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Integrating Sustainability Planning and the Environmental Review Process (2019)

Chapter: Chapter 2 - How to Integrate Sustainability Planning into the Environmental Review Process

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Suggested Citation:"Chapter 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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 2 - How to Integrate Sustainability Planning into the Environmental Review Process." 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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Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

15 This chapter provides information for Guidebook users regarding considerations, practices, and examples of how to integrate sustainability planning into the environmental review process. Information provided in this chapter is intended for the following audiences: • Airport managers, planners, or other airport staff seeking to gain a general understanding of the process and practices for integrating sustainability planning into the environmental review process; • Airport managers, planners, or project staff responsible for preparing environmental reviews and interested in how sustainability considerations may be incorporated into the review process and document; • Airport consultants or government agency staff preparing an environmental review document in coordination with an airport and interested in how sustainability considerations may be incorporated into the review process and document; and • Airport managers, planners, or other airport staff engaged in sustainability work and interested in understanding how sustainability programs, plans, and initiatives may be used and incor- porated within an environmental review. This chapter of the Guidebook is organized to provide the following: • An overview of a typical environmental review process and its stages; • Recommendations for incorporating aspects of sustainability into an environmental review; and • Best practices for addressing common challenges that airports face when considering how to integrate sustainability planning and the environmental review process. Section 2.4, Special Purpose Laws and Other Environmental Regulations, provides some additional information on how the recommendations provided in this chapter may apply to other regulatory permitting and special reviews. 2.1 What Is a Typical Environmental Review? Understanding the environmental review process allows users to make informed decisions about how, when, and whether to implement recommendations presented in the Guidebook. This section provides an overview of a typical federal environmental review process for an airport project. For the sake of providing concrete examples, the Guidebook will typically refer to NEPA regulations, but the federal environmental review process is substantially similar to that of Canada’s CEAA regulations and even many U.S. state environmental review regulations (“mini-NEPAs”). C H A P T E R 2 How to Integrate Sustainability Planning into the Environmental Review Process

16 Integrating Sustainability Planning and the Environmental Review Process 2.1.1 Typical Environmental Review Scope Environmental reviews are generally “triggered” by specific actions or events. In the case of NEPA regulations, this trigger consists of any major federal action affecting the human or natural environment. The term “action” is defined broadly and includes the action of providing funding to airports, municipalities, or other government agencies that would be used for a specific purpose. Federal action also includes a range of other activities: construction and instal- lation, procedural actions, research, rulemaking, certifications, licensing, permits, and plans that require FAA approval. Because environmental reviews are initiated based on a trigger or exceedance of a specific threshold, the majority of reviews are focused on evaluating the potential impacts of specific projects with a defined time frame and defined scope of action. While less common, “programmatic” reviews may also require additional environmental review for discrete projects included therein. Under NEPA, environmental reviews typically follow a structured format and are derived from a procedure-based regulation. Therefore, compliance with the regulations is measured by whether or not agencies and airports conducting the review take the appropriate steps and follow the correct process (see Table 2-1). Compliance is not measured by the outcome or find- ings of the environmental review. NEPA is also the umbrella under which federal agencies must demonstrate compliance with special purpose laws such as Section 4(f) of the U.S. DOT Act of 1966 (Pub. L. 89-670, 80 Stat. 931), now codified at 23 U.S.C. § 138 and 49 U.S.C. § 303, and Section 106 of the Historic Preservation Act. Many projects under NEPA review will likely require a CATEX. Before preparing a CATEX, the project sponsor must evaluate any potential extraordinary circumstances of the proposed project including impacts to national marine sanctuaries and wilderness areas. Extraordinary circumstances preclude the use of a CATEX and merit a higher level of NEPA review. Projects evaluated as a CATEX are relatively small in scope with limited environmental impacts. 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, in the United States, the FAA is typically the lead agency for airport projects, in cooperation with the project sponsor. In Chapter 2 of FAA Order 5050.4B, the Office of Airports (ARP) may categorically exclude the action or require the airport sponsor to prepare an EA under FAA oversight. If it is determined that the action will require preparation of an EIS, the FAA will either prepare an EIS in-house (utilizing agency personnel and resources) or select a contractor to prepare the EIS. "Third party contracting" refers to the preparation of an EIS by a contractor/consultant selected by the FAA; however, this may be paid for by an airport sponsor. The contractor is responsible to the FAA for preparing an EIS that meets the requirements of NEPA, NEPA regulations, FAA's NEPA procedures, and all other appropriate federal, state, and local laws. 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 to prepare the environmental review documentation. Cooperating Agency The cooperating agency is a federal agency or tribe with particular expertise related to environmental resources or with legal jurisdiction over a resource or activity related to a federal action. Per a lead agency’s request, a cooperating agency assists the lead agency in the preparation of the environmental review document. Coordinating or participating agencies Coordinating or participating agencies are other agencies or organizations with special interest or jurisdictions, often including tribal organizations. Table 2-1. Defined roles of key participants in a NEPA environmental review.

How to Integrate Sustainability Planning into the Environmental Review Process 17 However, a CATEX still requires review of potential impacts to relevant environmental resource areas. Some special purpose laws encompassed in a CATEX require public engagement or involvement. Projects with more complexity in both scope and impact are likely to require an EA or EIS. For more information about these distinctions, please refer to Section 1.5.3, Regulatory Requirements. In addition to these defined roles, the environmental review process typically has a public engagement component. As an option, public involvement for an EA varies based on the pro- posed action and the potential impacts. For an EIS, the lead agency is required to engage the public in a public scoping process through which the proposed project’s objectives are presented. During this process, public and agency feedback is gathered about potential concerns, resources and aspects to be studied, and a range of reasonable alternatives. After the preliminary impact analysis is completed, the lead agency will present the findings, followed by a required public comment period during which the findings are made available for public comment. Depending on the level of detail that is required for the review, there may be one or more iterations of public comment and document revision(s) before a final determination is made. 2.1.2 Typical Environmental Review Process Each of the steps shown in the typical NEPA environmental review process for EAs and EISs is described herein. Figure 2-1 outlines the general framework for a typical review process. Identify Project Concept. The first step in a NEPA environmental review process is for the project proponent to develop a preliminary definition of the project. Ideally, sustainability considerations are incorporated into the planning and concept design phase of the project developed by the project proponent. The initial project concept is considered a starting point for the environmental review. The level of environmental review required will depend on the project’s or action’s anticipated impacts. The project’s preferred alternative may ultimately change during the environmental review process. A preliminary purpose and need statement is typically developed at this time. Identify Project Concept Determine the Level of Review Evaluate Potential Impacts and Access Environmental Consequences Facilitate Public Scoping and Agency Engagement Finalize Project Purpose and Need Identify Project Alternatives and Screening Criteria Identify Preferred Alternative and Proposed Mitigation Measures Present Findings for Public and Agency Comment Respond to Comments, Revise Evaluation, and Issue Determination Characterize the Affected Environment Figure 2-1. Typical environmental review process.

18 Integrating Sustainability Planning and the Environmental Review Process Determine the Level of Review. The lead agency will determine the level of environmental review required based on anticipated environmental consequences and applicable environ- mental regulations. Under NEPA, there are three levels of environmental review: CATEX (lowest level of analysis), EA (detailed analysis), and EIS (highly detailed analysis). The lead agency considers the environmental regulations and procedures, the comments received during scoping, and the anticipated or expected significance of environmental impacts to determine the scope of the environmental review. The lead federal agency would prepare the EIS, whereas the lead agency for an EA or CATEX would be the project proponent. Facilitate Public Scoping and Agency Engagement. Environmental regulations vary in whether a scoping hearing, scoping meeting, scoping notice, or any scoping event at all is required. For larger or more significant actions (e.g., actions that would require an EIS or actions subject to an EIS or EA and which could include public opposition or controversy), the lead agency will conduct scoping of the project during which the preliminary project is made available for public and agency comment. The lead agency may also initiate consultation with other agencies that could be affected by the project or with jurisdiction over an element of the project. The scoping process allows the lead agency to identify critical issues of concern that should be evaluated during the environmental review and potentially consider additional alter- natives. It also provides an opportunity to refine the proposed action and the project purpose and need. Finalize Project Purpose and Need. The purpose and need statement describes the core reasons the federal agency is undertaking the action. The statement typically demonstrates an existing problem and a proposed resolution to the problem; it is important to note that the purpose and need statement is not tied to any particular project alternative and is a general problem statement. Identify Project Alternatives and Screening Criteria. The lead agency will identify all reasonable alternatives that would satisfy the project purpose and need. This is the core of the environmental review process. The lead agency outlines the reasoning and justification for deciding to pursue the preferred alternative. This section also includes an alternative that defines the assumed conditions, if the lead agency takes no action. Under NEPA, this is typically referred to as the “No Action” alternative. Characterize the Affected Environment. Characterizing the existing conditions in the project area is a critical step in the environmental review process; it provides the context in which the proposed project is occurring. The existing conditions section of the environmental review provides a snapshot of the status of various environmental resources. Under FAA’s NEPA guidance, there are 14 specific environmental resource categories that must be assessed. These categories include the following: • Air quality • Biological resources (including fish, wildlife, and plants) • Climate • Coastal resources • U.S. DOT Act, Section 4(f) • Farmlands • Hazardous materials, solid waste, and pollution prevention • Historical, architectural, archeological, and cultural resources • Land use • Natural resources and energy supply • Noise and noise-compatible land use

How to Integrate Sustainability Planning into the Environmental Review Process 19 • Socioeconomics, environmental justice, and children’s environmental health and safety risks • Visual effects (including light emissions) • Water resources (including wetlands, floodplains, surface waters, groundwater, and wild and scenic rivers) Evaluate Potential Impacts and Assess Environmental Consequences. The lead agency will identify potential impacts to each resource category for each of the identified alternatives. This section is typically the largest portion of the environmental review document and involves the most technical analysis. Potential impacts of each alternative (including the No Action alter- native) to each resource are evaluated by comparing the potential environmental conditions against the future No Action alternative. A key element of this step is providing decision-makers with enough information to identify a preferred alternative. Identify Preferred Alternative and Proposed Mitigation Measures. The lead agency will identify proposed measures to mitigate any significant adverse effects identified for each of the resource categories. Where necessary, these measures will be developed in coordination with other cooperating agencies or other entities participating in the process. It is important to note that these mitigation measures are not commitments until the environmental review document is finalized, and the determination is issued. The determination formally defines the proposed mitigation measures for projects, typically a FONSI for projects requiring a CATEX or EA and a Record of Decision (ROD) for projects requiring an EIS. An EA may receive a FONSI/ROD, if mitigation is warranted, but there are no significant impacts once mitigation is implemented. For some commitments, additional actions may be required to formalize the mitigation measures, such as adopting a MOA or memorandum of understanding (MOU) with a resource agency or external party. Present Findings for Public and Agency Comment. Public engagement is an important element of the EA and EIS environmental review process. After a draft of the document is prepared, the lead agency provides public notice that the document is available for public review. Depending on the action and the lead agency’s procedures, a public hearing or a public meeting will be held. The lead agency will gather and record public and agency verbal and written comments. This is a foundational principle in the environmental review process, because it provides for public disclosure and transparency in the methods used for analysis and potential consequences. Respond to Comments, Revise Evaluation, and Issue Determination. The lead agency will receive and catalog comments and provide public responses to comments received. Where necessary, the agency will adjust or revise the environmental evaluation in response to any public or agency comment. This process provides structure for public engagement and agency coordination. The lead agency will then issue a final document and an environmental deter- mination. On occasion, additional “supplemental” analyses or “re-evaluations” may be required depending on the adequacy of the draft environmental document, the scope of the review, and the length of time that has elapsed between the determination and the project start. This process is not required for a CATEX under NEPA. 2.2 Integrating Sustainability Planning into the Environmental Review Process This section provides best practices and recommendations through which Guidebook users may incorporate sustainability considerations into an environmental review process and prepare an environmental review document. The Guidebook typically uses NEPA as the representative

20 Integrating Sustainability Planning and the Environmental Review Process environmental review regulation, but the recommendations and processes described are broadly applicable to other environmental review regulations at the state level and internationally in many cases. 2.2.1 Integrating Sustainability Planning During the Environmental Review Process Effective integration of sustainability considerations in an environmental review process largely centers around internal and external communication. It is critical that project teams undertaking an environmental review open internal communication channels to identify existing and planned sustainability programs, projects, and initiatives at the airport. It is also beneficial to communicate internally before engaging with external parties and agencies to ensure consistent project messaging across multiple stakeholder groups and to maintain existing working relationships. 2.2.1.1 During Project Development and Conceptual Planning Ideally, the project proponent will consider sustainability elements as part of the project definition, planning, and conceptual design. There are many sources of guidance for how this process can occur including ACRP publications and materials provided by sustainability rating systems administered by the U.S. Green Building Council for buildings and parking garages, or by the Institute for Sustainable Infrastructure for runways, roads utilities, and other infra- structure projects. Key questions to ask as the need for environment review is established and the level of review is determined include the following: • Does the project meet a sustainability goal set by the airport? • Is the purpose of the project to make the airport more sustainable? • Does the proposed project include sustainable elements such as energy or water conservation measures, renewable energy infrastructure, or use of renewable construction materials? The earlier these questions are asked, the more likely sustainability considerations can be reflected in the environmental review process. 2.2.1.2 During Project Scoping As part of project scoping, the project team should consider the proposed project at a high level within the context of sustainability. Project scoping is the process used to define the project goals, objectives, and the primary problem(s) that the project seeks to address. Because this stage creates the foundation of the project, it is an important opportunity to define the degree to which sustainability principles factor in the project. Aviation practitioners working or involved in project scoping should ask the following questions: • Does the airport have a sustainability mission, vision statement, or policy? Does the proposed project goal align with this document? Does it conflict with this document? • What does the airport already have in place as far as any sustainability-related plans, goals programs, or initiatives? • In what way(s) might the project contribute to the airport’s overall sustainability? • What are the potential implications (costs, logistics, etc.) of the project with regard to sustainability considerations? 2.2.1.3 Public Stakeholder Engagement Stakeholder groups and community task forces can serve beneficial roles in providing input for both sustainability planning and environmental review processes. Public engagement is a

How to Integrate Sustainability Planning into the Environmental Review Process 21 requirement for certain projects’ environmental reviews and a best practice for most planning efforts. Additionally, framing the project benefits through a sustainability lens will improve buy-in from community stakeholders, potentially making the review process less contentious while maintaining a positive community relationship. A project team undertaking an environmental review should coordinate with airport staff familiar with the preparation and administration of any sustainability programs or plans before conducting public outreach for the project. This coordination enables the project team to determine if there is an existing public body (e.g., a task force) that could be consulted as part of a public engagement effort for the environmental review. This step also ensures that the project purpose is not in conflict with any goals or vision statements developed through these other plans. This early internal coordination will also help keep public messaging consistent, ensure that members of the public are informed, and may reduce the amount of time needed to identify other public external stakeholder groups. In addition, individuals already invested in a prior or ongoing stakeholder group would likely be informed regarding the airport’s general activities and therefore be more likely to provide meaningful input. 2.2.1.4 After Project Approval In addition to incorporating sustainability elements into project design, considering addi- tional sustainability measures as part of the project’s proposed mitigation efforts, where appro- priate, provides an effective mechanism to ensure that the project contributes to the airport’s overall sustainability efforts. It is important that a project team undertaking an environmental review carefully consider the recommended mitigation measures and proposed tracking and reporting strategies to ensure that they accurately capture the sustainability aspects of the project. Not only will this consideration ensure effective implementation, it may also enable the project to earn recognized sustainability-rating certifications, such as LEED for green buildings, Envision for sustainable infrastructure, or Parksmart for sustainable parking structure design and operations. 2.2.2 Integrating Sustainability Planning in an Environmental Review Document This section provides recommendations on how airport practitioners can integrate sustain- ability considerations throughout the environmental review process. Guidebook users may choose to adopt or implement any of the recommendations provided under each section of a typical environmental review document as appropriate for the specific project. Figure 2-2 displays the typical sections included in an environmental review document for NEPA. In the following pages, inclusion of sustainability considerations in each of the document sections is demonstrated using a hypothetical example of proposed construction of a new airport parking garage. 2.2.2.1 Project Description As part of the Project Description, there may be opportunities to introduce sustainability such as the following: • Including existing airport sustainability efforts as part of the background information about the airport; and • Highlighting specific sustainability elements that are considered or incorporated into the proposed project.

22 Integrating Sustainability Planning and the Environmental Review Process This is the first opportunity for the project team to introduce relevant sustainability com- ponents of the proposed project. Using the EONS framework, the project team should take a holistic approach to examining the proposed project, discussing not only the project’s environ- mental factors, but also its potential economic, operational, and social implications and its benefits. For instance, an airport project may initially be proposed with a goal of improving the airport’s economic or operational conditions, without considering the potential social and environmental implications as outcomes of the project. These additional considerations, when included early in the project description, provide an opportunity to better integrate sustainability elements into the project planning and design. Not all projects may be driven by sustainability principles; however, any project can be enhanced by incorporating sustainability considerations through thoughtful planning. Hypothetical Example Proposed Project: Construction of a New Airport Parking Garage An airport is facing a parking shortage and proposes to construct a new parking facility. The proj- ect has multiple elements, such as increasing total parking space capacity, relocating employee parking, and consolidating the shuttle bus system serving the new parking garage. The goals of the project include taking circulating cars off the airport roadway system, improving revenue, and providing more passenger parking. The proposed parking facility will target those air passengers who are currently using the drop-off/pick-up mode to access the airport, or in the future would do so because of insufficient parking at the airport. The proposed parking facility will also provide parking for the portion of the anticipated additional air passengers who will seek to park at the airport. Using this example, as part of the Project Description section of the NEPA document, the project proponent should include a description of overall sustainability efforts by first considering the following general questions: • Does the airport have a sustainability mission? • Has the airport established a sustainability management plan? What are the airport’s sustainability goals? Figure 2-2. Outline of typical environmental review document.

How to Integrate Sustainability Planning into the Environmental Review Process 23 • If the airport does not have a formal plan or program, pose the following questions: – In what ways does the airport contribute to the local or regional economy? – What are some major efforts the airport has undertaken to monitor and minimize the envi- ronmental effects of its operation? – What role does the airport play in the local communities? – What are some of the initiatives through which the airport supports its employees’ professional development and well-being? Consideration of these questions helps frame the proposed project within a broader context of airport sustainability and an understanding of if and how this project might contribute to overall sustainability. When providing a specific discussion about the proposed project, sustainability elements can be highlighted, such as the following: • Economic Viability: Will the project provide economic benefits for the airport (e.g., increased revenues, decreased costs)? • Operational Efficiency: Will the project pursue and achieve any of the available sustainability rating systems (e.g., Parksmart, LEED, Envision)? • Natural Resource Conservation: What are some sustainability features of the project design elements (e.g., recycled and regional construction materials, on-site renewable energy systems, LED lights for interior and exterior lighting, charging stations for electric vehicles, etc.)? • Social Responsibility: Will the project incorporate social considerations, such as hiring local workers or contracting with women- and minority-owned businesses? 2.2.2.2 Project Purpose and Need Statement The purpose and need statement addresses two underlying questions: 1. What is the issue (i.e., need for the proposed project)? 2. How does the proponent propose to address the issue (i.e., project purpose)? This section also helps frame the selection of considered alternatives and justifications for the proposed project. For some projects, resiliency or sustainability can be the main project purpose. However, most airport projects generally do not have sustainability as a primary driver for project initiation. Nevertheless, sustainability principles can still help define secondary goals of the project and can shape the evaluation criteria used to analyze alternatives that are developed to address the purpose and need. These are described in more detail in the following sections. At the same time, if the project team decides that the need for the proposed project is to address identified deficiencies that subsequently help meet the airport’s sustainability goals, then sustainability could be stated as the secondary goal of the proposed project. Hypothetical Example Using the same example of the proposed parking garage, in the purpose and need statement, the need for the project would be the lack of capacity to efficiently accommodate existing and future passenger vehicular traffic volumes. The purpose of the proposed project is to provide adequate parking, improve efficiency of airport traffic circulation, minimize environmental effects associ- ated with airport traffic, and improve passenger service and convenience. While improving airport sustainability is not a primary driver of the parking garage project need, sustainability principles could be incorporated as project goals to shape the alternatives development process and advance design details. 2.2.2.3 Alternatives Analysis The Alternatives Analysis section identifies the proposed alternatives for the project (includ- ing a No Action alternative) and describes each of the alternatives. The analysis presents an

24 Integrating Sustainability Planning and the Environmental Review Process opportunity for the project team to introduce sustainable design elements into the proposed project. Additionally, the evaluation criteria for screening these action alternatives are critical, because they can help differentiate the considered alternatives and justify the proposed action. Therefore, the project team should consider adding sustainability-focused screening criteria that reflect the airport’s overall sustainability goals. Evaluation criteria for action alternatives typically include design efficiency, cost, constructability, phasing, aesthetics, and feasibility. The project team should make sure to adopt and modify the alternatives screening criteria so that they touch on all aspects of airport sustainability according to the EONS framework includ- ing environmental, operational, economic, and social factors. The project team can also adjust the scoring weight for sustainability-specific criteria as it sees fit, to accommodate the airport’s needs, priorities, and level of commitment to sustainability. For airports that have a sustainability program or goals in place, adopting screening criteria that are consistent with these established programs and goals will help maximize the benefits of integrating the environmental review and ongoing airport sustainability planning pro- cesses. For airports that have not yet established a sustainability mission or goals, developing sustainability-related screening criteria can still be useful by providing the project team with a better understanding of potential positive or negative environmental, social, and economic impacts of the proposed project. Hypothetical Example In the proposed parking facility project example, the project team would develop alternatives to address the parking deficiency. These alternatives could include a new parking garage, alternative parking rules or fee structure, improved transit access, or others. The range of alternatives, as defined by the project purpose and need, can also incorporate sustainability considerations. Examples of sustainable goal categories could include energy and GHG emissions; water conservation; and community, passenger, and employee engagement. The sustainability-related evaluation criteria should address the following key question: To what extent does the alternative contribute to meeting the airport’s sustainability goal(s)? The airport can also establish a more comprehensive set of sustainability-related evaluation criteria for con- sidered action alternatives using a series of quantitative and qualitative yes/no questions, such as the following: • Energy and GHG Emissions: – Does the alternative reduce operational energy use? – Does the alternative reduce overall air pollution and GHG emissions? • Water Conservation: – Does the alternative allow for water conservation measures? – Does the alternative enable water capture or reuse systems? • Community, Passenger, and Employee Engagement: – Does the alternative minimize employee and/or passenger travel time? – Does the alternative further achieve the airport’s customer satisfaction goals? Even if the airport does not have formal sustainability goals, these types of questions can be consid- ered in the alternatives assessment. 2.2.2.4 Affected Environment The Affected Environment section assesses the existing conditions for applicable resources within the proposed project area. In this section, descriptions of existing and applicable sustainability programs, projects, or initiatives should also be included, if available. In addition, because the intent of this section is to accurately report existing baseline con- ditions, benefits from existing sustainability programs should be included in the baseline information.

How to Integrate Sustainability Planning into the Environmental Review Process 25 All FAA-defined environmental resource categories must be addressed in the affected envi- ronment documentation. If environmental resources are not impacted, this too must be stated. For, example, if a project is not in a coastal zone, then coastal resources would not be evaluated, and a statement to that effect would be included in the documentation. When identifying the applicable resource categories for a proposed project area, the proponent should also consider collecting baseline data and assessing these resources’ existing conditions from a sustainability lens. Doing so will help inform the sustainability-related discussion around the direct, indirect, and temporary impacts to these resource categories in the environmental consequences evaluation. For instance, when determining baseline conditions for quantifiable information, such as electricity use, the affected environment documentation should report the existing kilowatt hour (kWh) usage as the baseline consumption and note any existing sustainability projects or initiatives that are current drivers of that energy performance. There is an opportunity to coordinate or leverage how baseline data is collected for sustain- ability planning efforts or existing sustainability programs, to the extent that the data can also inform the affected environment assessment of an environmental review document. Table 2-2 Table 2-2. FAA’s NEPA categories and relationship to sustainability categories. NEPA Environmental Review Category Sustainability Category1 NEPA and Sustainability Synergies Air Quality Climate Energy and Climate Human Well-Being Air Quality Improvement • Minimizing air pollution emissions • Reducing GHG emissions/energy use • Resiliency to changing climate conditions Biological Resources Coastal Resources Historic, Architectural, and Cultural Resources Section 4(f) Resources Natural Resources Human Well-Being Resiliency • Protecting natural resources (habitat, species, etc.) • Minimizing or avoiding environmental impacts (to coastal resources—habitat, species, etc.) • Efficient land uses that minimize environmental impacts and promote social well-being and economic development • Protection of historically and culturally significant landmarks • Protection of green and open space Ground Transportation Ground Transportation Human Well-Being Air Quality Improvement • Efficient and equitable transportation modes that minimize air pollution and GHGs Hazardous Materials, Solid Waste, Pollution Prevention Water and Waste Management Design and Materials Natural Resources • Reduction of waste • Diversion of materials from landfills • Productive reuse of materials • Sustainable, efficient procurement • Safe handling of materials Natural Resources and Energy Climate and Energy Natural Resources • Improved energy performance and operational efficiency Noise and Noise-Compatible Human Well-Being • Minimizing noise impacts Noise Abatement Land Use Socioeconomics (Environmental Justice and Children’s Health and Safety) Economic Performance Human Well-being Passenger Experience Community • Promotion of employee health and well-being • Equity and community health • Minimization or avoided negative impacts on surrounding communities Visual Effects Design and Materials Passenger Experience • Sustainable and resource-efficient design and materials Water Resources Water and Waste Natural Resources • Pollution prevention of water sources • Water conservation 1Sustainability categories as defined by SAGA (www.airportsustainability.org).

26 Integrating Sustainability Planning and the Environmental Review Process shows the alignment of NEPA environmental resource categories and sustainability resource categories, as defined by SAGA (http://www.airportsustainability.org) and identifies data points and objectives that could be applicable for sustainability planning for the environmental review process. Hypothetical Example As the project team begins gathering information and data on the existing conditions of the affected environment resources within the proposed parking project’s study area, the project team also looks into reviewing the airport’s latest sustainability-related plans (such as the Sustainable Management Plan or Sustainability Master Plan), any resource-specific plans (such as the Water Conservation Plan or Energy Management Plan), or any stand-alone sustainability-related initiatives or policies (such as recycling policy, sustainable construction policy, or sustainable design standards and guidelines). This exercise allows the project team to note the baseline data as well as specific airport sustainability goals associated with identified resource categories. The project team will need to refer to and discuss the potential impacts to these resources by the proposed project in the Environmental Consequences section, for example: • Under the Air Quality category, in addition to including any existing local, state, and federal air quality standards (such as the Clean Air Act, National Ambient Air Quality Standards, or state-specific air quality regulations) with which the airport and the project study area must comply, the project team also discusses existing airport policies or initiatives aimed at reducing and minimizing emissions associated with airport activities, especially those associated with existing parking facilities. The project team learns that the airport has been conducting air quality-related inventories, such as for air pollutant emissions; therefore, the team includes a discussion of the emissions trend to date as part of the resource category’s existing conditions. • Under the Natural Resources category, the project team may find it helpful to draw from the baseline data of specific sustainability goals and targets, such as energy consumption, water consumption, or waste generation. Airports that do not have specific sustainability goals and targets but adhere to goals and targets established by their municipalities (or other jurisdictions where the airport is located) may include those baseline data instead. • Under the Hazardous Materials, Solid Waste, and Pollution Prevention category, the airport has been implementing a green construction policy. In noting this policy under existing conditions, the project team is able to analyze under Environmental Consequences, the potential impacts related to construction activities (as well as air quality, noise, GHG emissions from equipment, etc.) under the assumption that the proposed project would comply with this policy. 2.2.2.5 Environmental Consequences and Cumulative Impacts The Environmental Consequences section documents the potential impacts from the pro- posed project on each applicable resource category identified under the Affected Environment section. Impacts analyses must include the No Action and the proposed alternatives for the project. The NEPA document should include discussion of the potential impacts within the framework of existing airport sustainability plans and goals, and of sustainability resource categories as described in Table 2-2. Airports that have established a sustainability program or sustainability goals typically have also identified sustainability resource areas (e.g., energy, water, waste, GHGs) and asso- ciated key performance indicators (KPIs) (e.g., energy consumption per square foot, annual water consumption per passenger, GHG emission reduction per passenger). It is important that this discussion consider the potential impacts of the proposed project to these sustain- ability resources and their KPIs. For airports that have yet to establish a formal sustain- ability program or set specific sustainability goals, the project team should still consider the potential impacts of the proposed project on key sustainability resource areas as described in Table 2-2.

How to Integrate Sustainability Planning into the Environmental Review Process 27 Hypothetical Example For the proposed parking facility project example, to make sure that the proposed action’s direct, indirect, temporary construction-related, and cumulative impacts are discussed with the airport’s sustainability goals and targets incorporated, the project proponent should consider the following: • What are the sustainability goals and key performance indicators considered in the existing conditions assessment? – For example, what are the baseline and anticipated impacts related to total energy consumption, GHG emissions, waste minimization, air pollutant emissions reduction, and natural resources restoration? This type of inquiry ties directly into the NEPA requirement for assessing impacts to climate and air quality. • How would existing sustainability initiatives, goals, and targets affect the action alternative’s potential impacts on the identified resource categories under the Affected Environment section? – For example, the project team can explain that because of an airport policy to utilize sustainable design guidelines, the project would be designed to standards that improve energy performance during the life of a typical project. (These standards could also be characterized as mitigation measures incorporated into the project to minimize adverse effects.) • How would the action alternative positively or negatively impact the airport’s overall sustainability goals and targets? – For example, as the airport aims to reduce GHG emissions by 80% by 2050, the project team will need to discuss how consolidating the shuttle bus system would contribute to reducing GHG emissions by reducing the number of trips. Or, as with the goal of energy reduction, the project team will need to discuss how the proposed new facility might result in changes to overall energy consumption at the airport. 2.2.2.6 Proposed Mitigation The Mitigation section of an environmental review is intended to provide information on how the potential impacts of the project may be mitigated, minimized, or reduced. Proposed mitigation goals provide an opportunity for documenting and ensuring that mitigation measures that are also sustainability measures are implemented. Hypothetical Example The project team concludes that the proposed parking facility project may have some negative impacts such as increased energy demand associated with building energy use and temporary increased noise during construction activities. In developing the proposed mitigation measures, the project team also takes into consideration the opportunity to improve airport sustainability wherever possible, ensuring that the proposed mitigation measures also align with the airport’s overall sustainability mission and goals. An example follows: • Proposed mitigation measures to reduce energy demand of the proposed parking facility – Install energy-efficient interior and exterior lighting. – Incorporate occupancy sensors. – Consider installing on-site renewable energy systems to supply a certain percentage of the parking facility’s power need. • Proposed mitigation measures to minimize inconvenience for employees – Offer dedicated shuttle bus service for transporting airport employees directly between the parking facility and their offices or workstations. – Consider making these shuttle buses alternative fuel vehicles. 2.2.3 Case Studies—San Francisco International Airport, Philadelphia International Airport, and Boston Logan International Airport The following case studies demonstrate how different airports in the United States have integrated sustainability planning into the environmental review process and documentation.

28 Integrating Sustainability Planning and the Environmental Review Process 2015 San Francisco International Airport (SFO) Administrative Facilities—FEIR Addendum SFO released an addendum to its Airport Master Plan’s Final Environmental Impact Report (FEIR) under the California Environmental Quality Act (CEQA), which specifically evaluated a modified Master Plan, including additional sustainability features. CEQA is the state environmental review process, similar to the federal NEPA process; therefore, lessons can be drawn from this case study, and they apply to projects subject to NEPA environmental review. The original Airport Master Plan and FEIR analysis included separate administration facilities at the International Terminal Building (ITB) and on a surface parking lot. The revised plans for the administration facilities included a 7.3- acre portion of an adjacent plot to be developed with three office buildings, two parking garages, and a new pedestrian connector to an existing AirTrain station. The administration facilities project would be designed and constructed to Leadership in Energy and Environmental Design (LEED) Gold standards, consistent with the city of San Francisco’s Green Building Code. Sustainable outdoor features were also included in the proposed projects. These features included “white noise,” or natural noise mitigation features such as tilted landforms and green walls with dense vegetation, to reduce noise from an adjacent major roadway (US 101). Landscaping was limited to vegetation that discourages wildlife and birds from foraging at the administration facilities. SFO recognized the need to include specific sustainability elements in the Master Plan to adequately integrate sustainability into the CEQA review. The airport prepared an addendum to evaluate specific sustainability elements, providing a discussion of green building features (as part of the project description) and detailing the project’s approach to meeting the city's Green Building Code and LEED Gold requirements. SFO’s addendum to the FEIR shows how sustainability features need to be built into the project design before the project undergoes environmental review. The addendum demonstrates successful incorporation of sustainability into an airport project design and thereby into the CEQA environmental review. More details on this case study can be found on the following website: http://sfmea.sfplanning.org/86.638E_Add2.pdf. Philadelphia International Airport (PHL) Capacity Enhancement Project EIS and Stewardship Plan In December 2010, the FAA issued a ROD on the Capacity Enhancement Program’s EIS at PHL. The EIS was prepared to evaluate the potential effects associated with airport capacity improvements to accommodate current and future aviation demand during all weather conditions. The EIS evaluated multiple alternatives intended to increase Pennsylvania Department of Environmental Protection, as cooperating agencies. The EIS resulted in a number of mitigation commitments related to noise, land use, surface transportation, a ir quality, wetlands and waterways, water quality, biotic communities, archaeological resources, and hazardous materials and soils. To effectively implement and track some of these commitments, PHL and the FAA agreed to use the airport’s Environmental Stewardship Plan as a vehicle for implementation and monitoring. The first Environmental Stewardship Plan was released in 2008, prior to the EIS, but subsequent updates of the plan included initiatives specifically tied to the mitigation commitments in the Capacity Enhancement Program EIS. This enabled PHL to streamline the mitigation commitment implementation and monitoring and tied the NEPA commitments to other ongoing sustainability initiatives at the airport. More details on this case study can be found on the following website: http://www.phl-cep-eis.com/. capacity and involved the U.S. Army Corps of Engineers, the U.S. Environmental Protection Agency, and the

How to Integrate Sustainability Planning into the Environmental Review Process 29 Boston Logan International Airport (BOS) Environmental Data Reports and Environmental Status and Planning Reports For nearly three decades, the Massachusetts Port Authority (Massport) has prepared annual environmental reports as a requirement under the Massachusetts Environmental Policy Act (MEPA), a state environmental law that functions similarly to NEPA environmental review requirements. Approximately every 5 years, Massport prepares an Environmental Status and Planning Report (ESPR) that reports on historic and projected airport environmental conditions. The Environmental Data Reports (EDRs) are prepared annually in the intervals between ESPRs and provide a review of environmental conditions for the reporting year compared with the previous year. The ESPRs and EDRs are part of a well -established state-level environmental review process that assesses BOS’s cumulative environmental impacts. The ESPRs and EDRs serve as the forum to address cumulative airport-wide impacts; they provide the broad planning context against which individual projects at BOS are evaluated on a project-specific basis, should they meet state and federal environmental review thresholds. The ESPRs and EDRs serve as a source for reliable and consistent environmental data, provide source data for projects undergoing both state and federal environmental review processes, and ensure consistency and transparency in information gathering and reporting. Massport has a robust sustainability program that includes sustainability guidelines, a Sustainability Management Plan, ongoing sustainability initiative implementation, LEED building requirements, and annual sustainability reporting. The ESPRs and EDRs provide a record of historic environmental conditions and performance that allows the agency to establish reliable baseline data and track historical performance over time. The ESPRs and EDRs are primary sources for Massport reports, both under the Massport sustainability program and during NEPA reviews. Core Issues The Massport environmental reporting allows it to tackle several key issues related to NEPA and sustainability: • The reporting serves as a readily available data source for both MEPA and NEPA reviews and the sustainability program, streamlining and reducing costs; • The reporting provides consistency in information gathering and reporting across various agency projects and programs; • The reporting has a familiar and consistent public engagement framework for reporting and information sharing from which specific projects or programs can build; and • The reporting effort is consistent and measurable, allowing the agency to plan for costs of data collection and reporting well into the future. The ESPRs and EDRs facilitate expedited state and federal review processes in the following ways: • They provide the baseline data source for project-specific environmental reviews under MEPA and NEPA; • They serve as the forums to address cumulative airport-wide impacts, accounting for individual projects in close temporal and spatial proximity; and • They preview upcoming projects in an airport planning chapter to ensure community stakeholders are informed well before project-specific environmental review processes advance.

30 Integrating Sustainability Planning and the Environmental Review Process Boston Logan International Airport (BOS) Environmental Data Reports and Environmental Status and Planning Reports (continued) During the preparation of the Logan Airport Sustainability Management Plan, Massport selected five focus areas, which included (1) energy and GHG emissions; (2) community, employee, and passenger well-being; (3) resiliency; (4) water conservation; and (5) materials, waste management, and recycling. These focus areas were selected to augment the resource areas that are documented in the ESPRs and EDRs. Thus, the information presented and analyzed in the two reports are complementary to each another. The Logan Airport Sustainability Management Plan, the ESPRs and EDRs facilitate project-specific review under the state and federal environmental review processes by providing readily available data on key environmental categories. MEPA and NEPA reviews use information from the Sustainability Management Plan and the ESPRs and EDRs to define the conditions in the Affected Environment section, assess potential impacts in the Environmental Consequences section, and evaluate potential effects in Indirect and Cumulative Impacts sections. NEPA Context Massport’s environmental reports serve as key data sources for projects undergoing environmental review under MEPA and NEPA. The agency has found value in the reports, because of the consistency in the way the report data is gathered, analyzed, and reported and the publication framework through which the reports are published. ESPRs and EDRs report on airport-wide environmental conditions including passenger and operation activity levels, regional transportation, ground access, noise, air quality, and water quality. The reports also include an airport planning chapter, which describes recently completed and reasonably foreseeable projects. The identification of reasonably foreseeable projects in the environmental reports sets up these projects for future NEPA review. Projects that undergo a MEPA or NEPA review eventually feed back into the ESPRs and EDRs. The agency uses the environmental reports to track the ongoing mitigation commitments that come out of environmental reviews under MEPA. This enables the agency to “close the loop,” serving as a repository and tracking mechanism for past projects through data records and environmental tracking, ongoing projects through tracking mitigation commitments, and foreseeable projects by listing and disclosing planned and foreseeable projects. Lessons Learned ESPRs and EDRs have provided Massport with a formal, reliable, and consistent data source for understanding environmental conditions at BOS. The reports serve as primary information sources for projects undergoing environmental review under NEPA and provide historical and current environmental performance data for the agency’s sustainability programs. The publication of the reports provides a strong public engagement platform that leads to a well-informed public stakeholder group that receives consistent information on current and planned activities. The agency’s cost to prepare the environmental reports is minimized by reduced time and effort in gathering data for NEPA reviews, sustainability programs, and public engagement. While there is an upfront cost to initiating an environmental reporting program that is independent from a specific project or initiative, the ESPRs and EDRs for BOS demonstrate that there are significant benefits to establishing and maintaining such a program. More details on this case study can be found on the following website: http://massport.com/logan-airport/about-logan/environmental-reports/.

How to Integrate Sustainability Planning into the Environmental Review Process 31 2.3 Addressing Common Challenges This section provides recommendations for how Guidebook users may address specific challenges that have been identified as being common or recurring. Guidebook users may want to refer to this section as a “Frequently Asked Questions” (FAQs) section. The following issues are those that airport staff, FAA personnel, and airport consultants have identified as being the most significant or challenging. 2.3.1 Can Airports Integrate Sustainability Planning into an Environmental Review Without Expanding Scope? The FAA and other federal agencies expect environmental reviews to be conducted in a clear and concise manner that does not reduce the overall document clarity and communicability. It is important that decision-makers and project teams establish a process to effectively inte- grate sustainability planning and avoid producing a superficial or “green washed” document (please refer to Section 3.3.3 for more information about “green washing”) while continuing to meet these agencies’ expectations and requirements. Additional efforts may be required to establish a procedure or to adjust the documentation process; examples include, but are not limited to, identifying relevant data needs that align existing sustainability efforts with project environmental reviews, determining relevant sustainability considerations, and involving appropriate staff with expertise or familiarity with sustainability concepts in the review process. However, once such procedures have been established, incorporating sustainability considerations should reflect the project’s alignment with the airport’s overall sustainability commitment without resulting in project scope growth or increase in costs or time. In fact, over time, integration of these efforts should streamline them and make them both more effective in the long run. 2.3.2 Accounting for Disparate Durations and Scopes Between Sustainability Planning Efforts and Environmental Reviews Sustainability planning and the environmental review process are two separate processes with distinct purposes but similar goals. Airports must understand the timing and role of each process to understand how to improve the flow of information from one to the other. The scope and duration of sustainability programs may be long term (over several years) with specific short-term (over 2 to 3 years) projects, initiatives, or planning efforts. In many cases, an airport may not have sustainability programs, projects, or initiatives under way at all. In contrast, environmental reviews typically focus on a specific action or project with a conceptual design and well-defined timeline, scope, and focus. Project teams may find it challenging to interpret how to incorporate sustainability efforts that are either much broader and generalized than the project undergoing review, or efforts that are much more focused and discrete than the project undergoing review. If an airport has only one or two individual or stand-alone sustainability initiatives (e.g., replacing office light bulbs or installing informational signage about recycling), the project team might find that these initiatives do not have any effect on an environmental review, and the team might not even discuss these initiatives in an environmental review. Project teams should also conduct 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”).

32 Integrating Sustainability Planning and the Environmental Review Process 2.3.3 Integrating Sustainability Planning into an Environmental Review Without a Sustainability Program or Goals If the airport does not have existing sustainability programs, projects, or initiatives in place, it can be challenging for a project team to integrate sustainability planning into the environ- mental review process. If an airport has not yet developed a formal sustainability program or goals, which is likely at smaller airports or general aviation facilities, the project team should look into existing ad hoc sustainability initiatives that may lend insights into the airport’s sustainability commitment and priorities. This approach can be helpful as interim actions prior to establishing formal goals and targets; however, it should not be a long-term solution for airport sustainability efforts. It may be very difficult for airports to consider sustainability planning in an environmental review, if sustainability planning was not considered during the project conception, planning, or early design phases. Ideally, any sustainability element of the project should be incorporated into the project before the environmental review process begins. Project teams should verify that the conceptual design of the project already includes any applicable sustainable design elements before beginning the environmental review. Once a project begins environmental review, it is often too late, or very difficult, to integrate major sustainability features into a project, given project deadlines, stakeholder engagement, scope creep, and funding constraints. Considering new sustainability initiatives while in the middle of the environmental review process is only acceptable if the new elements are being proposed as mitigation measures and do not substantially change the overall project. 2.3.4 Adopting a Consistent and Replicable Approach to Integrating Sustainability Planning and the Environmental Review Process Although the FAA has provided specific guidance for developing and adopting sustainability plans at airports, it is not required that airports conduct sustainability planning or integrate sustainability planning and environmental review processes. As described in Section 1.3.4, Organizational Integration at a Strategic Level, establishing policies and procedures with sustainability considerations as well as shifting institutional culture from “business as usual” can influence the degree to which airports integrate the environmental review and sustain- ability processes. Governance and communication are key to such integration. Without having leadership support and establishing a formal procedure on how to consider sustainability plans when conducting an environmental review, airport practitioners may be hesitant to adopt new techniques or processes. Section 1.7, Quick Start Guide, provides a checklist that project teams can use when starting an environmental review to determine the degree to which the project can integrate sustain- ability planning and environmental review processes. Chapter 4 provides additional resources that aviation practitioners may want to refer to when evaluating sustainability planning in the context of an environmental review. The integration of sustainability planning does not and should not affect the procedure or core goals of a typical environmental review process; the recommendations and practices presented in the Guidebook are intended to enhance the existing steps in the environmental review process, not create new ones. Continuing to follow the step-by-step approach defined in environmental review regulations will maintain the legal defensibility of the final document; integrating sustainability concepts into the environmental review does not require deviating from these steps.

How to Integrate Sustainability Planning into the Environmental Review Process 33 2.3.5 Is It Possible to Align Sustainability Planning and Environmental Review Resource Categories? The following categories are representative sustainability categories based on airport sustain- ability planning documents and FAA interim guidance on sustainability planning at airports. These are consistent with the categories identified by SAGA (www.airportsustainability.org). Table 2-2 contains the alignment of sustainability planning and environmental review resource categories. • Energy and climate • Ground transportation • Economic performance • Design and materials • Water and waste • Natural resources • Human well-being If the project team determines that an existing sustainability program, project, or initiative is related to or influences a project undergoing an environmental review, that program, project, or initiative should be described in the same section of the document in which the potential impact is described. For instance, an environmental review document for a project that may have an impact on stormwater runoff volume would describe any existing sustainability programs, projects, or initiatives related to stormwater in the Water Resources section of the document. A project team may determine that there is a sustainability program, project, or initiative related to or affecting a project undergoing an environmental review, but that program, project, or initiative does not fit clearly within any one environmental resource category. In this case, the project team should work with the lead agency and cooperating or participating agencies to determine the best approach for discussing and evaluating the program, project, or initiative. These approaches may include discussing the program, project, or initiative in a separate chapter or section of the document, discussing the program, project, or initiative in the Project Descrip- tion or Cumulative Impacts section, or providing an evaluation of the program, project, or initiative in a technical appendix. 2.3.6 Best Practices for Sponsor and Leadership Support on the Integration of Sustainability Planning and the Environmental Review Process It is crucial that the effort to integrate sustainability planning into an environmental review process is regularly communicated and coordinated with airport stakeholders, project sponsors, and lead and cooperating agencies. Larger airports often have separate departments responsible for sustainability planning and conducting environmental reviews. Staff within these depart- ments should coordinate and establish a process through which the elements of sustainability plans are appropriately captured in an environmental review document. Where there is no separate sustainability or environmental department, coordination is just as important. The environmental review process is often characterized as a permitting process, when in fact it is a review process that bridges planning and conceptual design. When under schedule or funding constraints, airport staff may approach the environmental review process as a regula- tory hurdle or an authorizing permit rather than a project review; this may limit the ability of the project team responsible for preparing the review to fully consider and integrate features of sustainability plans or programs into the review.

34 Integrating Sustainability Planning and the Environmental Review Process A project team undertaking an environmental review should work with project sponsors and lead agencies early in the process to identify opportunities for integrating sustainability planning within the environmental review to get their buy-in or support while also avoiding extending or expanding the scope of the project. 2.3.7 Case Study—Portland International Airport The following case study demonstrates how the Portland International Airport (PDX) develops a community engagement framework that ultimately supports and benefits its sustain- ability planning and environmental review efforts. Portland International Airport (PDX) Community Advisory Committee’s Focus on Sustainability In 2011, the Port of Portland, city of Portland, and city of Vancouver created the PDX Community Advisory Committee (PDX CAC) on the recommendation of the regional advisory committee for the Airport Futures Plan District and Portland International Airport (PDX) Master Plan. The goal of the PDX CAC is to support “meaningful public engagement,” while encouraging the community to inform airport decision-making and raise public awareness about PDX and impacted neighborhoods. The Committee comprises members representing a variety of local and regional interests. Many airports around the country have community advisory committees, but the PDX CAC is notable for the cross-regional membership and, because a key committee goal is to work toward assuring that PDX and the Airport Plan District become the most sustainable in the world (PDX Community Advisory Committee 2013). The PDX CAC’s focus on sustainability allows PDX and partner agencies to completely integrate community engagement and sustainability planning. The committee serves as an engaged and involved stakeholder for projects undergoing review under NEPA and represents a liaison between the airport and a variety of public interests. The PDX CAC provides a venue for PDX and partner agencies to present proposed programs and receive input and guidance. For example, in 2012, the Port of Portland provided the PDX CAC with an overview of PDX sustainability guiding principles, goals, strategies, and initiatives as well as highlights of sustainability projects like the Port’s energy maintenance strategy and the Sustainable Aviation Fuels Northwest program. Other managed. This case study highlights long-term NEPA and sustainability integration through the alignment of airport planning, particularly for NEPA-regulated projects and public outreach focused on sustainability. PDX’s permanent community engagement framework has created a continuous open dialogue between airport planners and staff, local stakeholders, and concerned public. More information about PDX CAC can be found on the following website: https://www.portofportland.com/Committees/CAC. topics included discussion of the PDX Capital Program and how projects are programmed and assets are 2.4 Special Purpose Laws and Other Environmental Regulations This section provides general information on how airport practitioners should consider sustainability planning integration with other various environmental review regulations. This includes state environmental review requirements and special purpose regulations. Special purpose regulations require a review focused around a specific resource category such as water, air quality, or historic resources. For example, the U.S. DOT’s Section 4(f) review process requires consideration of impacts on park and recreation lands, wildlife and waterfowl refuges, and historic sites. Section 106 of the National Historic Preservation Act requires federal agencies, including the FAA, to consider the effects of federally funded projects on historic properties.

How to Integrate Sustainability Planning into the Environmental Review Process 35 The environmental review processes and the additional analysis or public engagement required under special purpose laws are quite similar. Most involve a component of public noticing and public comment, and typically require a specific level of in-depth review of impacts on a specific resource or in a specific area. Because these regulations are all largely similar in terms of process and approach, the recommendations provided in the Guidebook may be applied at the discretion of the practitioner. For instance, a Section 408 permit authorized under the U.S. Army Corps of Engineers (USACE) requires the proponent to evaluate the potential impacts of a project on any project under USACE jurisdiction. This evaluation generally will include elements similar to those of a typical environmental review such as identifying the project goals and alternatives, describing the existing conditions, and evaluating potential impacts. While there are some significant differences between environmental reviews conducted under different levels of government and under different special purpose laws, the lessons and recommendations for how to integrate sustainability considerations into the review are applicable across regulations. Airport practitioners undertaking a project review under a special purpose law or other regulation may still want to consult the Guidebook and review sections of the Guidebook describing aspects of the environmental review process that are shared with other regulations and laws. Finally, for some projects, there could be opportunities for alignment between the intent of special purpose laws and sustainability planning, For example, recreational uses or historic preservation could be included in, or enhanced by, projects; however, exercise caution because it could later be subject to a Section 4(f) analysis. Another example would be creating a wetland bank as part of a project could promote sustainability as well as satisfy future mitigation require- ments in compliance with the Clean Water Act. All participants in the airport planning process should be aware of the potential connections among airport planning, sustainability planning, and compliance with special purpose laws. The following case study highlights the Canadian Strategic Environmental Assessment process and its similarity to the NEPA environmental review process. High-level recommendations on how to enhance the internal process for preparing an environmental assessment are also provided.

36 Integrating Sustainability Planning and the Environmental Review Process Canadian Strategic Environmental Assessment in Comparison with NEPA Canadian Airport Authorities are required by lease to produce a five-year Master Plan for Transport Canada’s (Canada’s federal transportation ministry) approval including an assessment of the plan's environmental impacts. CEAA of 2012 requires preparation of an environmental report known as an Environmental Assessment. Staff at Calgary Airport (YYC) prepared an environmental review report for their 5-year Master Plan that went above and beyond the minimum requirements of an EA. Airport staff prepared a “Strategic Environmental Assessment” of the airport’s Master Plan that took a longer view and covered more topics than a traditional EA. The Strategic Environmental Assessment allowed the airport to consider potential environmental consequences of the Master Plan as well as policies, plans, and program proposals. There were several benefits of this more robust assessment: • Optimized positive environmental effects and minimized or mitigated negative environmental impacts; • Considered potential cumulative environmental effects; • Implemented the federal Sustainable Development Strategy; • Saved time and money by drawing attention to potential liabilities for environmental cleanup and other unforeseen concerns; • Streamlined project-level environmental assessment by eliminating the need to address some issues at the project stage; and • Promoted accountability and credibility among the public and stakeholders. The Strategic Environmental Assessment provided a systematic approach for identifying, predicting, and evaluating the potential environmental and associated socioeconomic impacts of proposed policies, programs, plans, and projects before decisions were made. YYC never publicly released the strategic assessment, but instead used the information to guide internal decision-making and in the preparation of the traditional EA. The Canadian Environmental Assessment process is very similar in purpose and scope to the NEPA environmental review process. Airports undergoing a NEPA review should consider whether they would benefit from preparing an internal EA prior to beginning the NEPA process that is broader in scope than a traditional EA or EIS. Once completed, the airport would be able to simplify the report to meet the requirements of NEPA, while still using the report for long-term and comprehensive decision-making. Conducting a strategic environmental review prior to the NEPA process could enable airports to consider factors beyond the direct scope of the project-specific NEPA review and would provide an opportunity to consider the immediate- and long-term impacts of sustainability programs. More information can be found on the following website: agency/programs/strategic-environmental-assessment.html. https://www.canada.ca/en/environmental-assessment-

Next: Chapter 3 - How to Leverage the Environmental Review Process for Sustainability Planning »
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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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