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37 This chapter is aimed at airport practitioners and staff who seek to understand how to leverage the environmental review process for airport-wide sustainability planning efforts and develop sustainability programs, projects, and initiatives. Although the environmental review process and sustainability planning process are two separate processes, they can be approached in a manner that improves the flow of information from one to the other and that ensures mutual benefit. In other words, sustainability planning could draw information from and be consistent with previously completed environmental reviews, but it can also be structured in such a way as to set up future projects and their environmental reviews for success. The following Guidebook users may find the information in the following sections helpful: ⢠Airport managers, planners, or other federal agency staff seeking to gain a general under- standing of the process and practices for integrating the environmental review process and sustainability planning; ⢠Airport managers or project managers preparing a sustainability plan and interested in learning about how environmental reviews may be leveraged to support development and implementation of the plan; ⢠Airport consultants or government agency staff preparing a sustainability plan in coordination with an airport; and ⢠Airport managers or planners engaged in environmental review work and interested in understanding how environmental review documents may be used and incorporated within a sustainability plan. 3.1 What Is Involved in Planning for Sustainability? It is crucial that Guidebook users have a concrete understanding of what is involved in developing and implementing a typical sustainability program, project, or initiative to make informed decisions about how, when, and whether to implement any recommendations presented in the Guidebook. This section provides an overview of a typical sustainability planning process. For the sake of providing concrete examples, the Guidebook will typically refer to the NEPA regulations regarding environmental review documents, but the environmental review process is substan- tially similar to that of CEAA regulations, and even to that of many U.S. state environmental review regulations. 3.1.1 Types of Sustainability Programs, Projects, and Initiatives This section describes the different types of sustainability programs, projects, and initiatives that are adopted at airports. There is a wide range of mechanisms through which airports C H A P T E R 3 How to Leverage the Environmental Review Process for Sustainability Planning
38 Integrating Sustainability Planning and the Environmental Review Process implement sustainability practices. These modes range from broad, long-term, programmatic plans to focused, short-term, discrete efforts. This section describes these various modes, the typical processes used to develop them, and their typical content. Sustainability programs, projects, and initiatives are generally elective actions for airports. There are no current federal or state regulations in the United States or Canada that require airport staff to develop or maintain any type of sustainability program. Different from environ- mental review documents, which focus on a specific project or suite of projects, sustainability plans reflect a broader approach and set airport-wide visions, commitments, and goals. The following are typical types of sustainability efforts that airports may develop: ⢠Sustainability Master Plans, ⢠Sustainability Management Plans or Sustainability Plans, ⢠Resource-specific plans or programs, or ⢠Individual projects or initiatives. Refer to Section 1.6, Key Terminology, for further explanation of these items. It is important to note that while sustainability plans are often a first step in developing and formalizing a sustainability vision and program, the intent is not strictly to create a plan. The intent is to implement strategies that contribute to airport and community sustainability and embed these efforts into the way the airport operates daily. This intent extends to how airport decision- makers review and evaluate potential projects at the airport and should include its environmental review processes. Sustainability plans address initiatives to meet sustainability goals and are a broad approach, while NEPA documents are project specific. Sustainability plans provide a framework of how projects, before moving into NEPA, can and should be reviewed for consistency with sustainability goals and objectives. 3.1.2 Typical Sustainability Planning Process and Content This section identifies the typical components and discussion topics that are included in a sustainability plan. This section is intended to provide Guidebook users with a foundation for understanding the sustainability planning framework within which the recommendations in the following sections can be employed. FAA interim guidance on sustainability planning at airports (FAA 2010) provides a recom- mended structure and content for the plans. As outlined in that guidance, the typical sustain- ability planning steps consist of the following: 1. Develop a sustainability policy, vision, or mission statement; 2. Define sustainability categories; 3. Conduct a baseline assessment; 4. Establish goals for each category; 5. Identify sustainability initiatives; 6. Set targets and performance metrics for each initiative; and 7. Develop the implementation approach. While not specifically called out, public and airport stakeholder engagement is a crucial aspect of sustainability planning. Because sustainability plans are broad and incorporate many different aspects of airport operations, a successful plan requires input from many different airport personnel overseeing these operations. Often, a task force or core stakeholder group is established before preparing the plan. The task force may include representatives from
How to Leverage the Environmental Review Process for Sustainability Planning 39 an airportâs facilities department, accounting office, executive office, air traffic control, capital planning, human resources, and security as well as representatives from federal agencies, concessionaires, airlines, air cargo, and other airport tenants. A task force may also comprise members of the public or non-aviation practitioners. Stakeholder engagement often occurs multiple times throughout the preparation of a sustainability plan. At a minimum, stakeholders would be consulted and provide input on the sustainability policy, vision, or mission statement, selected sustainability categories for the plan, goals for each category, and implementation approach. Depending on the complexity of the plan, additional input may be sought on the specifics of the sustainability initiatives, initiative targets, and performance metrics. It is important that stakeholder engagement include input and buy-in from those individuals who ultimately will be responsible for implementing various initiatives identified in the plan. While this section describes a typical approach for preparing a sustainability plan, resource- specific plans and individual projects and initiatives do not have a defined approach or required content and may deviate from the steps illustrated in Figure 3-1. 3.2 Leveraging the Environmental Review Process for Sustainability Planning This section describes how the environmental review process and documentation should be considered to inform the preparation and implementation of airport sustainability plans. Pulling information from previously completed environmental review documents can help develop robust and relevant goals and initiatives of a sustainability plan, which can sub sequently help inform and improve data collection for future environmental reviews. Additionally, leveraging the environmental review process for sustainability planning will help ensure that sustainability goals and objectives are better institutionalized and that the overall sustainability plan is effectively implemented. Discussions around how to incorporate information from an environmental review process and documentation will be demonstrated using a hypothetical example of an airport going through development of a sustainability management plan. Conduct Baseline Assessment Define Sustainability Categories Develop Sustainability Policy, Vision, or Mission Statement Set Targets and Performance Metrics for Each Initiative Develop Implementation Approach Identify Sustainability Initiatives Establish Goals for Each Category Figure 3-1. Typical process of a sustainability plan.
40 Integrating Sustainability Planning and the Environmental Review Process 3.2.1 Integrating Environmental Reviews within the Sustainability Planning Process This section provides recommendations on how to integrate environmental reviews within the sustainability planning process. These suggestions are largely centered around internal and external communication. It is critical that project teams working on a sustainability plan open internal communication channels to identify (a) previously completed environmental reviews and (b) reasonably foreseeable future projects. It is also beneficial to communicate internally before engaging with external parties and agencies to ensure consistent project mes- saging across multiple stakeholder groups and to maintain existing working relationships. 3.2.1.1 Sustainability Plan Scoping Before and during project scoping, the project team should consider the proposed sustain- ability program, project, or initiative in the context of recent and upcoming major projects. Scoping is the process used to define the primary purpose of the program, project, or initiative. It is an important opportunity to define the degree to which the program, project, or initiative will need to reflect previous or inform upcoming environmental reviews. No matter the size or role of an airport, aviation practitioners working or involved in scoping a sustainability pro- gram, project, or initiative should answer the following questions: ⢠Does the airport have any major recently completed projects that underwent an environmental review? If so, in what ways do the findings and commitments from that review influence the sustainability program, project, or initiative? ⢠What types of information are available in previous environmental reviews that might be useful to include or reference in the sustainability program, project, or initiative? ⢠What are the major upcoming capital projects that might require environmental review? What resource areas might these projects impact, and how might the sustainability program, project, or initiative overlap with or influence these areas? ⢠What types of information could be included in the sustainability program, project, or initiative that would help a project team understand how to implement the plan when working on future projects? ⢠Was there input or feedback received during public engagement processes of any recent environmental reviews that should inform the development of goals and targets for this sustainability plan or program? It is important to develop a general idea of the airportâs current state of capital projects and recently completed and upcoming projects. Answering these questions may help the project team (1) better identify environmental review documents that would make good information sources for the plan, and (2) structure the plan in a way that will guide the implementation of sustainability components on future projects. 3.2.1.2 Stakeholder Engagement Public and agency engagement is a crucial component of both sustainability planning and the environmental review process. When developing sustainability programs and plans, airport staff will often convene internal and external stakeholder groups to assist and provide input on various aspects of the plans. Stakeholder groups and task forces provide crucial input for guiding aspects like vision and mission statements. A project team preparing a sustainability plan should coordinate with airport staff familiar with the public engagement activities of recent environmental reviews. This coordination enables the project team to determine whether there is an existing public body (like a task force) that could be consulted as part of a public engagement effort for the sustainability plan. Such communication also ensures that the sustainability vision or mission statement or the sustainability goals are not in conflict
How to Leverage the Environmental Review Process for Sustainability Planning 41 with commitments or purpose and need statements contained in the environmental review documents. This early internal coordination helps keep messaging consistent, ensures that stakeholders are kept informed, avoids concerns or conflicts between agencies and stakeholders that may arise, and may reduce the amount of time needed to identify internal or external stakeholder groups. Internal coordination can also help identify potential concerns or conflicts with agency policies. It is also important that a project team preparing a sustainability plan consult with internal airport staff responsible for managing planning or mitigation commitments from prior envi- ronmental reviews, including any information tracking or agency reporting requirements. Internal coordination with departments and staff responsible for both environmental reviews and sustainability plans is critical to ensuring consistency across reporting and consistency between project and plan objectives. 3.2.2 Aligning the Environmental Review Process with the Sustainability Planning Process Sustainability plans are broad and typically do not have to follow a set structure (unlike environmental review documents). Recommendations provided in this section will build on sustainability frameworks and content typically found within airport sustainability plans. This format will allow Guidebook users to employ ideas and concepts from the Guidebook for their sustainability planning efforts, even if their sustainability plan framework does not directly align with a typical sustainability plan. Users may choose to adopt or implement any of the recommendations provided under each section. Where relevant, recommendations are broken down into two steps: âPreviously Completed Environmental Reviewsâ and âReasonably Foresee- able Environmental Reviewsâ (see Figure 3-2). 3.2.2.1 Developing a Sustainability Vision or Mission Statement The sustainability vision or mission statement defines the overall objectives of the sustain- ability plan and serves as the building block for the rest of the planâs goals, sustainability categories, initiatives, targets, and implementation. Airports may find it helpful to revisit Figure 3-2. Information flow for integrating environmental reviews into sustainability plans.
42 Integrating Sustainability Planning and the Environmental Review Process any existing policy statement or program with goals specifically focused on sustainability and consider incorporating elements of those goals into this sustainability vision or mission statement. Whether the airport chooses to adopt an existing statement or develop a new one for the sustainability plan, stakeholder engagement is crucial to ensure that this vision or mission statement accurately reflects all aspects of the airport operations and accounts for different departmental goals. Incorporating Previously Completed Environmental Reviews. As the project team works with airport staff to develop a sustainability vision or mission statement, the team should also review recently completed major airport projects (within the past 2 to 5 years) and note whether any sustainability aspects have been considered or identified in their environ- mental reviews. Sustainability aspects in these environmental review documents might not be specifically called out; however, using the EONS framework, the project team may be able to identify common sustainability-related themes based on these projectsâ purposes and needs. Examples of common sustainability-related themes include enhancing the passenger experience, operational efficiency, environmental stewardship, and community responsibility. The project team should ensure that the airport-wide sustainability vision or mission statement encompasses these common themes. Considering Future Environmental Reviews. The project team should also consider future airport projects that would require environmental review. A conceptual understanding of the purpose and need of these future projects will ensure that the project team develops a sustain- ability vision or mission statement, and ultimately a sustainability plan, that will help guide these future projectsâ planning and development to align with the overall airport sustainability efforts. In a similar manner, the established sustainability vision or mission statement should also reflect in the purpose and need of those future projects. Hypothetical Example An airport has received a grant from the FAA to prepare a Sustainability Management Plan (SMP). The SMP is intended to promote and integrate sustainability airport-wide and to coordinate ongoing sustainability efforts across the airport. The SMP developed a framework and implementation plan, with metrics and targets, designed to track progress over time. While developing the airportâs sustainability mission statement, the project team first conducted a search for existing policies, programs, and initiatives across airport departments that focused on sustainability. Findings included the following: ⢠An existing health and wellness initiative for all airport employees, developed by the airportâs Human Resources department; ⢠A Ten-Year Capital Improvement Plan with various sustainability design features called out for proposed projects; and ⢠An Energy Master Plan with comprehensive strategies to reduce overall airport energy usage and increase investment in renewable energy resources. Then, the project team revisited recently completed airport projects and their environmental review documents. Findings included the following: ⢠An EA for proposed new construction of a parking facility. The purpose and need of this project was to improve operational efficiency, minimize air quality impacts, and increase passengersâ convenience and access. ⢠An EIS for a proposed terminal expansion. The purpose and need of this project was to improve operational efficiency, improve passengersâ convenience and access, and improve terminal safety and security. Based on the information gathered, the project team noted the airportâs common sustainability- related themes: engaging with and promoting employeesâ health and well-being, applying
How to Leverage the Environmental Review Process for Sustainability Planning 43 sustainability best practices in construction projects, promoting waste minimization, improving local or regional air quality, minimizing environmental effects caused by airport operations, and improving passengersâ accommodation and convenience. The project team then developed a broad airport-wide sustainability mission statement that speaks to the airportâs commitment to sustainability through ongoing improvement in operational efficiency; environmental stewardship; facility design and construction; and passenger, employee, and community engagement. Once the mission statement was developed, the project team worked closely with staff across airport departments for feedback and further refinement of the statement. 3.2.2.2 Defining Sustainability Categories When considering the sustainability categories, the project team can refer to the information collected for the airport-wide sustainability vision or mission statement to identify applicable themes or focus areas of the sustainability plan. The following categories are typical sustain- ability themes or focus areas based on airport sustainability planning documents and FAAâs interim guidance on sustainability planning at airports. These categories are also consistent with those of SAGA: Economic Performance Engagement and Leadership Energy and Climate Water Ground Transportation Waste Design and Materials Natural Resources Human Well-Being Based on these themes or focus areas, the project team can adopt or modify sustainability categories to reflect the specific areas of importance to the airport. Refer to Table 2-2 in Section 2.2.2.4 for the different sustainability categories as well as alignment of sustainability categories and environmental review resource categories for consideration. As described in that section, the project team should take advantage of the opportunity to align sustainability cate- gories with the typical environmental review resource categories to streamline the collection and reporting process for existing conditions or baseline data assessment, where possible. Incorporating Previously Completed Environmental Reviews. Consulting previously completed environmental review documents and identifying any resource areas described in the documents may provide useful information for each of the sustainability categories. Environmental review documents, particularly in the Affected Environment and Environmental Consequences sections, often provide a good source of information for data, qualitative dis- cussions, and even a framework for setting goals and targets. Refer to Table 2-2 for the alignment of sustainability categories and environmental review resource categories. Considering Future Environmental Reviews. It will be beneficial to consider future projects when determining categories for the sustainability plan. By doing so, the project team can ensure that the sustainability plan will cover useful and applicable resources, when these future projects go through the environmental review process. This exercise will align the objectives of both the sustainability plan and the future projects and bolster their values, while also helping future project teams incorporate sustainability measures into their project designs at an early stage. In the sustainability plan, project teams should identify resource categories of particular concern and associated airport sustainability commitments. To improve coordination and efficiency, the project team should provide guidance in the sustainability plan, ensuring that those categories are also covered in environmental reviews, especially because the airport is making commitments to improved sustainability within these resource areas.
44 Integrating Sustainability Planning and the Environmental Review Process Hypothetical Example Using the SMP development example, the project team looked at the environmental resources described in the recently completed environmental review documents as well as the various existing plans and initiatives that had a focus on sustainability. The project team identified the following sustainability categories to include in the SMP: ⢠Energy and GHG Emissions. This category may help align values and objectives for assessing future projectsâ Air Quality and Climate sections under NEPA review. ⢠Water Conservation. This category may help align values and objectives for assessing future projectsâ Water Resources section under NEPA review. ⢠Community, Employee, and Passenger Well-Being. This category may help align values and objec- tives for assessing future projectsâ Socioeconomics, Noise/Noise-Compatible Land Use, Air Quality, and Climate sections (to name a few) under NEPA review. ⢠Materials, Waste Management, and Recycling. This category may help align values and objectives for assessing future projectsâ Hazardous Materials, Solid Waste, Pollution Prevention, and Water Resources sections under NEPA review. ⢠Resiliency. This category may help align values and objectives for assessing future projectsâ Biological Resources, Coastal Resources, and Cultural Resources sections (to name a few) under NEPA review. ⢠Noise Abatement. This category may help align values and objectives for assessing future projectsâ Noise and Noise-Compatible Land Use section under NEPA review. ⢠Air Quality Improvement. This category may help align values and objectives for assessing future projectsâ Air Quality, Ground Transportation, and Climate sections under NEPA review. ⢠Ground Access and Connectivity. This category may help align values and objectives for assessing future projectsâ Ground Transportation section under NEPA review. ⢠Water Quality/Stormwater. This category may help align values and objectives for assessing future projectsâ Water Resources section under NEPA review. ⢠Natural Resources. This category may help align values and objectives for assessing future projectsâ Biological Resources, Water Resources, Natural Resources, and Energy sections (to name a few) under NEPA review. For instance, under the Water Conservation category for the SMP, the airport can establish specific objectives such as âreduce total water useâ or âreduce potable water used for landscapingâ to ensure airport-wide efforts to implement more efficient water use measures and reduce overall water usage. Under this framework, relevant future airport projects (such as terminal expansion, parking garage renovation, etc.) undergoing environmental review can align their design planning to meet the airportâs commitment to water conservation as well as streamline the data collection and baseline environmental assessment effort. Most of these sustainability categories share the common theme (found across existing initiatives and programs as well as in recently completed environmental review documents) of minimizing environmental effects caused by airport operations. By including these sustainability categories in the SMP, future airport projects, whether they have to undergo the environmental review process or not, will now have a framework with clear sustainability values and objectives to follow. Refer to Table 2-2 in Section 2.2.2.4 for more details on the synergies among NEPA and sustainability categories. 3.2.2.3 Conducting a Sustainability Baseline Assessment The baseline assessment collects information related to the existing conditions and sustain- ability performance of an airport and provides a benchmark for setting improvement goals and targets and for evaluating progress. Once the sustainability categories are identified, the project team can conduct a deeper analysis of existing initiatives, current conditions, perfor- mance, and opportunities for sustainability improvements. In addition to gathering historical data from previously completed reports and existing programs, it can be beneficial to include in the baseline analysis information gathered from interviews and meetings with airport staff across departments. In addition, in the project proposal or planning phases for future projects, the project team may have already gathered baseline information that can be incorporated into sustainability planning.
How to Leverage the Environmental Review Process for Sustainability Planning 45 Incorporating Data from Previously Completed Environmental Reviews. Consulting recently completed environmental review documents can be helpful in providing referenced quantitative data for setting the baseline conditions of the plan. For instance, a recently com- pleted review that quantified electricity consumption for a terminal would save the project team the time and effort of calculating electricity consumption for the sustainability plan. In particu- lar, the project team should review the Affected Environment sections of previous environmental review documents, provided they are relatively recent and up to date. Additionally, mitigation measures that were identified in such documents may be useful to include in a sustainability baseline assessment for existing programs and initiatives. The project team will need to confirm with other staff that such mitigation measures were implemented. Hypothetical Example Using the airport SMP development example, the project team conducted the baseline assessment by reviewing existing resources, such as previously completed environmental review reports, current recycling program components, and master plans. Working closely with various airport department staff (such as Human Resources, Community Relations, Government Affairs, Finance, etc.), the project team collected quantitative and qualitative data for baseline analysis. Some highlights of the project teamâs approach included the following: ⢠Reviewing the recently completed EA for proposed new construction of a parking facility at the airport and the EIS for a proposed terminal expansion. The project team focused on the Affected Environment sections in both reports and looked for relevant existing conditions presented for the identified affected resources. ⢠In reviewing the EIS for the terminal expansion, the project team discovered that renewable energy installations and an extensive construction and demolition waste management program were identified as mitigation measures. After confirming that these sustainable projects and practices were implemented in the terminal expansion project, the team was able to incorporate information from them into the baseline assessment. 3.2.2.4 Developing Goals, Targets, and Performance Metrics Goals are broad, generalized statements that inform strategies and initiative recommendations to be included in a plan. Goals should also be supported by targets and performance metrics that detail the expected results. See the following example: Goal: Reduce energy consumption at the airport Target: Reduce the overall energy consumption in airport-operated buildings and facilities by 25% by 2020 Performance Metric: Total Millions of British Thermal Units (MMBTU) reduced; Thousands of British Thermal Units (kBTU) per square foot reduced This process should be similar to the one in which the project team reviews existing resources to develop an airport-wide sustainability vision or mission statement. The project team should coordinate with airport staff across departments to ensure that the goals devel- oped for the sustainability management plan are consistent with individual department goals and are achievable. This coordination is especially crucial, because sustainability goals often require buy-in and hands-on support from every airport department for effective implemen- tation and achievement. Integrating Previously Completed Environmental Reviews. The project team should consult previously completed environmental reviews, specifically the Proposed Mitigation section, to identify existing proposed mitigation measures and commitments that may inform the goals or objectives to be included in the sustainability plan. Reviewing previously completed environmental reviews may also provide insight into particular environmental
46 Integrating Sustainability Planning and the Environmental Review Process challenges or impacts generated by previous projects that should be considered when devel- oping goals. Considering Future Environmental Reviews. The project team should consult with airport staff to identify foreseeable future projects that may undergo environmental review. Similar to reviewing previously completed environmental reviews, looking ahead to the types of projects the airport is planning to develop may provide insights into potential environ- mental challenges or impacts that the plan should consider when developing sustainability goals and targets. For example, setting an aggressive total energy reduction goal may not make sense if an airport is planning to construct a new terminal; instead the energy reduction goal should include normalized targets that account for necessary growth and expansion. In this example, a kBTU per square foot performance metric might make more sense than a total MMBTU performance metric. Hypothetical Example Using the SMP development example, consulting airport staff from various departments to get input from their departments to develop effective and achievable goals, targets, and perfor- mance metrics for the identified sustainability categories will allow for development of reason- able goals. Some examples of the developed goals, targets, and performance metrics are included in Table 3-1. Sustainability Category Goal Targets Performance Metrics Energy and GHG Emissions Reduce energy consumption Reduce overall energy consumption in airport- operated buildings by 25% by 2020 Total MMBTU kBTU per passenger kBTU per square foot Reduce overall GHG emissions associated with energy consumed at airport-operated facilities Reduce GHG emissions that result from airport facility operations by 40% by 2020 and 80% by 2050 Annual GHG emissions Percentage reduction of GHG emission intensity per gross square foot Water Conservation Reduce potable water used for landscaping Reduce landscaping water use by 10% by 2020 Total annual cubic feet of water used for landscaping per square foot open space Community, Employee, and Passenger Well- Being Continue to support workforce diversity at airport Increase hiring of minority employees by 25%, and of female employees by 40% by 2020 Percentage of minority and female employees Materials, Waste Management, and Recycling Reduce total amount of waste generated at the airport Reduce waste generation per passenger by 2% each year through 2030 Waste volume per passenger rate; Percent of total waste diverted from landfill or incinerator Maintain a high amount of construction waste recycling and reuse Maintain nearly 100% construction and demolition (C&D) waste diversion rate Percentage of C&D waste recycled/reused Air Quality Improvement Ensure the health and safety of travelers and airport employees Maintain NOx emissions associated with airport at or below 1999 levels; Meet National Ambient Air Quality Standards (NAAQS) requirements Measurements of criteria pollutant Source: Massport (2015). Table 3-1. Examples of goals, targets and performance metrics.
How to Leverage the Environmental Review Process for Sustainability Planning 47 3.2.2.5 Identifying Sustainability Initiatives and Implementation Approach Sustainability planning is centered around setting goals and targets, implementing ini- tiatives, tracking progress, re-evaluating, and updating for continuous improvements. Therefore, the project team should identify and develop sustainability initiatives that are actionable measures and projects to support the airport in achieving established sustainabil- ity goals. Additionally, for each of the recommended sustainability initiatives, the project team should also discuss the implementation process, including responsible parties, key partners, metrics for measuring progress, implementation timeline, and potential funding sources. Integrating Previously Completed Environmental Reviews. The project team should consult previously completed environmental reviews to identify proposed initiatives (as an outcome of projects) or mitigation commitments that may inform sustainability initiative recommendations to be included in the sustainability plan. The project team may also find it helpful to review any ongoing tracking reporting programs from previously completed envi- ronmental reviews, because these programs can provide reliable information that can be incor- porated into the sustainability planâs proposed tracking and implementation approach. Considering Future Environmental Reviews. Sustainability initiative recommendations may include measures or actions that can be considered in future projects, such as incorporat- ing sustainability design elements. That way, project teams will have more flexibility to review elements from the sustainability plan and incorporate sustainability considerations early in the project phase. Hypothetical Example Using the SMP development example, the project team looks at the recent EA for proposed new construction of a parking facility at the airport and the EIS for a proposed terminal expansion. In reviewing the Proposed Mitigation section of these projects, the project team notes the following proposed mitigation measures: ⢠Proposed Parking Facility â Monitor passenger activity and employee modes of transportation. â Develop, coordinate, and implement effective transportation demand management (TDM) strategies to reduce the number of single-occupant trips made by airport employees. â Expand high-occupancy vehicle (HOV) hours of service. ⢠Proposed Terminal Expansion â Specify energy-efficient interior and exterior lighting. â Incorporate high-performance glazing systems to optimize building envelope thermal performance, reducing heating and cooling energy consumption and improving passenger comfort. â Incorporate infrastructure for collection, storage, and handling of recyclables. â Ensure that all areas of the first floor (lowest level) of the proposed project are above the Design Flood Elevation for existing structures. â Require that construction equipment use noise reduction measures, ensuring that sound levels from activities associated with the construction of the project be voluntarily consistent with the communityâs noise criteria. The project team then incorporates these proposed mitigation measures into a set of recommendations and works closely with airport staff to identify leaders and teams that will be responsible for the implementation of the recommended initiatives. Figure 3-3 presents an example of an initiative implementation sheet at Massport.
48 Integrating Sustainability Planning and the Environmental Review Process Source: Massport (2015). Figure 3-3. Example of an energy implementation sheet.
How to Leverage the Environmental Review Process for Sustainability Planning 49 3.2.3 Case StudyâPort Authority of New York and New Jersey In the following case study, the Port Authority of New York and New Jersey (PANYNJ) leveraged sustainability-related mitigation measures from the NEPA review process for a terminal project. These mitigation measures were documented in the FONSI, thus formalizing the sustainability elements of the project and ensuring their funding and implementation. Port Authority of New York and New Jersey (PANYNJ) Sustainability Mitigation Core Issues Sustainability Context NEPA Context The EA for the Central Terminal Building (CTB) Redevelopment Program at LaGuardia Airport exhibits how the PANYNJ leveraged mitigation measures from the NEPA review process that were documented in the FONSI to formalize the sustainability elements of the project and ensure their funding and implementation. The PANYNJ CTB Redevelopment EAâs use of mitigation commitments illustrates how the agency integrated its NEPA process and sustainability planning efforts. First, the agency ensured that the sustainability program for the CTB Redevelopment was well developed before the project underwent NEPA review. The core sustainability work involved the review and verification of specification and contractual documents to confirm that they accurately represented the planned sustainability elements. The formalization of sustainability components of the project as mitigation measures ensured that the commitments would be followed, specifically because they were conditions of the FONSI. Sustainability features were embedded in the CTB Redevelopment proposal from early in the conceptual design process because of project sponsor and stakeholder support. To ensure that the sustainability elements were preserved as the project moved through conceptual design and environmental review, PANYNJ included specific sustainability requirements throughout project documents and contracts. The request for proposals (RFPs) for the public-private partnership that would go on to operate the terminal included specific sustainability requirements. The lease and bond offering document also included these specific sustainability requirements. PANYNJ environmental staff reviewed documents to verify that they accurately represented the sustainability elements that were planned as part of the project. PANYNJ staff also followed this approach when collaborating with the FAA in developing the draft FONSI for the CTB Redevelopment EA. PANYNJ suggested that specific sustainability elements linked to the CTB project be included in the FONSI to ensure consistency with sustainability elements planned as part of the project and to assure their implementation. Incorporating the specific sustainability elements of the project into the EA provided several benefits to PANYNJ. From a public comment perspective, it enabled the authority to reference existing sections of the NEPA document in which sustainability was discussed. Specifically, it streamlined the comment responses for common concerns that external agencies (like the EPA) often express regarding external environmental impacts. In anticipation of such comments, sustainability elements were highlighted in the mitigation measures. In developing the sustainability elements of these mitigation commitments, PANYNJ adopted flexible language to ensure that enforcement would be feasible. For example, language about compliance with a sustainability rating system would not specify a specific system; rather, it would remain flexible in the type and application of the rating system. PANYNJ found that the FAA did not view sustainability as a project focal point during the NEPA review; however, by including sustainability elements in the project mitigation commitments, the FAA viewed these commitments as binding and mandatory measures that warrant increased focus. PANYNJ anticipates that the FAAâs focus on sustainability elements within mitigation commitments will increase in the future. The CTB Redevelopment EA demonstrates how airports may use the NEPA review mitigation commitments to ensure follow through and incorporation of planned sustainability elements. The project shows the importance of continued involvement of sustainability planning staff in the project, from conceptual design through the resolution of the NEPA process, to ensure that sustainability elements are accurately represented in binding documents. The inclusion of sustainability commitments in the FONSI is a natural result of this involvement. Further, the flexible mitigation commitment language ensures that the mitigation commitments remain enforceable and valid through the typically longer time frame in which NEPA mitigation measures are tracked, despite possible shifts or changes to specific rating systems. To view or download the written re-evaluation and FONSI for the CTB Redevelopment EA, please see the following website: https://www.panynj.gov/about/studies-reports.html. Lessons Learned Description
50 Integrating Sustainability Planning and the Environmental Review Process 3.3 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 an FAQ section. The following issues are those that airport staff, FAA personnel, and airport consultants identified as being the most significant or challenging. 3.3.1 Best Practices to Ensure Airport-Wide Sustainability Is Considered in Future Environmental Review Preparation Airport staff and airport consultants may not always consider sustainability when preparing the environmental review documentation. This gap is most likely because of the following causes: ⢠Lack of awareness about existing sustainability programs; ⢠Lack of understanding about the connection and applicability of aligning the environmental review process with airport-wide sustainability planning efforts; and ⢠Lack of coordination to streamline the two processes. Airport staff can take steps to ensure that these airport-wide sustainability efforts and plans are actionable and include useful and applicable information that can then be considered in future environmental reviews. The sustainability plan should incorporate guidance on ensuring that sustainability goals, targets, and initiatives are effectively communicated to staff working on future projects. As described in Section 1.3.4, this coordination requires ongoing engage- ment among airport departments and staff responsible as well as a clear communication of the leadership and organizational commitment to sustainability. Through such engagement and communication, everyone stays informed and has the opportunity to provide input on topics including data needs and realistic sustainability goals and targets. Ultimately, airport staff and departments will be able to communicate consistent messages and replicable approaches for existing and future airport activities in both processes (see Figure 3-4). In addition, when developing or updating sustainability plans, airport staff should also consider reasonably foreseeable capital projects and identify sustainable approaches to these Figure 3-4. Environmental review and sustainability planning alignment.
How to Leverage the Environmental Review Process for Sustainability Planning 51 projects in the plan. If possible, information including applicable sustainability categories, goals, or initiatives should be provided for these projects, so that when these projects advance, the project design team and permitting team can refer directly to the sustainability plan to ensure a comprehensive integration of sustainability goals and implementation of plan recommenda- tions throughout these projectsâ planning, design, and construction processes. 3.3.2 What If the Airport Does Not Have Any Recently Completed or Upcoming Projects Requiring Environmental Review? Knowledge of specific projects, completed or upcoming, may be helpful but is not required for sustainability planning. An understanding of the opportunities as well as the airportâs vision and priorities for advancing sustainability through project development is more important, because it will help structure the sustainability plan in ways that make the plan comprehensive and relevant for future project reviews. 3.3.3 What Is âGreen Washingâ? The term âgreen washingâ is commonly used to describe meaningless marketing of sustain- ability or other environmental initiatives, in which the focus is placed on having a good story rather than actually implementing tangible impacts. Branding a project or initiative with the term sustainable or âgreenâ without demonstrating actual goals, targets, or implementation actions is an example of green washing. It is important to involve airport staff or consultants with expertise in or familiarity with airport sustainability, so that they can guide discussions of challenges and opportunities for integrating sustainability into airport projects and activities. Undertaking an environmental review without such expertise could risk unnecessary expansion of project scopes or invalidation of the projects through green washing. 3.3.4 How Does the Project Team Balance Project-Focused Environmental Reviews with Airport-Wide Sustainability Planning Efforts? While typical environmental reviews are project-focused, they may contain useful references or background information (especially regarding environmental consequences, cumulative impacts, and mitigation measures) that inform the development of immediate- and long-term airport sustainability goals. In the interest of advancing sustainability at airports, sustainability plans and programs should be seen as guiding frameworks for sustainability, whereas specific projects (including those requiring environmental review) are where these frameworks are implemented and in which sustainability improvements are realized. Airport practitioners should regularly coordinate and communicate between individual projects requiring environ- mental reviews and sustainability programs and planning.
