1. ACA Conference - September 2017
Environmental Clearance and Next Year’s Grant Presented by: Los Angeles Airport District Office Brenda Pérez George Buley David Cushing
ACA Conference - September 2017

2. Presentation Agenda
Consideration of environmental processes in master planning
Why do we prepare environmental documents?
Timing, Planning and Coordination

3. Appropriate Planning is Critical for the Environmental Process
Master Plan
ALP
Feasibility Studies
Noise Studies
Environmental Determination
CatEx EA
EIS
Project Implementation
Construction

4. Consideration of Environmental Factors in Airport Master
FAA’s Mission is to provide a safe and efficient aviation system
Integral to this Mission, is the FAA’s responsibility for complying with requirements of the National Environmental Policy Act (NEPA)
Environmental issues should be considered early in the airport master planning process to ensure efficient, timely, and effective subsequent NEPA environmental review of a proposed airport development project.

5. Planning and NEPA Purpose and Need
“Purpose & Need” of a proposed action
Airport planning study provides the justification and basis of a proposed action
Consideration of environmental factors as a task
Airport planning process
Related baseline environmental consideration
How does planning set the groundwork for NEPA? One of the first things that NEPA looks at is a clear Purpose and Need, which is a NEPA term that refers to a section of an environmental document the describes the purpose of, and need for, the proposed action.
An airport planning study provides the justification and basis for a project’s Purpose & Need in subsequent environmental evaluation and NEPA analysis of Alternatives.
Consideration of environmental factors as a Task within the airport planning study is appropriate for the planning large complex projects, as well as smaller scope planning projects.
The Airport Sponsor should always complete the airport planning process and any related baseline environmental consideration prior to commencing preparation of an EA or EIS.

6. FAA Role in Airport Master Planning
Proper planning includes FAA review/approval of:
Aviation Activity Forecast and Critical Aircraft
Obstruction Mitigation Plans
Site selection studies
Review the adequacy of the planning alternative analysis
ALP set and associated airspace case study
Planning study and associated capital improvement program
Proper planning includes FAA review/approval of:
Aviation Activity Forecast and Critical Aircraft.
Obstruction Mitigation Plans.
Site selection studies.
Review the adequacy of the planning alternative analysis.
Airport Layout Plan (ALP) Drawing Set and associated airspace case study.
Planning study and associated capital improvement program. Airport Master Plan Study should identify and justify the airport facility’s True Needs for the planning horizon.

7. Planning vs. Programming
Planning informs the CIP
Project need
Priority
Expected costs
ALP is not a programming document
Airport Master Plan Study should identify and justify the airport facility’s True Needs for the planning horizon.

8. Environmental Baseline Features
Planning Environmental Baseline
Preliminary identification of potential, or known, environmental features
Major airport drainage ditches
Wetlands
Flood Zones
Historic or Cultural features
DOT Section 4(f) features
Flora/Fauna
Not part of NEPA
Planning Environmental Baseline - As a Task, the Airport Master Planning study can include a preliminary identification of potential, or known, environmental features.
This Environmental Baseline can include preliminary identification of potential or known environmental features can include:
Major airport drainage ditches
Wetlands
Flood Zones
Historic or Cultural features
DOT Section 4(f) features
Flora/Fauna
This Environmental Baseline is not intended to be part of the NEPA process. It is to ensure that supportable and consistent planning data is provided. It can be used to avoid any sensitive or protected resources during your planning efforts.

9. Intergovernmental and Interagency Coordination
Formal and informal:
FAA must consult affected Federal and state agencies, tribes, and local units of government early in the NEPA process
Community involvement
Early coordination should include coordinating with airport sponsors affected by proposed FAA actions. Consultation comments on the potential environmental impacts of the proposed action must be considered in determining whether the proposed action requires an EA or EIS, and can aid in the preparation of the EA or EIS.
This is KEY to establishing a lasting cooperative relationship between the airport and local community. Successful projects involve the community early in airport master planning.
This involvement is encouraged as it educates and informs the local citizens and local airport users by allowing them to provide constructive input to guide the airport sponsor and FAA decision-making.
The planning process benefits by receiving feedback on local airport needs, local economy and develop which also allows the airport to voice its interest in maintaining compatible land use.
Ultimately – the community involvement in the planning process increases community awareness of the proposed action prior to commencing preparation of an EA or EIS.

10. Why Do We Prepare Environmental Documents?
To ensure that proposed projects comply with federal laws and regulations
To support the “Federal Action”

11. National Environmental Policy Act of 1969 (NEPA)
NEPA requires each Federal agency to disclose a description of potential environmental impacts of the proposed project
FAA must comply with NEPA for all proposed airport development projects that require a federal action
Funding
Approving
Releasing
NEPA covers many environmental laws such as these:

12. NEPA Native American Grave Protection Act
Executive Order (Environmental Justice)
Americans with Disabilities Act
Section 4(f) of USDOT Act (49 USC 303)
Clean Air Act
Farmland Protection Policy Act
Executive Order (Floodplains)
Endangered Species Act of 1973
Migratory Bird Treaty Act of 1918
Resource Conservation and Recovery Act of 1976
Comprehensive Environmental Response, Compensation and Liability Act
National Historic Preservation Act
Archaeological and Historic Preservation Act
Archaeological Resources Protection Act
American Antiquities Act of 1906
Land and Water Conservation Fund Act
Clean Water Act
Executive Order (Wetlands)
Economic, Social and Environmental Effects
Public involvement, interagency coordination

13. Levels of NEPA Study and Federal Review
Categorical Exclusion (CATEX) for action that does not individually or cumulatively result in significant impacts.
Environmental Assessment (EA) for project that does not fall within the scope of a CATEX or has one or more extraordinary circumstances.
Environmental Impact Statement (EIS) for actions with significant impacts.
(Order F, chapter 3)

14. Levels of NEPA Review- Roles
Type of NEPA
Sponsor
FAA
FAA Decision
CATEX
Prepares
Reviews
CATEX Determination EA
FONSI, FONSI/ROD,
Or prepare EIS
EIS
Assists FAA
ROD
FAA’s Roles in Environmental Review
Review the sponsor-prepared Categorical Exclusion (CATEX) for accuracy and issue CATEX approvals to sponsors.
Review the EA and request correction of deficiencies
Coordinate, or consulting, with Federal and state resources agencies and tribes where federal participation is required.
Coordinate review with ADO staff, Regional Counsel, Region, and other LOBs as needed
Prepare FONSIs or FONSI/RODs
Prepare EIS…

15. What projects qualify for CATEX?
Projects must be listed as a CATEX in the Order to qualify as a CATEX
All the same:
Categorical Exclusion
CatEx CE

16. CatEx (CE) Documentation
Airport sponsors can often complete CE documentation for routine actions:
Address all resources categories
Submit to FAA ADO
More complicated CEs may require
Specialized assistance to sponsor such as a city or county planning department staff or
Consultant assistance
FAA ADOs can help you separate “do it yourself” from “need a pro” CE situations

17. Environmental Assessment (EA)
An EA must be prepared for a proposed action if:
It is not categorically excluded
It is normally categorically excluded, but involves one or more extraordinary circumstance that may impact the human environment, or
The action does not normally require an EIS and is not categorically excluded
EA is a concise document used to describe a proposed action’s anticipated environmental impacts

18. Finding of No Significant Impact (FONSI)
FONSI is a finding made by the responsible FAA official after an EA is complete.
Issuance of a FONSI signifies that the FAA will not prepare an EIS and has completed the NEPA process.
Allows project funding and development to proceed

19. Environmental Impact Statement (EIS)
New Runway or New Terminal.
We’ll let you know.

20. NEPA Document Timing What Level of Study Do I Need?
Coordinate early with FAA
Airport Planner
Environmental Protection Specialist
Project Manager
Tip: Utilize Master Plan process for early identification of environmental issues

21. How Long Does It Take? It depends… Planning??
Complexity of the project
Timeliness of surveys/reports
Response from other agencies
Quality of submittals

22. How Long Does It Take? Cont.
If there are no unexpected environmental issues, planning has been completed and quality of submittals
CE – about 1 week to 6 months (depends on extraordinary circumstances)
EA – about 18 to 24 months to a FONSI
EIS – on average about 3 to 4-years to a ROD

23. NEPA Document Timing
The Big Question…When should I submit my documents*
Potential CE Projects:
6 months prior to the Federal Action
Potential EA Projects: these are prior to Federal Action
Biological Assessment – 19 months
Map of Area of Potential Effect (APE) – 22 months
Cultural Report – 22 months
Draft EA – 15 months

24. NEPA Document Timing
Objective is to complete the NEPA process in advance of the “funding need date or proposed project construction schedule”
Why Start the Environmental Early? – Provide sufficient time to ensure NEPA documentation and FAA decision is completed to meet the need date
FAA will need to determine if additional information requirements are needed
Special Purpose Law Consultations. These are Federal laws, regulations, executive orders or departmental orders that are required outside of NEPA.
Endangered Species Act *
Coastal Zone Management Act
National Historic Preservation Act *
Air Quality Act
Floodplains
Clean Water Act
*FAA consultation required if any potential impacts

25. Extraordinary Circumstances
Factors or circumstances which a normally categorically excluded action may have a significant environmental impact that then requires further analysis in an EA or EIS
For FAA, extraordinary circumstances must have the potential for a significant impact.
Identified extraordinary circumstances can be eliminated in order to apply a CatEx.
Some kinds of extraordinary circumstances are:

26. Extraordinary Circumstances
An adverse effect on cultural resources
Impact on properties protected under Section 4(f)
Impact on natural, ecological, or scenic resources of Federal, state, tribal or local significance (T&E species / critical habitat, natural resources and energy supply)
Impact on resources – wetlands, floodplains etc.
Division or disruption of established community
Increase in congestion from surface transportation
Impact on noise levels of sensitive
Impact on air and water quality

27. Project Development Issues
Concerned citizens
Special Interests
Regulatory agencies
Political considerations

28. Common Trouble Spots Purpose and Need Alternatives Cumulative Effects
Compliance with Special Purpose Laws

29. Common Trouble Spots Responses to Public Comments
Response to Resource Agency Concerns
Accounting for New Information
Insufficient Administrative Record