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Suggested Citation:"Chapter 3 - Interactive Tool Logic." National Academies of Sciences, Engineering, and Medicine. 2020. Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports. Washington, DC: The National Academies Press. doi: 10.17226/25735.
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Suggested Citation:"Chapter 3 - Interactive Tool Logic." National Academies of Sciences, Engineering, and Medicine. 2020. Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports. Washington, DC: The National Academies Press. doi: 10.17226/25735.
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Suggested Citation:"Chapter 3 - Interactive Tool Logic." National Academies of Sciences, Engineering, and Medicine. 2020. Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports. Washington, DC: The National Academies Press. doi: 10.17226/25735.
×
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Suggested Citation:"Chapter 3 - Interactive Tool Logic." National Academies of Sciences, Engineering, and Medicine. 2020. Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports. Washington, DC: The National Academies Press. doi: 10.17226/25735.
×
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Suggested Citation:"Chapter 3 - Interactive Tool Logic." National Academies of Sciences, Engineering, and Medicine. 2020. Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports. Washington, DC: The National Academies Press. doi: 10.17226/25735.
×
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Suggested Citation:"Chapter 3 - Interactive Tool Logic." National Academies of Sciences, Engineering, and Medicine. 2020. Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports. Washington, DC: The National Academies Press. doi: 10.17226/25735.
×
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Suggested Citation:"Chapter 3 - Interactive Tool Logic." National Academies of Sciences, Engineering, and Medicine. 2020. Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports. Washington, DC: The National Academies Press. doi: 10.17226/25735.
×
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Suggested Citation:"Chapter 3 - Interactive Tool Logic." National Academies of Sciences, Engineering, and Medicine. 2020. Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports. Washington, DC: The National Academies Press. doi: 10.17226/25735.
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Page 27

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20 Given the wide range of issues to be addressed in the NEPA process, and the need for the user to provide sufficient input to the Interactive Tool for the results to be meaningful, the Team concluded that a “decision tree” structure, in which each answer moves the user along a branch of the tree, is needed. This approach enables the Interactive Tool to provide context-sensitive information at each potential branching point to guide the user through the process. The Team developed logic diagrams that translated the requirements of NEPA and the special-purpose laws into a series of discrete choices that for the user. It is important that the user make these choices on the basis of the best available information, and the Interactive Tool also provides references and links to information sources to assist the user in obtaining the necessary information. The Interactive Tool consists of the following two modules. 1. The analysis module guides the user through the NEPA process and the requirements of special-purpose laws. 2. The cost- and time-estimating module guides the user in estimating the likely costs and time- line for NEPA compliance. This chapter reviews the logic of these modules. Appendix D contains a detailed User’s Guide, which provides step-by-step instructions in working through the process. 3.1 Evaluation Module The evaluation function of the Interactive Tool can be viewed as a “decision tree” or flow chart in which decisions made at one point of the process define the possible paths to the next deci- sion, and so on. This module consists of project definition and environmental analysis sections. 3.1.1 Project Definition The NEPA process must start with a complete definition of the project to be evaluated. The research indicates that poor and/or incomplete project planning is the most common deficiency in the NEPA process. As directed by the ACRP 02-73 Panel, the Interactive Tool provides the information a user needs to complete the FAA Airports Division CATEX checklist. The first step in this process is to define the project itself. As noted earlier, many types of projects at GA airports can be approved through a CATEX. The Interactive Tool provides guidance to the user to aid in determining if the project would be eligible for a CATEX and provides guidance for the user in selecting the appropriate responses. Figure 4 shows how the Interactive Tool translates the logic of the NEPA Process into dis- crete choices for the user to make in defining the project. The Interactive Tool includes a list of C H A P T E R 3 Interactive Tool Logic

Interactive Tool Logic 21 47 types of projects typically required at airports and provides a screen for the user to select the project type, a fence in this case. In this example, the selected project type, fencing, is covered by a CATEX defined in FAA Order 1050.1F. The Interactive Tool generates a screen for the user to review and confirm that the fencing project meets the requirements of the CATEX. Should the user determine that the project does not meet those requirements, the Interactive Tool would advise the user to consult with the ADO EPS about initiating an EA or EIS. The research described in Chapter 2 emphasizes the need for projects to be based on com- plete planning and to be fully defined. Following the process shown in Figure 4, the Interactive Tool identifies the types of additional supporting or “enabling” projects often associated with the selected project. If the user identifies any of these associated projects, the Interactive Tool provides the associated CATEX requirements and asks the user to confirm that the associated project meets those requirements. It is also possible that an associated project would not be eligible for a CATEX or would not meet the requirements of a CATEX, in which case the Inter- active Tool would advise the user to the user to consult with the ADO EPS about initiating an EA or EIS. Figure 4. Application of the NEPA logic diagram in the interactive tool.

22 Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports 3.1.2 Environmental Analysis As noted in Section 1.1.1, the FAA can only approve a CATEX if no “extraordinary cir- cumstances” apply. The second step in this process is therefore to determine if extraordinary circumstances apply to this specific project. In general, extraordinary circumstances arise from environmental impacts associated with the project setting. The research described in Chapter 2, notably the FAA NEPA practitioner interviews summarized in Section 2.1, emphasizes the need for airport sponsors to know the nature of the environmental setting for proposed projects. For the Interactive Tool to provide realistic guidance, the user must therefore assemble critical information and enter that into the database. The Interactive Tool guides the user in providing the information needed to complete the CATEX checklist provided in FAA Airports (ARP) Stan- dard Operating Procedures (SOP) 5.0 by asking the user a series of questions about the impacts of the project on various environmental resources needed to complete the CATEX checklist. The bulk of the research in developing the Interactive Tool consisted of investigating the require- ments of the special-purpose laws that fall under the NEPA umbrella. Figure 5 gives an example logic diagram for determining a project’s impacts to wetlands. (ARP SOP 5.1 became effective on June 2, 2017, following development of the Interactive Tool logic.) In the example above, a series of steps guides the user through the process of determining the type of wetlands affected and the associated requirements for coordination and compliance with the applicable laws and regulations, which in this case include Executive Order 11990 and Section 404 of the Clean Water Act. If the wetlands fall under the jurisdiction of the U.S. Army Corps of Engineers, the Interactive Tool guides the user in determining the type of permit required and the NEPA process required. The Interactive Tool incorporates similar logic dia- grams for every environmental resource category identified in FAA Orders 1050.1F and 5050.4B. The user interface generates a screen for each step of the logic diagram for each environmental category. As an example, Figures 6–9 show a series of screens developed from the wetlands logic diagram shown in Figure 5. The answers to the questions posed in the screens will ultimately Figure 5. Application of the wetlands analysis logic diagram in the interactive tool.

Interactive Tool Logic 23 Source: Interactive NEPA Information Tool Figure 6. Wetlands and other waters of the U.S. – introduction. Source: Interactive NEPA Information Tool Figure 7. Wetlands and other waters of the U.S. – data sources. Source: Interactive NEPA Information Tool Figure 8. Wetlands and other waters of the U.S. – avoidance alternative warning.

24 Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports determine the type of NEPA documentation required. In this case, the project area contains wet- lands identified by a site survey. Had the user indicated that no investigations had been under- taken, the Interactive Tool would have advised the user to obtain additional information prior to continuing. The fact that wetlands would be affected causes the Interactive Tool to remind the user that alternatives that would have avoided or minimized the impact must have been considered. The last screen in the series asks if a jurisdictional determination has been made. Depending on the responses to this and other questions, the Interactive Tool would advise the user if a CATEX could be issued or if an EA or EIS would be required. 3.2 Cost and Schedule Module In the experience of the Team members, the ability to investigate costs and scheduling impli- cations of a planned project can be useful before starting a NEPA process. While the project definition and environmental analysis modules described above provide information that will aid the user estimating the cost and duration of the NEPA process and supporting studies, the Interactive Tool also allows the user to estimate costs and schedules without first completing those modules. This feature can be useful in pre-planning for funding and scheduling purposes, especially if the user already has some information about the environmental setting of a possible future project. Project costs are highly sensitive to the specific details of project design, location, and envi- ronmental issues. In the experience of Team Members, augmented by investigations of indi- vidual projects, the costs and durations for various types of NEPA processes and environmental issues can vary dramatically, sometimes by orders of magnitude. Project costs and schedules are affected by myriad variables that the Interactive Tool is not able to capture. For example, the following considerations can substantially affect the level of effort required to complete the NEPA process. • Quality and completeness of planning • Regional conditions and sensitivities • State and local regulatory requirements • Site conditions Source: Interactive NEPA Information Tool Figure 9. Wetlands and other waters of the U.S. – jurisdictional status.

Interactive Tool Logic 25 • Levels of community interest or concern • Availability of local technical experts • Regional costs of doing business • Competitive environment for services The cost and time module helps the user to estimate the time and effort required to complete the NEPA process and comply with special-purpose laws for the selected project. Due to the extreme variability in costs and durations due to factors that can’t be fully reflected in a pro- grammatic process such as the Interactive Tool, the cost and schedule estimates generated by the Interactive Tool represent ranges of order-of-magnitude costs. These estimates are based on the level of effort or “technical intensity” required to assess the impacts of the projects on spe- cific environmental resources. The results of the cost and scheduling estimates developed by the Interactive Tool are not designed to be, nor should they be used as, the Independent Fee Estimate (IFE) required for some FAA grant-funded projects. An IFE must be based on a specific scope of work that should reflect the variables noted above, as well as other relevant considerations such as the airport sponsor’s management and public outreach requirements. To estimate the cost and schedule implications of generic projects, the Interactive Tool must base cost and schedule estimates on more general factors. The Interactive Tool provides guidance in the form of pop-up menus that help the user select the most appropriate level of technical intensity, which is then used to estimate costs and durations. The logic for estimating total costs is essentially additive: the Interactive Tool simply accumulates the costs for each item in the total. In contrast, the logic for estimating duration is more complex because some elements are dependent on others, while others can be completed concurrently. The range of estimated durations reflects the variations in site- specific issues and in study design and accounts for interdependencies, such as the need to have completed a Section 106 analysis prior to investigating Section 4(f ) impacts. Appendix B outlines the cost and schedule assumptions built into the Interactive Tool. Similar to the evaluation module, this module asks the user to identify levels of effort based on built-in guidance. The number of possible combinations of NEPA document types and environmental resource analyses reaches well into the millions. The Interactive Tool treats the process as a series of independent steps. 1. Cost and duration of the NEPA process. After the user identifies the most likely NEPA process, either based on the results of the Project Definition and Environmental Analysis modules, or on other user input, the Interactive Tool prompts the user to select the level of complexity from a pull-down menu. The menu includes descriptions of the factors to con- sider in determining the level of complexity. While the number and type of environmental issues will clearly affect the level of NEPA documentation identified by the Interactive Tool, this step does not address the level of effort and duration required for individual environ- mental analyses. In effect, this step addresses all of the NEPA document except the evaluation of environmental impacts, or consequences. 2. Cost and duration of individual environmental resource analyses. The Interactive Tool identifies the environmental analyses required to complete the NEPA process based on the user’s input. As noted above, the user selects the appropriate level of complexity from a pull- down menu with associated descriptions of the factors to consider in establishing the level of complexity for each resource. Again, user input may be based on the output of the Project Definition and Environmental Analysis modules, or on other user input. The Interactive Tool assumes that all costs are cumulative, meaning that the costs of the selected NEPA document type and level of complexity are added to the costs of all the applicable environmental resource analyses. The process for estimating the total duration is more complex.

26 Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports Source: Interactive NEPA Information Tool Low High Low High Required? Responsible Agency Air Quality Medium $1,500 $50,000 1 3 Possible EPA, State Air Agency Climate Low $500 $500 0.2 0.2 No Coastal Resources Not applicable $0 $0 0 0 Section 4(f) Not applicable $0 $0 0 0 Farmlands Not applicable $0 $0 0 0 Hazardous Materials, Solid Waste, and Pollution Prevention Low $500 $500 1 1 No Historic, Architectural, Archaeological, and Cultural Resources Not applicable $0 $0 0 0 Land Use Not applicable $0 $0 0 0 Natural Resources and Energy Supply Low $500 $500 1 1 No Noise and Noise-Compatible Land Use Medium $5,000 $15,000 2 4 Through NEPA FAA Socioeconomic, Environmental Justice, and Children's Environmental Health and Safety Risks Low $500 $500 1 1 No Visual Effects Low $500 $500 1 1 No Water Resources Medium $500 $2,000 1 4 Possible US Army Corps of Engineers Cumulative Impacts Low $500 $500 1 1 No Irreversible and Irretrievable Commitment of Resources Low $500 $500 1 1 No NEPA Documentation Documented Categorical Exclusion $5,000 $15,000 4 8 Through NEPA FAA Costs Durations (weeks) Consultation Environmental Discipline Complexity Figure 10. Example output of cost and schedule module.

Interactive Tool Logic 27 For larger efforts, it is likely that several tasks might be done concurrently. In some cases, each environmental resource might be assigned to a different individual or team. On the other hand, some analyses are dependent on the outcome of other analyses. For example, if aircraft noise impacts would occur, the evaluation of Section 4(f) issues cannot be completed until the noise analysis shows whether Section 4(f) resources would be affected. In that case, the Interac- tive Tool combines the time required for a string of connected analyses as a single duration. The Inter active Tool estimates the duration of the environmental analyses based on the assumption that all environmental analyses are conducted concurrently except for those dependent on the results of other analyses. The duration of the environmental analysis equals the longest time required for any environmental analysis or string of analyses. As with the total cost estimates, the total duration estimates are based on the estimated duration of the NEPA process added to the estimated duration of the environmental analyses calculated as described above. Figure 10 shows an example of the cost output. The user can print a clipping of this screen to preserve a hard copy of the results. It is important to note that these cost estimates are not appropriate for use in developing the Independent Fee Estimates often required by the FAA for grant purposes.

Next: Chapter 4 - Conclusions and Suggested Research »
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Most general aviation (GA) airports are minimally staffed and rarely employ environmental specialists, and the National Environmental Policy Act (NEPA) can be overwhelming to work through for those not familiar with the requirements.

The TRB Airport Cooperative Research Program's ACRP Research Report 211: Guidance for Using the Interactive Tool for Understanding NEPA at General Aviation Airports, and the accompanying interactive tool that was developed, will help airport staff from GA airports understand the NEPA process. The report provides an overview of NEPA, when it is applied, and the three levels of NEPA review. The tool will be helpful in better understanding the level of effort that may be required to comply with NEPA.

An annotated bibliography, which was Appendix A to the Contractor’s Final Report, is also available.

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