. Figure 1. The “Plan-Do- Check-Act” Deming cycle.

8 Guidebook of Practices for Improving Environmental Performance at Small Airports environmental policy, establish what is environmentally important to an airport and how it wants to be seen by its employees, business partners, and the general public. Therefore, drafting an environmental policy often requires the participation of and approval by the airport’s management and board of directors. This may be a challenge, especially where there are diverse opinions as to how environmental considerations fit into airport operational and development decision-making. Ultimately, a well-crafted environmental policy should be a reference for operational and development decision-making and shape the establishment of environmental program objectives. Identifying Applicable Environmental Laws and Regulations Achieving and maintaining environmental compliance should be an underlying tenet of airport environmental programs. To accomplish this, an airport must first identify the laws and regulations applicable to its operations. This Guidebook and referenced resource materials can assist by breaking down the universe of environmental regulatory programs into manageable pieces. It begins by understanding how common airport activities may be regulated. Familiarity with common airport activities is the critical starting point for identifying applicable environmental regulatory programs. Table 1, which presents a matrix of common airport activities and Guidebook chapters, can facilitate quick location of a regulatory program summary applicable to a listed activity. The regulatory summaries offer a high-level overview of federal environmental compliance requirements including laws, regulations, and other directives. This information can be used to assess regulatory applicability and establish a general understanding of each program’s scope and purpose. The Guidebook does not restate the text of the federal environmental requirements or provide step-by-step descriptions of methodologies for compliance, as these are beyond its intended scope. However, for most of the programs described in the Guidebook, web-based links to the regulatory text, regulatory guidance, and other additional resources are provided. Many state governments have been authorized or delegated the responsibility to promulgate, administer, and enforce federal environmental laws and regulations. Because state-led and, in some cases, local government-led environmental programs are equivalent or more stringent than their federal counterparts, the Guidebook’s regulatory summaries remain relevant. However, to establish a truly effective environmental program, airport operators should use their understanding of the applicable federal environmental laws, regulations, and other directives to identify and assess the applicability of state and locally administered environmental programs. Setting Environmental Objectives Environmental objectives should describe what an airport must do to achieve and maintain compliance with applicable environmental laws and regulations and conform to its environmental policy. Example program objectives may include consistently meeting airport storm water permit requirements, minimizing Helpful Hint Developing relationships with contacts at various state and federal agencies may facilitate staying abreast of new and changing local, state and federal regulations. Helpful Hint Refer to the Northeast Florida Regional Airport at St. Augustine Case Study in Appendix B-1 on how to garner support within a small airport organization to initiate proactive environmental stewardship practices.

Establishing an Effective Environmental Program 9 landfilled waste, or conserving potable water. Objectives may also have indirect environmental benefits such as implementing an employee environmental awareness and training program. For each environmental objective, one or more implementation strategies and performance measures should be established to help an airport understand how it can achieve the objective, when the objective has been met, or what progress has been made toward achieving it. Using the earlier example objectives, the following are example implementation strategies and performance measures: • Example 1 Objective: Consistently meet airport storm water permit requirements. Implementation Strategy: Provide routine training for an airport-wide storm water pollution prevention (SWPP) team and conduct periodic inspections. Performance Measure: No violations identified during storm water inspections. • Example 2 Objective: Minimize landfilled waste. Implementation Strategy: Institute a recycling program targeting readily separable and recyclable waste streams. Performance Measure: Capture and recycle 80 percent of cardboard and 90 percent of office paper within two years of program implementation. • Example 3 Objective: Implement an employee environmental awareness and training program. Implementation Strategy: Hire a consultant to develop initial training materials and conduct initial training; airport conducts subsequent annual and new hire training sessions. Performance Measure: 100 percent of airport employees trained within one year; all new employees trained within one month of hire. Assigning and Communicating Program Roles and Responsibilities To avoid key environmental program roles and responsibilities from going unfilled, airports should develop an environmental organizational chart that clearly assigns roles and responsibilities to airport staff, or in some cases, non- airport entities (e.g., fire department, contractors, vendors, etc.). This organizational chart should touch each airport function (e.g., management, legal, properties, planning, engineering, operations, maintenance, communications, etc.) and should be accompanied by a detailed description of the roles and responsibilities within the environmental program. For example, airports should clearly assign responsibility for the following: • Establishing or modifying the organization’s environmental policy • Determining applicable environmental laws and regulations • Establishing or modifying program objectives • Assigning and enforcing environmental roles and responsibilities • Identifying the needs and committing the resources necessary to implement the program objectives • Identifying potential environmental implications of planned facility and infrastructure improvements

10 Guidebook of Practices for Improving Environmental Performance at Small Airports • Informing consultants and contractors of environmental performance expectations and ensuring the expectations are met • Managing employee, tenant, and contractor training programs • Identifying the need for and applying for environmental permits • Coordinating with regulators • Conducting routine facility inspections • Reviewing and retaining environmental documents and records • Responding to, containing, cleaning up, and disposing of spills occurring on airport property • Communicating environmental program successes, or if necessary, reporting failures An effective environmental program relies upon clearly defined and assigned roles and responsibilities. However, the inability of an environmental program to achieve its intended objectives is less likely due to inadequately defined roles and responsibilities, but rather inadequately communicated roles and responsibilities. Airports of all sizes have experienced situations where employees make wrong decisions having potentially serious environmental consequences simply because they were not familiar with their assigned responsibilities. Therefore, environmental roles and responsibilities should be reviewed with assigned individuals periodically, and as program components and staff are added or change. 2.2 Do The “Do” phase of the P-D-C-A cycle represents the culmination of environmental program planning efforts. During this phase, the program objectives and strategies should be fully implemented by the individuals and entities assigned specific roles and responsibilities. Airports should give special attention to the timing of regulatory compliance requirements, especially when there is routine inspection, monitoring, reporting, training, or advance notification requirements. Developing a compliance calendar and distributing it electronically or in hardcopy is an effective strategy for ensuring compliance deadlines are not overlooked. Conducting Integrated Environmental Training Environmental training resides in the “Do” phase because it is often a regulatory requirement that must occur at a predetermined frequency. Training is also a beneficial method for increasing awareness of an airport’s environmental policy and program objectives, and reinforcing roles and responsibilities. Training attendees should include airport staff with the potential to impact the environment, as well as airport tenants, contractors, and vendors. Ongoing effort will be required to maintain current training materials and to train new staff and tenants, as needed. Environmental training sessions should be a positive experience for attendees, and while past issues should be reviewed, it should be done in a way that avoids placing blame and emphasizes what should be done to prevent future occurrences. Training should also be an opportunity to reward employees and tenants for environmental success (e.g., no violations “The single biggest problem in communication is the illusion that it has taken place.” George Bernard Shaw

Establishing an Effective Environmental Program 11 identified during storm water inspections, successful implementation of new initiatives, increased participation in voluntary no fly curfews, etc.) and to get feedback on environmental policies and initiatives. The best ideas for environmental conservation, protection, and improvement may come from staff attending environmental training. 2.3 Check The “Check” phase of the P-D-C-A cycle provides airports the opportunity to monitor environmental program performance and assess if observed results align with the environmental policy, achieve program objectives, and meet internal and external airport stakeholder expectations. If the results are not as expected, the information gathered may help to understand why. This phase should also be used to maintain awareness of an ever-changing regulatory landscape. Monitoring Environmental Program Performance Identifying environmental program gaps is an integral step toward improving program performance. Gaps commonly result from one or more of the following: • Staff turnover without reassignment of roles and responsibilities • Incomplete regulatory reviews • Changed facility operations or infrastructure without consideration of the regulatory implications • Promulgation of new regulations for previously unregulated operations or infrastructure • Changed expectations without associated changed objectives Identifying gaps before they result in potential costly enforcement actions or negative publicity can be accomplished by completing the following activities: • Maintaining a list of applicable environmental regulatory programs, as well as those that could reasonably become applicable (e.g., by adding a new activity or increasing the scale of an existing activity) • For each environmental regulatory program, creating a checklist of key actions required for compliance (e.g., permit applications and renewals, plans, inspections, record keeping, training, etc.) • Conducting an environmental compliance applicability review for planned operational changes or facility improvements utilizing the compliance checklist • Periodically (e.g., quarterly, semi-annually, or annually depending upon level of risk) conducting environmental compliance audits for existing activities To reduce the operational and financial burdens presented by training programs, airports should consider opportunities to integrate regulatory training programs. Presenting one 1-hour integrated program rather than two 30-minute programs can help attendees “connect the dots” between related regulatory programs. For example, SWPP training and spill prevention, control and countermeasure (SPCC) training are often combined because both regulatory programs target the protection of storm water runoff quality and nearby surface waters.

12 Guidebook of Practices for Improving Environmental Performance at Small Airports utilizing the compliance checklist to ensure the environmental program is meeting objectives Airports must monitor and respond to pressure from within and outside of the organization to meet changing environmental expectations. Examples of external pressures include local government environmental commitments or a growing environmental concern from the general public. An example of internal pressure is an airport board’s commitment to adopt more sustainable practices as part of a proactive environmental stewardship initiative. Identifying opportunities for increasing proactive environmental stewardship is presented in the later discussion of the “Act” phase of the P-D-C-A cycle. Tracking a Changing Regulatory Landscape Identifying applicable environmental laws, regulations, and other directives is a continuous process requiring routine monitoring for new and changing requirements. Airports can stay abreast of regulatory changes by actively participating in state or national aviation trade organizations. Many trade organizations have established programs for monitoring proposed legislation and new regulatory initiatives, and they alert their membership through digital communications and conference presentations. Additionally, active membership networks enable near real-time knowledge and information sharing. Establishing and maintaining proactive and positive relationships with state environmental regulators is another effective method to stay informed of regulatory changes. Airports should approach regulators about anticipated future regulations and seek guidance on compliance challenges that may significantly and adversely impact airport operations. These established relationships may pay dividends in the event an unanticipated compliance issue arises. 2.4 Act The “Act” phase of the P-D-C-A cycle provides airports the opportunity to assess elements within their environmental programs that may require improvement (e.g., identified as gaps during the “Check” phase). Airports should assess where in the preceding phases the problems originate and commit to a plan to improve the deficient environmental program components. Identifying Opportunities for Proactive Environmental Stewardship Small airports have a number of opportunities to proactively enhance environmental stewardship through careful selection of practices that meet stewardship goals while catering to the needs and constraints specific to the airport. The practices presented in Appendix A of this Guidebook may be implemented to effectively meet and/or exceed the requirements of the environmental regulations. In addition to these practices, small airports have the opportunity to address environmental stewardship in areas that are not directly regulated, as described in further detail in Chapter 9.

Establishing an Effective Environmental Program 13 Additional Resources In addition to the numerous regulatory resources identified in the following Guidebook chapters, and practice-specific resources identified in Appendix A, small airports should become familiar with the general content of the following resources while developing and expanding their environmental programs: • FAA Website http://www.faa.gov/ • FAA Airport Regional Offices http://www.faa.gov/about/office_org/headquarters_offices/arp/ regional_offices/ • FAA Airport Environmental Program http://www.faa.gov/airports/environmental/ • EPA Website http://www.epa.gov/ • EPA Website A-Z Index http://www.epa.gov/epahome/quickfinder.htm • Sustainable Aviation Guidance Alliance (SAGA) Guidebook and Database www.airportsustainability.org • Joint Service Pollution Prevention and Sustainability Library http://205.153.241.230/ • ISO 14000 http://www.iso.org/iso/iso_14000_essentials • EMS Peer Center www.peercenter.net • EPA EMS resources http://cfpub.epa.gov/compliance/resources/publications/incentives/ems/