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Integrating Sustainability Planning and the Environmental Review Process (2019)

Chapter: Chapter 1 - Introduction to the Guidebook

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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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Suggested Citation:"Chapter 1 - Introduction to the Guidebook." National Academies of Sciences, Engineering, and Medicine. 2019. Integrating Sustainability Planning and the Environmental Review Process. Washington, DC: The National Academies Press. doi: 10.17226/25638.
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1 1.1 Guidebook Overview The Guidebook serves as a best practices and recommendations manual for professionals who seek to integrate the environmental review and sustainability planning processes at airports. The goal of the Guidebook is to (1) demonstrate the opportunities in which the sus- tainability planning process and the environmental review process overlap and (2) enhance each other and provide suggestions on how to integrate information and concepts between the two. Integrated approaches for sustainability planning and environmental review can improve the effectiveness of the two processes by streamlining the flow of information; improving internal communication and consistency; and strengthening final plans, documents, and implementation. Airport personnel, airport regulators, aviation industry consultants, and other individuals involved in capital planning, strategic planning, sustainability planning, or environmental planning at airports are encouraged to use and refer to the Guidebook. While the content of this Guidebook is airport-focused and geared toward airport practitioners, many of the ideas are relevant to environmental review and sustainability planning professionals in other fields. There is a lack of guidance for airport practitioners concerned with integrating sustainability considerations into regulatory environmental review processes like the U.S. National Environ- mental Policy Act (NEPA). To fill this information void, the Guidebook presents tools, concepts, and case studies to help airport practitioners integrate sustainability planning with the envi- ronmental analysis required under environmental review regulations. The Guidebook focuses primarily on NEPA for examples, but the information included herein also applies to state environmental review regulations and the Canadian Environmental Assessment Agency’s Canadian Environmental Assessment Act (CEAA) regulations. The contents presented herein will help practitioners produce holistic environmental review and sustainability planning documents that complement each other and also help guide implementation of projects that support airport sustainability goals, without increasing demands on time, financial resources, or effort. Definitions of sustainability vary by industry, but this Guidebook defines sustainability as the ability of organizations or individuals to meet the needs of the present, without compromising the ability of future generations to meet their needs, while also conducting a balanced approach to environmental, economic, and social factors (UN Brundtland Commission 1987). For additional information about the importance and benefits of sustainability planning at airports, refer to Section 1.4, Sustainability at Airports. C H A P T E R 1 Introduction to the Guidebook

2 Integrating Sustainability Planning and the Environmental Review Process The Guidebook is organized into four chapters: Chapter 1: Introduction to the Guidebook, Chapter 2: How to Integrate Sustainability Planning into the Environmental Review Process, Chapter 3: How to Leverage the Environmental Review Process for Sustainability Planning, and Chapter 4: Tools and Resources. 1.2 How to Use the Guidebook This Guidebook is designed to be user-friendly and easy to navigate, providing useful infor- mation for a wide variety of aviation and sustainability professionals. The Guidebook is intended to be used as a reference document. Many Guidebook users will likely already be familiar with sustainability concepts, the environmental review process, and aviation planning. Users may not need to read the Guidebook from beginning to end, but instead might elect to browse sections of the Guidebook relevant to their needs. The Guidebook content was developed to provide useful information for airport managers, project managers, environmental practitioners, and airport planners working at airports of all sizes. Some challenges and initiatives may be unique or more easily implementable at larger or smaller airports; however, the recommended approaches and methodologies for integration were selected for their ability to be scaled to suit airports of all sizes. For example, practitioners at larger airports may find the sections on integrating sustainability principles into their current environmental planning and environmental review work particularly useful. Staff at general aviation airports might find the sections on the efficiencies gained from inte- grating the environmental review process and sustainability planning helpful for long-term planning. Sustainability planners and consultants may benefit from the Guidebook’s description of how to develop sustainability reporting to support the environmental review process or how to best leverage the environmental review process to reinforce sustainability goals and objectives. This Guidebook includes call-out boxes that provide real-world examples of how air- ports have successfully integrated sustainability and environmental reviews and provide ideas and practices for users to adopt when considering how to apply the Guidebook to their own work. 1.3 Why Integrate Sustainability Planning and the Environmental Review Process? The NEPA environmental review process and sustainability planning are typically two dis- tinct efforts. A NEPA environmental review process is typically conducted following specific regulatory requirements and scopes for a particular project or plan, while sustainability planning can be designed to guide an airport’s operations with a broader vision and commitment. Both processes present similar benefits by ultimately helping airports minimize their social, economic, and environmental impacts, whether in general airport operations or through specific projects. Above all, these efforts aim to ensure long-term development in a sustainable manner. While sustainability is currently not required, airport practitioners should think about inte- grating it throughout their environmental review processes to advance sustainability efforts and to ensure that all airport projects reflect a balanced approach to economic opportunity, environmental quality, and social equity. Additionally, an integrated approach to sustainability planning and environmental review can help leverage information and resources, improve the effectiveness of both processes, and enhance the internal airport communication and consis- tency of the planning and development of airport projects. Call-Out Boxes Guidebook users will find these call-out boxes. They provide information and case studies that highlight or complement key discussions.

Introduction to the Guidebook 3 1.3.1 What Does Integrating Sustainability Planning and the Environmental Review Process Mean? Integrating sustainability planning and environmental review means making sure that a project’s elements of and contributions to sustainability are considered and incorporated, where feasible, while that project undergoes the environmental review process. The intent of the Guidebook is to show how airport practitioners can leverage both the environmental review and sustainability planning processes to accomplish sustainability objectives as well as to ensure that such sustainability objectives are integral elements of project environmental reviews. The Guidebook illustrates how airport practitioners can streamline the two processes as follows: • Use information from environmental review documents [e.g., environmental impact state- ments (EISs)] to inform sustainability documents [e.g., sustainability plans, applications for sustainability certifications including Leadership in Energy and Environmental Design (LEED) for green buildings, Parksmart for sustainable parking structure design and operations, or Envision for sustainable infrastructure]; • Apply a unified public communication framework; • Ensure that new plans or documents are internally consistent; • Structure the review or planning process to capitalize on prior work; and • Adopt or modify existing applicable goals or commitments to advance airport sustainability. The Guidebook provides various examples and techniques that airport practitioners can use to enhance the integration of sustainability planning and environmental review processes. 1.3.2 Potential Benefits of Integrating Sustainability Planning and the Environmental Review Process The potential benefits of integrating sustainability planning and the environmental review process vary based on the project under review and the feasibility of incorporating sustain- ability considerations into project design. Typically, master planning or project planning and conceptual design occur before the environmental review process begins. Ideally, sustainability considerations are included in the planning process before initiating the environmental assess- ment. Depending on the scope of the plan or project, integration may have one or more of the following benefits: • Reduced document or plan preparation time; • More effective implementation of project sustainability through documented environmental mitigation commitments; • Greater ability to complete projects with beneficial economic, operational, environmental, and social outcomes; • More opportunities to streamline airport sustainability planning efforts by aligning proposed project mitigation measures with the airport’s sustainability goals and initiatives, where possible; • Improved cross-departmental coordination; • Improved internal consistency for public facing documents; and • More consistent public communication and engagement. During the research phase for the Guidebook, airport staff, FAA personnel, and airport consultants expressed concerns regarding limited resources and personnel capacity. It is important that individuals with these concerns understand the potential benefits and challenges of any new practices associated with this integration before adopting it. The Guidebook is intended to provide examples and practices that are easily implemented or adopted, which focus on leveraging existing information and improving the processes of streamlining docu- ment development and implementation.

4 Integrating Sustainability Planning and the Environmental Review Process Figure 1-1 presents an overview of some of the areas where sustainability planning and the environmental review process can be integrated. 1.3.3 Case Study—Phoenix-Mesa Gateway Airport (IWA) The following case study highlights the integration of an Environmental Assessment (EA) and sustainability considerations from Phoenix-Mesa Gateway Airport. Figure 1-1. Environmental review and sustainability planning alignment. 2017 Environmental Assessment for the Proposed Northeast Area Development Plan and Associated Improvements Project—Phoenix-Mesa Gateway Airport (IWA) Phoenix-Mesa Gateway Airport (IWA) published an EA for the Proposed Northeast Area Development Plan (NADP) and Associated Improvements Project (“the Project”) in January 2017. The Project analyzed the impact of relocating an existing passenger terminal and associated facilities to the northeast area of the airport. The Project also included site preparation for future commercial development (retail and office space) and included lease space to enhance the airport's financial self- sufficiency and overall airport layout. The Mesa Gateway Strategic Development Plan establishes a framework for future environmental, social, and economic sustainability for the city of Mesa. IWA developed the NADP to support the city's vision of economic sustainability and align it with the development plan. IWA also aligned the NADP with the city’s existing sustainability plan to reduce the level of effort needed to incorporate sustainability elements into the NEPA review. The EA documented the airport’s intention to consider incorporating sustainability initiatives, such as solar power, green space, and LEED measures to enhance environmental and financial sustainability of the project and indicated that renewable energy opportunities would be considered during the terminal design process. The EA also noted that IWA would consider adopting sustainable construction practices and materials specifications for the project during the design and procurement phase. This case study illustrates how IWA incorporated sustainability considerations into the NEPA review of a project for which it was too early in the conceptual design process to commit to specific sustainability measures. The EA identified opportunities to develop the airport’s financial sustainability by considering sustainability early in the design process and mirroring the local municipality’s sustainability goals. For more information, see: Proposed Northeast Area Development Plan and Associated Improvement Projects Environmental Assessment, U.S. Department of Transportation, Federal Aviation Administration, Prepared by Ricondo Associates, Inc. January 2017.

Introduction to the Guidebook 5 1.3.4 Organizational Integration at a Strategic Level There are several areas in which aviation practitioners can integrate sustainability into their work. First, aviation practitioners can explore opportunities where sustainability considerations can be integrated into environmental review processes and ways to leverage environmental reviews for sustainability planning. Aviation practitioners also need to investigate the opportu- nities to transform policies and procedures as well as the institutional commitments to sustain- ability at an organizational level. In doing so, airports will be able to advance sustainability in a more consistent, strategic, and effective manner across the airport governance structure, instead of on a project-by-project or department-by-department basis. Airports develop policies and procedures to establish standard practices, so that all airport activities are implemented through consistent processes and with expected outcomes. Airport practitioners seeking to integrate sustainability planning and the environmental review processes should explore opportunities to update or modify relevant airport policies and procedures, ensuring that decision-making and proposed actions include sustainability considerations and that such efforts are implemented in a consistent manner. The process of updating or modifying policies and procedures should involve engaging with staff, especially those responsible for overseeing policies and procedures related to sustainability planning and preparing environ- mental reviews. The process should also gather input on likely challenges and potential oppor- tunities. Through this process, airports can obtain staff buy-in and make appropriate changes for effective implementation. Institutional culture reflects the expectation of “how the process should be done.” It is often influenced by the attitude and priorities of leadership. For effective integration of sustainability planning and environmental review processes, there needs to be a shift or change in practice regarding how airport staff approach planning and implementation efforts. It is essential that airport leadership understand the value created by integrating sustainability planning and the environmental review process and reinforce its commitment by clearly communicating how sustainability considerations need to be embedded throughout airport policies, programs, and procedures. While it may require focused thought and work effort, the realized benefits for such integration will be long term and will help streamline planning efforts. Guidebook users and aviation practitioners seeking to integrate sustainability planning and the environmental review process at a strategic level should take the following actions: • Ensure that there are open communication channels among various departments; • Adopt clear planning strategies and implementation procedures; and • Educate airport staff in different approaches to both sustainability planning and environmental reviews. Refer to Section 1.7, Quick Start Guide, for a checklist of strategic level actions that improve sustainability planning and environmental review integration. 1.4 Sustainability at Airports It is crucial to define the term “sustainability” in the context of airports and in the context of this Guidebook. Definitions of sustainability vary by industry, but typically reflect the Brundtland Commission’s emphasis on the ability of organizations or individuals to meet the needs of the present without compromising the ability of future generations to meet their own needs. While the Guidebook is airport-focused and geared toward airport practitioners, it may also be of use to other practitioners seeking to incorporate environmental, economic, and social factors into the environmental review and sustainability planning processes. The Airports

6 Integrating Sustainability Planning and the Environmental Review Process Council International–North America (ACI–NA) developed a definition of sustainability that considers operational aspects of airports. ACI–NA defines sustainability as a holistic approach to managing an airport so as to ensure integrity of its Economic Vitality, Operational Efficiency, Natural Resource Conservation, and Social Responsibility (EONS) (Figure 1-2). These elements are further defined as follows: Economic Vitality: Economic Performance Operational Efficiency: Well-Managed and High Performing Operations (Engagement and Leadership; Equipment Efficiency; Transportation Access) Natural Resource Conservation: Energy and Climate; Water and Waste; Design and Materials; Natural Resources Social Responsibility: Human Well-Being; Community Relations Within these components of sustainability, there are more detailed elements, which are defined in ACRP Report 119: Prototype Airport Sustainability Rating System—Characteristics, Viability, and Implementation, and on the Sustainable Aviation Guidance Alliance (SAGA) web- site (www.airportsustainability.org). Sustainability planning at airports has become increasingly relevant, because such efforts can help airports minimize the environmental and social impacts of their operations while maximiz- ing the benefits provided to passengers, businesses, and local communities. Public pressure and expectations are also a key driver for airport decision-makers to ensure that positive community relations are maintained. An airport’s sustainability also depends on its ability to stay resilient, which means being able to survive, adapt, and grow even when experiencing unanticipated dis- ruptions. Sustainability planning can frame strategies and solutions through a systems thinking approach to understand an airport’s cross-sectional challenges and opportunities for devel- oping integrated solutions across the airport that provide multiple co-benefits. For instance, Sustainability as an EONS Framework The Airports Council International–North America (ACI–NA) developed a definition of sustainability specific to airports: “Airport Sustainability, in effect is a holistic approach to managing an airport so as to ensure the integrity of the Economic Vitality, Operational Efficiency, Natural Resource Conservation and Social Responsibility (EONS) of the airport.” Figure 1-2. Sustainability as an EONS framework.

Introduction to the Guidebook 7 installing a green roof on a terminal can contribute to keeping the facility cool during hot days, which subsequently helps reduce energy demand for cooling the facility; the green roof can also help reduce stormwater runoff, which then minimizes or prevents pollutants from entering nearby water bodies. In 2009, the FAA established the Airport Sustainability Pilot Program to encourage airports to develop new sustainability plans or modify existing airport master plans to incorporate sus- tainability principles. The FAA has provided grants, guidance, and resources to airports for the development of Sustainability Master Plans, Sustainable Management Plans, or other Airport Sustainability Plans. A Sustainability Master Plan integrates sustainability into an airport’s long- range planning, while an Airport Sustainability Plan is a stand-alone plan for implementation of sustainability initiatives at an airport today. To date, the FAA has sponsored the development of 44 Sustainability Master Plans and Airport Sustainability Plans. It should be noted that many other airports have developed similar plans independently, without FAA funding. To assist in these efforts, the FAA has issued interim documents and reports on sustainability practices. It also provides a list of resources that includes the following: • Interim Guidance for Airport Sustainable Master Plan Pilot Program (FAA 2010), • Report on the Sustainable Master Plan Pilot Program and Lessons Learned (FAA 2012), and • ACRP Synthesis 77: Airport Sustainability Practices (Malick 2016). Although the FAA Sustainability Pilot Program is complete, airports may use Airport Improvement Program (AIP) grants to fund development of environmental reviews and sustainability plans (https://www.faa.gov/airports/aip/overview/). Many airports that participated in the pilot program are embarking on the next stage of sustainability planning: implementation of the plan. Implementation of sustainability plans, programs, and initiatives is effective and successful when airports clearly lay out their sustain- ability goals and targets, participate in robust stakeholder engagement (for buy-in from airport department leaders, employees, local communities, and passengers), regularly track and monitor progress, and update goals and initiatives to ensure they are feasible and practicable. This stage is where integrating sustainability planning and the environmental review process can be highly beneficial, especially to optimize the opportunities for streamlining efforts and to ensure that outcomes from proposed projects align with the airport-wide sustainability goals and objectives. Several factors—including staff capacity, financial resources, and the airport’s overall sustain- ability commitments, goals, and objectives—influence the implementation and effectiveness of sustainability initiatives and programs at airports. Sustainability considerations can be part of airport-wide strategic and programmatic plans, which provide more comprehensive strategic planning efforts, goals, and objectives that apply to all aspects of airport development and operations. Many airports may also choose to develop and implement resource-specific plans, setting goals and objectives for individual sustainability categories that the airport identifies as priorities. Many airports are implementing ad hoc sustainability initiatives, separate from formal sustainability plans and programs. The ad hoc measures can also bolster the environmental review process by providing a framework for project development, implementation, and mitigation. For airports that have not yet developed sustainability goals and objectives, these ad hoc sustainability initiatives can be implemented without setting or meeting specific goals or targets. This approach can be helpful in identifying interim actions before establishing formal goals and targets; however, it should not be a long-term solution for airport sustainability efforts. Figure 1-3 illustrates the different approaches through which airports can infuse and

8 Integrating Sustainability Planning and the Environmental Review Process advance sustainability efforts. Ad hoc efforts are more likely to be prevalent at general aviation airports than at larger, commercial service airports. 1.5 Environmental Review Process at Airports 1.5.1 Environmental Review Overview According to NEPA, environmental review is a regulatory review process during which a federal agency assesses the potential effects of a proposed action before approving the action. Regulations define the types of effects that federal agencies must evaluate and what resources must be evaluated. These resources consist of broad environmental and human resource cate- gories including air quality, water resources, biotic resources, land use, and socioeconomics. The specific nomenclature, definitions, and scope of the resource categories vary by agency and project type, but the resource categories reviewed under an environmental review process generally consist of broad environmental areas. The nomenclature and scope of these cate- gories are typically defined in the regulations and procedures set forth by the federal agency. For example, the specific environmental categories in FAA’s NEPA procedures may vary in name and definition from other federal agencies’ NEPA procedures. An environmental review is most often triggered by a specific, dis- crete project. A programmatic review may also be triggered by an agency’s action to adopt or approve broad, long-term programs or policy decisions. These types of reviews are less common and often require supplemental review of subsequent discrete projects. The environmental review process is typically structured around specific procedural steps that an agency must follow to comply with the regulations. These steps range from the identification of the project purpose and need to identification of project mitigation and monitor- ing. Public input is required throughout the process. As with resource categories, the specific nomenclature and definitions of the steps for a review vary by federal agency and project type, but the review steps generally consist of the following: • Project scoping and development of the project purpose and need, with public input; Figure 1-3. Typical methods through which airports implement sustainability. NEPA’s Purpose It is important to note that the core purpose of the environmental review process is in many ways aligned with the core purpose of sustainability. In fact, language directly in NEPA regulations notes: “Congress, recognizing the profound impact of man’s activity and the critical importance of restoring and maintaining environmental quality to the overall welfare and development of man declares that it is the continuing policy of the federal government to use all practical means and measure in a manner calculated to foster and promote the general welfare, to create and maintain conditions under which man and nature can exist in productive harmony, and fulfill the social, economic and other requirements of present and future generations of Americans.” (Underline added for emphasis) (42 U.S. Code § 4331– Congressional declaration of national environmental policy)

Introduction to the Guidebook 9 • Development of a draft NEPA document, which typically describes action alternatives analysis (including no-action and proposed action), environmental impact analysis, and proposed mitigation; • Publishing the document and providing opportunities for public comment; • Development of a final NEPA document (if required); and • Agency decision based on the NEPA review and public comment. For a detailed description of the environmental review process, please refer to Section 2.1.2, Typical Environmental Review Process. 1.5.2 Environmental Review at Airports Airport projects vary in purpose and scope including airside, terminal, and land side devel- opment. Aside from routine maintenance at airports, examples of projects or actions for which regulations require the preparation of environmental review documents include the following: • Extension or expansion of runways and taxiways; • Expansion, improvement, or reconfiguration of terminals; • Land acquisition using federal funds; • Construction of new facilities that change the Airport Layout Plan (ALP); or • Change of flight procedures. Environmental reviews are discrete and evaluate the potential effects of a specific action or project. Projects that have more straightforward, limited scope of environmental review, such as a Categorical Exclusion (CATEX), are typically prepared by in-house airport environmental staff, given their minimal level of effort. For projects that require more detailed environmental reviews, such as an EA, airport administrators will contract the environmental analysis and document preparation to an aviation or environmental consulting firm that works with airport staff and the FAA to prepare the analyses and document the findings. General aviation airports may use contractors to prepare CATEXs and EAs because of limited availability of airport staff. In the case of more significant environmental impact, where an EIS is required, the lead federal agency will select and direct an independent environmental consultant to prepare the EIS. In the case of the FAA, a memorandum of agreement (MOA) will be put in place to contract services through the airport to prepare environmental documentation. Environmental reviews are generally conducted at the conceptual design phase of a project or action. A federal agency must have sufficient information about the project to develop reasonable alternatives to the action and to adequately assess the potential impacts of these alternatives on the human and natural environment. A federal agency relies on planning studies, baseline technical studies, and the project’s conceptual designs to conduct a thorough review of the potential impacts under the regulations. Federal agencies will typically conduct a review of a project after the project planning phase has been completed, but before the final design phase begins. 1.5.3 Regulatory Requirements The environmental review process at airports is derived from various regulatory drivers that require government agencies to evaluate potential environmental consequences of an action. 1.5.3.1 Council on Environmental Quality In the United States, NEPA (42 USC 4321-4355) established the Council on Environmental Quality (CEQ) to oversee the implementation of NEPA and to provide guidance on procedures

10 Integrating Sustainability Planning and the Environmental Review Process through which federal agencies must evaluate the potential effects of major federal actions on the human and natural environment. CEQ procedures direct federal agencies to develop agency-specific procedures, defining how their projects are reviewed in a manner consistent with NEPA and CEQ procedures to achieve the goals of NEPA. NEPA regulations provide procedures for determining the level of detail required to adequately evaluate the potential effects of various types of actions. Under NEPA, different projects require different levels of review, based on the potential level of impacts. The three typical reviews used across agencies are CATEX, EA, and EIS. It should also be noted that different agencies have their own procedures for determining how a NEPA review is conducted. A CATEX requires a limited review to demonstrate there are no adverse effects, based on a federal agency’s predetermined list of actions that have negligible or no effect; an EA requires more detail than a CATEX and is triggered because of a limited potential for significant impacts; and an EIS requires the highest level of information and detail and is triggered because of the potential for significant impacts. 1.5.3.2 U.S. DOT U.S. DOT regulates transport activities within the United States and oversees multiple federal agencies including the FAA. U.S. DOT has devel- oped procedures for implementing NEPA as defined in CEQ procedures; these procedures specified in U.S. DOT Order 5610.1C apply to airports in the United States (U.S. Department of Transportation 1982, 1985). 1.5.3.3 Federal Aviation Administration The FAA is an agency within the U.S. DOT specifically responsible for the regulation and management of airports in the United States. The FAA is involved in every NEPA review conducted for airport projects. Like other federal agencies, the FAA also established its own regulations and procedures for implementing NEPA. FAA Order 1050.1F—Environmental Impacts: Policies and Procedures. This order serves as the primary guidance document for conducting a review under NEPA. The order provides a clear and concise description of FAA requirements for implementing NEPA and clarifies the requirements with the objective of timely, effective, and efficient environmental reviews. FAA Order 1050.1F is accompanied by FAA Order 5050.4B—National Environmental Policy Act (NEPA) Implementing Instructions for Airport Actions, which provides additional direction on specific aspects of NEPA compliance and review as well as requirements outside of NEPA (known as special purpose laws) (FAA 2015). FAA Order 5050.4B—National Environmental Policy Act (NEPA) Implementing Instructions for Airport Actions. This order provides implementing instructions for FAA Order 1050.1F and review guidance specific to airport actions. An accompanying Environ- ment Desk Reference for Airport Actions provides information on federal environmental laws other than NEPA (FAA 2006). 1.5.3.4 Canadian Environmental Assessment Act In Canada, the Canadian Environmental Assessment Act of 2012 (CEAA) (S.C. 2012, c. 19, s. 52) sets the procedures through which federal agencies must conduct environmental reviews. The Canadian Environmental Assessment Agency is responsible for the CEAA. Similar to U.S. federal agencies, Canadian federal agencies are responsible for setting and implementing regulations and procedures for implementing CEAA. FAA Guidance and Regulation The following provide guidance and regulation for implementing the requirements of NEPA according to FAA procedures and guidelines: • FAA Order 1050.1F • FAA Order 5050.4B • Environmental Desk Reference for Airport Actions

Introduction to the Guidebook 11 The Canadian Environmental Assessment Agency promotes the use of a Strategic Environ- mental Assessment (SEA) tool that contributes to informed decisions in support of sustain- able development by incorporating environmental considerations into the development of public policies and strategic decisions. This approach is described in greater detail in the Canadian Strategic Environmental Assessment case study, and it could have applicability for airports. Many other countries also have national environmental assessment regulations, with relevant implications for airports. 1.6 Key Terminology Table 1-1 contains a list of key terminology for environmental reviews and sustainability planning and provides a definition or description of each term. Key Term Definition or Description Categorical Exclusion FAA Order 1050.1F includes actions that the FAA has found, based on past experience with similar actions, do not normally require an EA or EIS, because they do not individually or cumulatively have a significant effect on the human environment, with the exception of extraordinary circumstances. These actions are defined as CATEXs under the CEQ regulations, and to reduce delay and paperwork, they do not require further review. A CATEX is not an exemption or waiver of NEPA review; it is a level of NEPA review. FAA Order 1050.1F clarifies when and what level of documentation is needed in the application of a CATEX. Environmental Assessment An EA is an environmental review of an action under NEPA that requires moderate documentation and analysis. The purpose of an EA is to determine whether a proposed action has the potential to significantly affect the human environment. An EA is a concise public document that provides sufficient evidence and analysis for determining a Finding of No Significant Impact (FONSI), or whether further environmental review is needed (e.g., through preparation of an EIS). Environmental Impact Statement Under NEPA, the FAA must prepare an EIS for actions significantly affecting the quality of the human environment. An EIS is a detailed written statement when one or more environmental impacts would be significant and mitigation measures cannot reduce the impact(s) below significant levels. Direct, indirect, and cumulative impacts must be considered when determining significance. Environmental Review Environmental review describes a type of federal or state regulation requiring that certain actions (projects or programs) be analyzed to understand the potential environmental consequences of the action; in the United States, NEPA is the federal environmental review regulation, and in Canada, CEAA applies. Lead Agency The lead agency is the federal agency that is responsible for the review findings and the agency considering the action that triggers the environmental review. For example, the FAA is typically the lead agency for airport projects in the United States. Project sponsor or proponent If the federal agency is providing funding to an airport or other agency for a specific action, the airport or other agency receiving the funding will typically be designated as the project sponsor or project proponent. The project sponsor or proponent will work with the lead agency in preparing the environmental review and will typically be considered a co-lead agency. Table 1-1. Key terminology. (continued on next page)

12 Integrating Sustainability Planning and the Environmental Review Process Key Term Definition or Description Public Engagement Public engagement refers to activities related to programs, projects, or initiatives that require public hearings, public meetings, public notices, or other informational publications. Public engagement is required under environmental regulations and commonly used in preparing sustainability plans. Sustainability For airports, the ACI–NA EONS definition is commonly used. EONS defines sustainability as having four aspects: Economic Viability, Operational Efficiency, Natural Resource Conservation, and Social Responsibility. Definitions of sustainability vary by industry, but typically reflect the Brundtland Commission's emphasis on the ability of organizations or individuals to meet the needs of the present without compromising the ability of future generations to meet their own needs. Sustainability Category Sustainability categories refer to the various topics that are described in sustainability plans. These categories are generally defined by the airport staff or project teams preparing the plans. They typically include topics within economic, operational, natural environment, and social aspects. Sustainability Initiative A sustainability initiative is a discrete activity, action, or project focused on improving an aspect of sustainability at the airport; it is not necessarily part of a broader strategic approach and may or may not have come out of a broader sustainability plan advanced by the airport. Sustainability Management Plan (or Sustainability Plan) A Sustainability Management Plan (also known as a Sustainability Plan) is a strategic document that evaluates sustainability at the airport through multiple categories, such as energy, water, air quality, greenhouse gas (GHG) emissions, waste management, and resiliency. It typically includes an airport-wide vision or mission for sustainability, immediate- and long-term goals and targets, initiatives, and an implementation approach for ongoing management and progress tracking. Sustainability Master Plan Different from a typical Airport Master Plan, this document evaluates and integrates sustainability into an airport’s long-term planning efforts. It is a broad planning document that integrates sustainability principles and goals into an airport’s planning strategies for long-range growth and development. Resource-specific plans or programs In addition to a Sustainability Management Plan, an airport can also develop more in-depth, resource-specific plans or programs, targeting the improvement of a specific resource category. Examples include, but are not limited to, energy plans, waste management plans, and water conservation plans. Individual projects or stand-alone initiatives Specific projects or components of projects can be aimed at improving sustainability through one discrete action. Individual projects or initiatives can be stand-alone efforts or can be integrated into a larger project or program. For instance, an airport may have implemented a campaign to promote recycling in airport terminals without an established sustainability plan, program, or specific goals and methods to track progress. Coordinating or participating agencies Coordinating or participating agencies are other agencies or organizations with special interests or jurisdictions, often including tribal organizations, that are not formally designated as cooperating agencies. Resource Category Resource categories refer to the various topics that are discussed in environmental reviews. These are generally defined in the environmental review regulation and specifically defined in the federal agency’s procedures for implementing the federal law. Special Purpose Law Special purpose laws are environmental regulations that focus on one specific resource or topic; for instance, Section 106 of the U.S. Historic Preservation Act requires federal agencies to review, document, and act on specific issues related to cultural and historic resources. Requirements for addressing special purpose laws are laid out in the Environmental Desk Reference for Airport Actions described in Section 1.5.3.3. Table 1-1. (Continued).

Introduction to the Guidebook 13 1.7 Quick Start Guide This Quick Start Guide provides a list of actions that practitioners can use to improve the integration of sustainability planning as well as management and operations and environmental review processes at their airport. Planning : Encourage consideration of sustainability principles in early project planning and conceptual design phases of projects. Ask questions about whether and how the project is contributing to sustainability goals. Incorporate sustainability elements into project plans. : Consult existing sustainability programs, projects, and initiatives for ideas on which sustain- ability features could be incorporated into a proposed project. : Determine whether the project is affected by an existing sustainability program, project, or initiative; affected projects will warrant special recommendations or considerations. Communication : Communicate organization’s sustainability vision and goal (if available). : Ensure there are communication channels among departments or individuals responsible for preparing environmental review documents and sustainability plans. For general aviation airports, focus on including staff at all levels. : Set up regular (monthly, quarterly, or annual) internal and external meetings for communica- tion on upcoming and existing projects and initiatives as well as any commitments or tracking from previously completed projects. : Develop an approach for environmental review documents that provides opportunities for staff to review and comment. Policy : Adopt a policy on sustainability that defines the vision and goals for the airport. : Review existing policies and modify them if necessary, to reflect the airport’s sustainability vision and goals. : Use this policy to shape the direction of both sustainability initiatives and projects under- going environmental review. : Ensure that this policy is made public and identified as part of the airport’s regulations and policy in environmental reviews. Procedures : Adopt a procedure for internal staff and contractors preparing environmental reviews that recommends sustainability programs, projects, and initiatives be identified, considered, and where possible, integrated. : Adopt a procedure for preparing sustainability plans that recommends prior and upcoming environmental reviews be identified and considered when developing sustainability plan goals. Public and Agency Engagement : Identify internal and public stakeholder groups that may provide useful input on sustainability- or project-related considerations. : Coordinate with federal and other oversight agencies, indicating that moving forward, the airport intends to consider sustainability in environmental reviews, and vice versa. : Capitalize on existing outreach contracts for both sustainability- and project-specific external engagement. : Develop consistent messaging for public meetings on environmental review projects and sustainability programs, projects, and initiatives.

14 Integrating Sustainability Planning and the Environmental Review Process 1.8 Key Takeaways The following are key takeaways for integrating sustainability considerations into the envi- ronmental review process and leveraging the environmental review process for sustainability planning: • Explore opportunities to update or modify relevant airport policies and procedures, ensuring that decision-making and proposed actions include sustainability considerations and that such efforts are implemented in a consistent manner (see Section 1.3.4). • Governance and communication are keys to the integration of sustainability planning and the environmental review process (see Section 1.3.4 and Section 1.7). Develop mechanisms or strategies for effective communications such as the following: – Ensure that there are open communication channels among various departments; – Adopt clear planning strategies and implementation procedures around the integration of sustainability planning and environmental review processes; and – Educate airport staff in different approaches to both sustainability planning and environ- mental reviews. Integrating Sustainability Considerations into the Environmental Review Process • Consider sustainability elements as early as during the proposed project’s planning and conceptual design phases. Framing the project benefits through a sustainability lens may help improve buy-in from community stakeholders, potentially making the review process less contentious while maintaining a positive community relationship (see Section 2.2.1). • Conduct a robust internal outreach to other airport staff to ensure that all ongoing sustainability-related initiatives are identified and considered in environmental reviews, even if they are not specifically called out as sustainability projects (see Section 2.3.2). • Continue to follow the step-by-step approach defined in environmental review regulations, which will maintain the legal defensibility of the final document; integrating sustainability concepts into the environmental review does not require deviating from these steps (see Section 2.3.4). Leveraging the Environmental Review Process for Sustainability Planning • Develop a general idea of the airport’s current state of capital projects and recently com- pleted and upcoming projects, which may help the project team better identify environmental review documents that would make good information sources for the plan and structure a sustainability plan in a way that will help guide the implementation of sustainability components on future projects (see Section 3.2.1). • Consider key findings or commitments from previously completed environmental reviews (such as environmental consequences, cumulative impacts, or mitigation measures) to ensure consistency across reporting as well as consistency between project and sustainability plan objectives (see Section 3.2.2). • Understand that sustainability plans and programs should be seen as guiding frameworks for sustainability, whereas specific projects (including those requiring environmental review) are where these frameworks get implemented and where sustainability improvements truly get realized (see Section 3.3.4).

Next: Chapter 2 - How to Integrate Sustainability Planning into the Environmental Review Process »
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Environmental regulations have long required airports to undertake review of many actions associated with planning and development. More recently, airports have embraced sustainability as a means for ensuring the long-term viability and community benefits of their facilities.

The TRB Airport Cooperative Research Program's ACRP Research Report 209: Integrating Sustainability Planning and the Environmental Review Process is designed for airport industry practitioners who are interested in gaining a better understanding of the benefits of integrating environmental review with sustainability planning, and who would like strategies and tools to help them implement this integration.

While there remain challenges to integrating environmental review and sustainability, this report should help guide practitioners on the many opportunities for integration and alignment.

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