Federal Aviation Overview of Office of Airports Engagement …...Federal Aviation Administration Environmental Justice 1 June 2015 Congressional Representatives February 2013 Environmental

Federal AviationAdministration 1Environmental Justice

June 2015Congressional RepresentativesFebruary 2013

Environmental JusticeJune 2015

1

Overview of Office of Airports Engagement on Environmental Justice (EJ) Issues

Federal AviationAdministration

Prepared for: FAA National Civil Rights Training Conference

Presented by: Thomas Cuddy (APP-400)FAA Office of Airports

Date: July 19, 2018


June 2015Congressional RepresentativesFAA Office of AirportsEnvironmental Justice

• When there is a pending Federal action—most typically when there is a proposed airport construction project with potential environmental impacts that go beyond airport boundaries.

• Processes:—Airport Planning (e.g., Airport Master Plan)—Environmental Review (NEPA analysis)

• Impacts of concern:—Noise exposure—Land purchases

• ARP has had no big EJ issues in a number of years

When does FAA Office of Airports get engaged on EJ?



Historical changes in contextHow a 65 dB contour has changed over time



• Executive Order 12898 (“Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations”) requires all Federal agencies to identify and address disproportionately high and adverse health or environmental effects of its programs, policies, and activities on minority and low-income populations.

• DOT Order 5610.2A requires Operating Administrations to fully consider environmental justice principles throughout planning and decision-making processes in the development of programs, policies, and activities that address or affect infrastructure planning and decision-making; social, economic, or environmental matters; public health; and public involvement.

(continued)

Federal Requirements



• FAA Order 1050.1F (“Environmental Impacts: Policies and Procedures”) and FAA Order 5050.4B (“National Environmental Policy Act (NEPA) Implementing Instructions for Airport Actions”) define how the FAA should address environmental justice issues for Airports actions.

• In addition, the Airports and the Order 1050.1F Desk References integrate compliance with NEPA and special purpose laws. Environmental Justice compliance procedures, including analysis and public outreach, are discussed in this document.

• The NEPA training course recently developed by the Office of Airports provides a detailed job-aid that gives background on legal authorities related to Environmental Justice as well as a framework of how to conduct an environmental justice evaluation.

Federal Requirements (continued)



• In February 2012, the Office of Airports entered into a Memorandum of Understanding (MOU) with the FAA Office of Civil Rights to promote the sharing of environmental justice information and analyses for proposed AIP-funded airport projects.

• The MOU established a three-year pilot program (from January 2012 through January 2015).

• In September 2014, the MOU and the pilot program were extended for three more years, through December 2017.

• No projects have met the stated criteria for heightened coordination during this timeframe. However, the Environmental Impact Statement for development at Charlotte-Douglas International Airport, just beginning, will meet likely the criteria.

MOU Between Office of Airports and Civil Rights



• EJ concerns are triggered by human health or environment effects, including interrelated social and economic effects:

— Displacement (e.g., of people and businesses) is the most likely significant Environmental Justice issue at and around airports.

— Noise and air quality are the most likely environmental issues.— Other environmental issues may be raised during the EJ process (e.g.,

thresholds, subsistence resources, use of categorical exclusions).• Although EJ is always an important part of NEPA review and analysis,

it is relatively infrequent for significant EJ issues to materialize.

• Lower-cost housing is sometimes available near large, busy airports and as a result it is not unusual for low-income populations to live in these areas. These areas are often exposed to high noise levels from airport operations.(continued)

Types of issues that can Trigger EJ concerns



• Noise-related EJ analysis may include reviewing potential alternatives to the proposed action, including different runway alignments, or other means of meeting the aviation need. As part of the EJ analysis, airport noise contour data and other data is compared with minority and low-income maps.

• EJ issues that have been studied in Environmental Impact Statements in Alaska have focused on impacts to subsistence resources used by Native Alaskans.

Types of issues that can Trigger EJ concerns (cont’d)



• Where possible, both airports and the FAA typically seek to avoid impacting populated areas at all—and particularly if they are disproportionately low-income areas.

• Mitigation measures may include property acquisition, sound insulation of homes and schools, or compensation through the purchase of avigation easements. The FAA is frequently able to support these measures through Airport Improvement Program (AIP) grants to the airport sponsor or the community.

• The FAA can also provide AIP funding to support airports that choose to work collaboratively with neighboring communities (through 14 CFR Part 150) to develop noise compatibility plans, which can include noise abatement measures such as preferred runway utilization plans, revised approach and departure paths for aircraft, voluntary nighttime restrictions, etc.

Potential Mitigation Measures



Los Angeles International AirportFirst opened 1961



The EJ analysis was part of a highly detailed Final Environmental Impact Statement issued in 2005. The major projects included shifting of runways, a new Ground Transportation Center, and new passenger terminal buildings.

• The analysis found that three of four alternatives evaluated in the Final EIS could have disproportionately high and adverse effects on minority and low-income populations. However, the selected alternative did not have a disproportionate impact.

• The analysis also found that air quality impacts would disproportionately occur on minority and low-income populations due in part to construction related emissions. As a result, 16 specific mitigation measures to reduce these impacts were identified.

• The airport sponsor conducted 126 specific outreach efforts to low-income and minority populations over the course of four years during development of the Master Plan and EIS.

Example 1. Los Angeles International Airport



Philadelphia International AirportFirst opened 1940



In 2010 an EIS was published for a capacity enhancement program for Philadelphia International Airport, including major runway and terminal expansion:• Impacts to environmental justice populations were considered relative to (a) Land

acquisition/community disruption and (b) areas significantly impacted by noise.

• The environmental justice analysis included a detailed assessment of minority, Hispanic, and low-income populations within the census blocks and census block groups where land would be acquired or impacts could occur.

• The EIS concluded that the proposed projects would not have a significant adverse impact to minority or low-income populations and would not result in disproportionate and high adverse impacts on these populations.

• FAA conducted an extensive public coordination process in minority communities. This outreach included public meetings, open houses, websites, and use of local newspapers. Meeting locations were selected to allow for easy access via public transportation.

Example 2. Philadelphia International Airport





Example 3. Kodiak AirportIn 2013 the FAA published a Final EIS for Runway Safety areas at Kodiak Airport in AK.• Impacts from a runway safety area project to environmental justice populations

were considered relative to subsistence resources (fisheries) and practices tied to the cultural identity of three Alaska Tribes.

• The environmental justice analysis included a detailed assessment of minority and low-income populations within census tracts around the project area. About 45% of the population were identified as minority with about 13% of the population identified as Alaska Natives and the rest predominantly Asian.

• The EIS concluded that the proposed project would have a significant adverse impact to on customary and traditional practices and cultural identity of the Alaska Villages and the Tribe. Mitigation included funding subsistence management on an affected river and funding a tribe to monitor fisheries impacts of the project.

• FAA conducted an extensive coordination process in minority communities. This outreach included public meetings, open houses, websites, and use of local newspapers as well as extensive government to government coordination with the Native Alaska tribes.



Recent Efforts to address EJ analysisFAA updated the agency-wide NEPA Order 1050.1 and created an accompanying Desk Reference (similar to the Airport Desk Reference), including more emphasis on environmental justice.

• The Order highlights public involvement for environmental justice populations in the planning chapter to be consistent with the DOT Order 5610.2A updates in May 2012.

• Order 1050.1F Desk Reference expands the guidance on FAA’s EJ responsibilities from about 2 pages to 7 pages of content:

— FAA must consider impacts on the environment that would affect an environmental justice population in way that is unique and significant to that population.

— Some adverse impacts may not normally be considered significant under NEPA ( i.e., normally cause an EIS to be prepared), yet may pose a significant impact when examined in the context of their effects on minority or low-income populations.

• ARP developed a job-aid as part of our Introduction to NEPA course that details how to conduct an EJ analysis



Recent Efforts to address EJ analysis (continued)

•FAA Community Involvement Manual (CIM) online Office of Environment and Energy (AEE) updated the 1990

community involvement guidance document to reflect current practices for engaging communities.

Document is agency-wide guidance that applies policies to all agency actions (cover photo at left).

•ATO Community Involvement Plan (CIP) online FAA Air Traffic Office has developed a Community Involvement Plan

(CIP) in an effort to identify what types of community involvement can best help implement flight procedures effectively.

Plan involves several parts, including changes to the PBN Order, and checklists for implementation.

•ATO Community Involvement PBN Desk Guide Developed by Airspace Services (AJV-1) with participation from FAA

representatives from AGC, AEE, AJV-0, and the Service Center OSGs. The Guide is intended as a reference for those engaged in community involvement activities within ATO and other lines of business.

FAA updated agency-wide focus on Community Involvement



Recent Efforts to address EJ analysis (continued)

The Office of Airports updated Advisory Circular (AV) Community Involvement in Airport Actions.

Developed Strategic Direction:• Encourage more robust interactions between sponsors and airport

public• Stay focused on the ‘Citizen’ part of public involvement• Emphasize win-win benefits of good public involvement• Emphasize continuity between public relations, planning,

environmental, project development• Highlight new tools for enhanced public involvement, e.g., social media4 chapters with appendices: • Need for Community Involvement• Planning for Community Involvement• Designing and Implementing a Community Involvement Program• Documenting the Process, Assessing Effectiveness, and Closing Out a

Program



Environmental Visualization (EVT) ToolPurpose:• Provide a more easily-accessible and user-friendly web-based tool to

visually evaluate potential environmental impacts.

Capabilities:• Web mapping application accessible only on the FAA network.• Ability to incorporate EJ data created in AEDT, and other data: flight

paths and noise data.• Integrate other sources of

environmental and political data (e.g. congressional districts, air quality).

• The AEDT EJ functionality provides a “rough cut”; additional information and research may still be required.

• http://evt.faa.gov

http://evt.faa.gov/



Potential Future FAA EJ Activities

• To enhance engagement on EJ issues and best practices related to FAA actions, the FAA can improve communication and engagement across FAA, and with airports and EJ communities.

• Activities that could be further explored include:

— Meetings and Outreach

— Educational and Training materials

— Web materials (e.g., comment boxes, a clearinghouse and/or repository).

Documents

Federal Aviation Overview of Office of Airports Engagement …...Federal Aviation Administration Environmental Justice 1 June 2015 Congressional Representatives February 2013 Environmental