Airport Air Quality Management 101 (2018)

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32 How an airport prioritizes and responds to airport air quality issues is often of significant interest to the local com- munity, the general public, regulators, and other stakeholders since they may be directly or indirectly affected by the emissions or related activities. Issues over airport air quality can arise for many reasons: • An airport expansion project may generate construction emissions, • Increases in airline schedules could potentially result in increased overall emissions associated with airport activities, • Environmental approval or permitting of a project or new generator provide opportunities for public review and input, • An illness outbreak at a nearby school may cause parents to raise questions about airport emissions, • An air quality concern at another airport may bring media attention to an airport’s air emissions, or • Public interest in broad environmental impacts like climate change may stimulate questions for an airport. For these reasons and others, airports must be prepared to engage with stakeholders to answer questions based on a clear understanding and analysis of emissions from airport operations and to provide authoritative sources of information for context. Although airports have broad control over airport-run facilities such as heating and cooling plants, generators, fire-training activities, and snow-melting equipment, they have more limited influence over vehicles travel- ing to and from the airport and even less over aircraft and associated GSE, which are the major sources of emissions. This makes stakeholder engagement complicated since the general public and often the regulators assume that airport management has control over all the major sources of air emissions. (See Section 3: Airport Emissions and Sources and Section 4: Air Quality Analysis.) Most airports have stakeholder engagement activities already in place such as a standing citizen advisory committee (CAC), which can be a starting place for engaging on air quality issues. Often CACs are specifically convened as part of the environmental review under NEPA or other environmental regulations. Additionally, many airports have developed and refined approaches to engaging stakeholders that have proven successful such as newsletters, postings on an airport’s website, or regular meetings with regulators. Many airports develop and maintain ongoing relationships with stakeholders so that a good basis for trust and understanding has been established when issues arise. With regard to air S E C T I O N 9 Stakeholder Engagement Strategies

Stakeholder Engagement Strategies 33 quality, there will usually be a core group of stakeholders with an interest in the issues. These might include environmental representatives from the local municipality or state government; FAA staff; local, state, and/or federal air quality regulators; local chapters of environmental non- governmental organizations; or representatives from neighboring communities. Depending on the issues at hand, it may be possible to handle all stakeholders through a common process and form of engagement: however, for some issues it may be necessary to handle opponents separately from supporters or other interests to be effective and keep the process moving. For each engagement with stakeholders, the airport should make an effort to find areas of common interest and ensure that it understands the scope and priorities of each stakeholder’s interests. This is a prime opportunity to educate stakeholders about the airport’s operations, clarifying the roles and responsibilities of the airport, airlines, FAA, tenants, and other entities in relation to air quality. Sharing ACRP Research Report 185: Airport Air Quality Management 101 or selected sections may be a way to help non-specialists understand the scope and activities of the airport’s air quality program and inform them of specialized terms needed to understand airport air quality. Having quantitative documentation about the airport’s emissions and air quality impacts is a useful way to establish credibility and demonstrate transparency. This might include an airport emissions inventory, a summary of air quality permits and conditions, and the airport’s sustainability plans, climate action plans, or any mitigation planning that may be underway. 9.1 Opportunities for Stakeholder Engagement There are several opportunities for stakeholder engagement in relation to air quality manage- ment at airports. Table 2 summarizes airport activities and potential stakeholders. Airports that have successful stakeholder engagement programs typically identify who the stakeholders are, determine what those stakeholders’ objectives are, and engage them as needed. The first step is identifying airport activities or functions for which stakeholder engagement is required or would be beneficial. While certain activities—such as a NEPA review—require stakeholder engagement, it is highly recommended that airports engage stakeholders during any planning, permitting, or construc- tion activity or operational change. Most airports do not engage stakeholders solely on functions related to air quality; rather, air quality is discussed within other activities or functions. 9.1.1 Planning Many airport planning activities have an air quality component or involve changes at the airport that will have an air quality impact. Frequently, these plans involve airport staff, air- lines, tenants, ground transportation providers, and the community. The plans do not neces- sarily need to include environmental or regulatory agencies, although often agencies wish to be informed of an airport’s plans as they are being developed rather than when the planning effort has reached its conclusion. The FAA recommends that the community be engaged during the airport’s master planning process through establishment of a CAC or similar group with broad representation from the community and airport users, as appropriate. A key element for this and other stakeholder processes is clarifying that stakeholder input is advisory and that the airport will make final decisions on policy, projects, and programs. The CAC can be used as a forum for sharing find- ings, briefing on projects or alternatives under consideration, or for requesting data or opinions. Ensuring appropriate notification of these stakeholder forums is important; notification should occur via the newspaper, the airport’s website, and mailings.

34 Airport Air Quality Management 101 9.1.2 Environmental Regulatory Review and Permitting For specific facility or equipment permits and approvals, opportunities for public review and comment vary by state or jurisdiction. A key element of this process, however, is direct and early engagement with the regulatory agencies that will grant the approval or permit. Ideally, airport staff would meet early with regulators and introduce the project and the anticipated air quality impacts. Together, the airport and agency staff would discuss the types of required air quality analyses (see Section 4: Air Quality Analysis) and would confirm the scope and methodology of the analysis protocol. It is recommended that the airport prepare well for this first meeting and provide a suggested approach so as to frame the scope and level of analysis. Coordinating with the agency throughout the process is good practice for things Airport Activity Potential Stakeholders Planning Strategic planning Project planning Ground transportation planning Sustainability planning Airlines, air cargo, and GSE operators Tenants Ground transportation providers (public transportation, hotel and rental car shuttles, and taxi/limousine services) Community/general public Permitting NEPA reviews (emission inventory, dispersion modeling) Air quality conformity determinations Local environmental protection approvals Permits for stationary sources (Title V, new source review) SIPs Airport staff Environmental/regulatory (EPA/state environmental agencies) FAA Local government Community General public Mitigation High-occupancy vehicle (HOV) strategies Grant funding (VALE, etc.) Construction mitigation (equipment retrofitting) ACERT (carbon accreditation) Alternative energy (electric GSE, renewable energy) Airport staff Environmental/regulatory (EPA/state environmental agencies) FAA Ground transportation providers (public transportation, hotel and rental car shuttles, and taxi/limousine services) Community/general public Compliance and Tracking Meeting permit requirements Tracking emissions airport wide or for specific equipment/facilities Airport staff Environmental/regulatory agencies Construction Construction equipment Onsite construction activities Deliveries/truck routes Airport staff (planning, capital programs, operations) Environmental/regulatory agencies Contractors General public Operations Airside—taxiing, use of APUs, aircraft fueling, GSE, fire training Landside—roadway operations, parking, curb operations and idling, HOV providers, cargo and other deliveries Airport staff (planning, capital programs, operations) Airlines Concessionaires Tenants FAA Maintenance Building and facility maintenance Equipment and supplies procurement Airport staff (operations, maintenance) Tenants Reporting Annual reporting on permit conditions Annual NAAQS emission inventory Annual GHG emission inventory Quarterly reporting on parking Environmental/regulatory agencies General public Off airport parking shuttles Table 2. Airport activities and potential stakeholders.

Stakeholder Engagement Strategies 35 like confirming existing conditions, previewing preliminary findings, and suggesting possible mitigation (if needed). 9.1.3 Construction Construction activities often attract community attention. Communities tend to be concerned with the level of emissions associated with construction at airports, not only with construction activity. If activity at the airport is projected to increase, communities want to know how much emissions will increase. Airport staff need to be included in the decision making, planning, and implementation processes to ensure that all opinions and ideas are shared. Many airports have a construction complaint hotline that provides members of the public with a forum for any grievances that may result from the construction process. 9.1.4 Maintenance Many airports have begun to incorporate air quality policies and procedures into building and facility maintenance. Some airports have also developed initiatives to encourage mainte- nance and janitorial staff to use safe, environmentally friendly cleaning products. Informing and educating airport, concessionaire, and tenant staff on air quality best practices can be effected through meetings, newsletters, or training sessions. Ideally, these would be included in the regular course of business and not through a new forum or activity. 9.2 Airport Air Quality Stakeholder Engagement Forums 9.2.1 Coordination Meetings with Regulators, Airlines, and Tenants During certain airport functions, airports may be required or may choose to hold coordina- tion meetings with local, state, and/or federal regulators. It is important to coordinate with regulators to provide an understanding of the airport’s project or efforts. Regulators may also be able to assist during the planning process to ensure that the airport is in compliance with all appropriate air quality regulations. Meetings with airlines and tenants at the airport should be held on a regular basis to ensure that all operations are conducted according to the airport’s air quality policies and procedures. Most airports hold regular airline/tenant meetings on a monthly basis to provide updates on air- port procedures and policies and to update information on any new airport construction, as well as to allow for comments from all attendees. It is important to ensure that airline and tenant staff have an understanding as to what air quality is and what the air quality goals are for the airport. 9.2.2 Public/Community Meetings and Hearings and Air Quality Published Reports and Successes Often NEPA actions or studies require airports to conduct stakeholder engagement. This will typically include public/community meetings or hearings to provide the community with an opportunity to communicate their opinions on a project. Most airports, depending on the size of the project, will hold multiple stakeholder meetings to ensure that as many individuals or groups of individuals as possible are afforded the opportunity to provide comments. Public/community meetings are typically held at a local school, recreation/community center, library, city hall, or any other appropriate location that can accommodate large groups of people.

36 Airport Air Quality Management 101 Many airports also have a complaint line established to receive complaints from the community. Complaints are most often associated with aircraft noise; however, members of the community may also use this line as a means to communicate complaints regarding air quality. It is important to ensure that airport staff responsible for receiving complaint calls from the community know how to answer questions related to air quality and record the type of complaint received. Involving stakeholders in actions that may involve air quality is important to maintain an airport’s credibility. For many airport plans, a report or document is developed to provide the planning or study results, as well as document the airport’s overall success for that study. These reports should be provided to the public, typically by posting them on the airport’s website or distribution through press releases. In many cases, distributing these reports to the public is required. As one example, Boston-Logan International Airport prepares an annual Environmental Data Report (EDR) in accordance with the Massachusetts Environmental Policy Act. The report provides details on the airport’s yearly activity, plans for the upcoming year, the status of regional transportation, noise abatement, air quality and emissions reduction, water quality, and environmental compliance and management as well as sustainability. The airport’s EDR has provided over 30 years of annual environmental report- ing data. The airport also publishes an Environmental Status and Planning Report every 3 to 5 years. It discusses the same topics as the EDR, but pro- vides more detail on each topic and the successes of the previous 3 years as well as describing anticipated conditions up to 15 years in the future. The reports are made available to the public and any other agencies interested in reviewing the airport’s environmental progress. While these reports are not solely focused on air quality and GHGs, both are discussed in detail, providing significant information to the public about what the airport has accomplished and what it plans to accomplish in the future. Other methods of communicating air quality successes and promoting emission reductions can include hanging posters or mounting displays throughout the airport and developing web postings or press briefings. The communication effort may include signage at various locations around the airport, wraps on airport buses, and advertisements on airport trains and buses that travel into the surrounding community, among other practices. Engaging stakeholders throughout airport activities and functions is essential to providing regulators, airport staff, and the community an opportunity to understand the airport’s activities and projects, as well as provide an opportunity for comments. While certain actions require stakeholder involvement, it is recommended that airports engage stakeholders in planning processes, mitigation efforts, construction activities, maintenance, and reporting. Regular meet- ings should be held with airlines, tenants, and concessionaires to ensure compliance with airport policies and provide updates to airport activities, while meetings with the community and regu- lators may be held on an as-needed basis. 9.2.3 Social Media Strategies Airports have used numerous methods to communicate and provide information to stake- holders. The traditional methods described in this section include newspapers, flyers, postcards, etc.; however, airports have begun to use more dynamic methods of communication and information sharing such as websites and social media. Social media can include websites and applications such as Facebook, Twitter, Google+, LinkedIn, and blogs among others. It is

Stakeholder Engagement Strategies 37 important to understand and determine the most appropriate social media platform for the airport. Some airports may establish one general social media page for the entire airport, while others may have separate pages for large projects or topics (such as air quality). Airport man- agement should decide the best method based on the current activities at the airport. Social media can reduce or eliminate cultural and communication barriers and provide active com- munication to the public and individuals around the world. Active communication with the public through social media allows airport sponsors to provide timely updates and information regarding airport operations, activities, events, and current or future projects. Airports may use social media to share information such as • Airline delays • Weather information • Ground transportation delays • Airport project updates • Topic updates • Hearing notices or public meetings for airport projects • Departmental programs, policies, and initiatives • New airline service • New concessionaires/tenants • Promotions and discounts • Special events While social media is an effective method of communication, it also allows the general public the opportunity to provide comments and feedback on airport activities. It is important to have a dedicated individual to provide quick responses to comments to show that the airport is listen- ing and responsive to the public’s needs and concerns. Airports that are actively addressing air quality issues may choose to incorporate air quality educational flyers, bulletins, website links, updates, and/or videos on social media to help educate the public on the airport’s current air quality efforts and applicable air quality regulations/requirements. Draft Advisory Circular 150/5050-4A, Community Involvement in Airport Planning, provides detailed information on the types of community involvement strategies recommended by the FAA and used by airports today. Additionally, ACRP Synthesis 56: Understanding the Value of Social Media at Airports for Customer Engagement provides valuable information within this same area, but from a customer service perspective. The same principles used for customer service can be applied in stakeholder engagement. 9.2.4 Environmental Justice Consideration of impacts to environmental justice (EJ) communities is an EPA requirement for all NEPA projects. The EPA defines EJ as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” The FAA’s Environmental Desk Reference for Airport Actions provides a summary of applicable special pur- pose laws for quick reference during airport projects or federal actions to ensure all laws and NEPA requirements are met. It is recommended that airport sponsors refer to the FAA’s Environmental Desk Reference for Airport Actions for more information on environmental justice analyses. An environmental justice analysis is conducted during the NEPA process to ensure that all potential federal actions do not cause disproportionate or adverse effects on low-income or minority populations. EJ communities experience historical and current disparities and have an array of challenges—some of which are not directly related to airport actions—that can serve

38 Airport Air Quality Management 101 as barriers to effective stakeholder engagement and improvement of conditions in communi- ties. Many types of airport development projects funded under the AIP may cause impacts to EJ communities. For example, common airport activities or projects that could cause impacts to EJ communities include, but are not limited to • New airport development • Airside/landside expansion projects • Runway/taxiway extensions • Navigational aids (NAVAIDS) relocation • Land acquisition (for expansion or noise mitigation) • Access road improvements • Remote parking facilities • Aircraft operations or arrival/departure procedures changes Vulnerable populations who may be located in close proximity to airports and are exposed to adverse impacts, including air quality, but whose access to the benefits and general services of the airport is very limited, may require more specialized stakeholder engagement efforts. Airport sponsors should make a special effort during airport projects, especially those that may affect an EJ community, to ensure that there is active communication throughout the project’s duration. EJ communities seek proactive, decision-making engagement with the airport to reduce/eliminate disproportionate impacts from airport operations, projects, and planning activities. Airports should reach out to community leaders or other spokespeople early in the project to ensure efficient and effective communication during the EJ analysis. This allows the airport sponsor to actively listen and understand the community’s needs and concerns, while relaying important information regarding airport activities. Airport sponsors should be aware that the air quality concerns of EJ communities may be related to health effects, but may also include noise concerns. These types of concerns occur most often when there are changes to aircraft operations, arrival/departure routes, or construction activity on the airport. It is important to understand the adverse impacts, if any, that could affect an EJ community. If significant adverse impacts may occur and mitigation measures are required, airports should discuss the impacts and potential mitigation efforts with these com- munities to provide educational sessions on airport activities and to receive feedback on proposed mitigation efforts. Essential References for Section 9: Stakeholder Engagement Strategies • Environmental Desk Reference for Airport Actions, FAA Office of Airport Planning and Programming, October 2007 • ACRP Report 85: Developing and Maintaining Support for Your Airport Capacity Project, Transportation Research Board, 2013 • ACRP Synthesis 65: Practices to Develop Effective Stakeholder Relationships at Smaller Airports, Transportation Research Board, 2015 • ACRP Synthesis 56: Understanding the Value of Social Media at Airports for Customer Engagement, Transportation Research Board, 2014 • FAA, Draft Advisory Circular 150/5050-4A, Community Involvement in Airport Planning • FAA Advisory Circular 150/5070, Change 2, Airport Master Planning • Environmental Justice Website, EPA