Data Supporting the Impact of Regulatory Compliance Costs on Small Airports, Volume 2: Technical Appendixes to ACRP Report 90 (2013) / Chapter Skim
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indicated by check marks. The table is included to provide an indication of the full range of environmental requirements to which small airports may be subject.
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Eleven regulatory actions had projections of minimal costs. For these actions a zero value was assigned in the cost column of Table A-2.
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Figure TA-21. Airport Operator Participation in Environmentally-Regulated Airport Activities (Sample: 95 airports)
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Figure TA-22. Airport Participation in Preparing Environmental Plans and Documents (Sample: 95 airports)
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Tables and figures associated with Phase 2 responses are provided in their appropriate section. The survey results are grouped according to regulatory topic and program.
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existing sources with controls to offset PM2.5 emissions. Examples of PM2.5 controls include particle traps or oxidation catalysts.
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Table TA-14. Reported Costs for Air Emissions Inventories Valid Responses (# of airports in the sample)
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Phase 2 Survey Results and Evaluation, Reported Costs of Compliance The economic analysis conducted for the rule change identified an annual cost savings of $383 for facilities implementing submerged fill technologies, and an annual cost of $948 for facilities with vapor balance systems. The reported costs in the analysis include annualized capital costs for equipment and operation, maintenance, monitoring, reporting, and recordkeeping costs.
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Table TA-15. Reported Costs for ASTs and USTs Valid Responses (# of airports in the sample)
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Emergency Planning and Community Right-to-Know Act (EPCRA) , if defined thresholds are exceeded.
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Table TA-16. Reported Costs for Tier I/Tier II Reports Valid Responses (# of airports in the sample)
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Phase 1 Survey Results and Evaluation Fifty-six percent of airports responded that an ESA has been prepared (Figure TA-22)
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The average cost for a Phase I, II, or III review is approximately $59,000, with a range of $500 to $380,000. Interquartile mean cost was $17,000.
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recycle used oil or reuse used oil onsite (i.e., waste oil heaters)
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average cost per thousand commercial operations is $716 with an interquartile mean of $673. Costs are dependent on the quantity of waste or used oil generated and picked up/disposed.
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Table TA-18. Reported Costs for Activities and Documents Related to Waste Management Valid Responses (# of airports in the sample)
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C.6 Waste Management – Recordkeeping Requirements Background and Change in Requirements In 2005, the content of the Uniform Hazardous Waste Manifest Forms (8700-22 and 22a) was revised to include procedures for tracking certain types of waste shipments.
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NTNCWS is a public water system that regularly supplies water to at least 25 of the same people at least six months per year, but not year-round. The actions affecting these types of treatment and distribution systems during the study period include the Ground Water Rule, Stage 2 Disinfectants and Disinfection Byproducts Rule (Stage 2 Rule)
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for the Lead and Copper Rule were presented cumulatively for all systems nationally. Costs associated with implementation of the Lead and Copper Rule for individual systems could not be determined.
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C.8 Water Resources – Above‐Ground Oil Storage and the SPCC Rule Changes Background and Change in SPCC Rule The SPCC rule was amended a number of times in the 1990's to clarify the rule, incorporate technical changes, and reduce the impact of information collection requirements for regulated entities. During the study period, the SPCC rule was further amended in 2002, 2006, 2008, and 2009 to provide increased clarity, tailor requirements to particular industry sectors, and streamline certain requirements for facility owners or operators.
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Due to the amount of fuel/oil managed and handled at an airport, the overall cost for an airport's SPCC implementation program can be substantial when compared to all of the applicable environmental regulatory. Phase 1 Survey Results and Evaluation A total of 80% of airports reported an SPCC plan was prepared for their operations (Figure TA-22)
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Ongoing operational activities associated with SPCC plan implementation include recordkeeping and periodic inspections and tests. The majority of airports report these activities are performed on a part-time basis.
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a. Contractor/consultants 2 $36 $40 $45 $50 $55 $45 $45 b.
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Costs for installation or construction of controls or equipment were also reported for aboveground storage tanks ($1,000-$1,000,000) , mobile refuelers ($1,200-$209,485)
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Phase 2 Survey Results and Evaluation, Reported Costs of Compliance The economic analysis conducted for the rulemaking estimated the required surveys to identify and evaluate problem areas, issues, and aquatic conditions to cost $100/acre. Assuming the area for pesticide application at a small airport encompasses 100 acres, the cost for a survey alone may be up to $10,000.
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Because some airports perform pesticide applications on or near waters, streams, etc. the new PGP may apply.
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NOI (Figure TA-23)
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Table TA-22. Reported Costs for Documents Related to Construction Storm Water Amendments Valid Responses (# of airports in the sample)
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5370-10. One airport reported the cost for construction controls was $2,000 and two airports reported costs for participation in specialized training as $3,000 and $5,000.
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• Changes to format and organization • New and modified categorical exclusions (CATEX) • New procedures for preparing documents for review • Inclusion of FAA's policy on the environmental stewardship and streamlining provisions of the "Vision 100 -- Century of Aviation Reauthorization Act," Pub.
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Order 5050.4B also provides detailed information related to the thresholds triggering extraordinary circumstances. If the proposed action does not meet the criteria for a CATEX, preparation of an EA begins.
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Table TA-23. Reported Costs for NEPA Related Documents Valid Responses (# of airports in the sample)
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As presented in Table TA-23, the reported average cost and range of costs for an EA compared to an EIS are similar. The average cost is approximately $124,000 and $132,000, respectively.
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skills, and abilities to safely and accurately implement the plan. To be acceptable to the FAA, the AC states that initial and recurrent training must be at least 8 hours in length.
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D.3 Noise Compatibility Requirements (Including Land Acquisition) Background and Change in Requirements Airport Noise Compatibility Planning, 14 CFR Part 150, governs voluntary airport noise compatibility planning programs.
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federally-assisted land acquisition. Thirty-seven percent of airports responding to the environmental Phase 1 Survey identified that a noise study (i.e., includes both Part 150 and161 studies)
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Table TA-25. Reported Costs of Noise Compatibility Requirements Question(s)
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Phase 2 Survey Results and Evaluation, Compliance Costs Table TA-26 summarizes the reported initial and recurring costs. Only one airport reported initial costs and two airports reported recurring costs.
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If a development project is eligible for AIP funding, preparation of the EA or EIS is also eligible for AIP funding, and required mitigation measures may also be eligible. The AIP share of environmental projects at small airports was 95% during most of the study period.
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emissions inventory, these funds may have otherwise been used to install equipment or devices to control air emissions from the airport. Drinking Water Supplier Requirements Grants and funding were made available to drinking water supply utilities through Drinking Water State Revolving Funds to meet costs associated with compliance or implementation of necessary upgrades.
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the projects triggering the CSWPP plan were funded with AIP grants, the costs of developing the plan would have been eligible for AIP funding. NEPA Requirements Two out of six airports reporting costs for a CATEX also reported receiving third-party funding.
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The analysis of funding for NCP requirements focuses on the use AIP and PFC funds, similar to the analysis of other FAA requirements in Technical Appendix 2. Figure TA-26 summarizes the use of AIP funds.
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