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TECHNICAL APPENDIX 6. ESTIMATES OF INDUSTRY COSTS Technical Appendix 2 through Technical Appendix 5 present estimates of average compliance costs per airport and per thousand units of activity, enplanements and commercial operations. Further analysis, however, shows that compliance costs do not increase with activity levels, and estimates of national costs should be derived from the average cost per airport. This technical appendix presents estimates of industry cost impacts for each of the four regulatory subject areas based on the average costs per airport calculated from the survey data. A. Methodology The primary estimates of industry cost impacts are based on the average cost per airport presented in Technical Appendix 2 through Technical Appendix 5. The estimation process followed three steps: 1. The total number of potentially affected airports (airport population) was determined. In many cases, the airport population consisted of all small airports. In other cases, such as the certification requirements, and PFC requirements, only a subset of small airports was potentially affected, and the appropriate airport population was determined using FAA records. 2. The number of airports actually affected by the requirement was determined. Unless the terms of a requirement or other information indicated otherwise, this number was calculated by multiplying the airport population subject to the requirement (Step 1) by the percentage of airports reporting an impact from the requirement in the Phase 1 survey. If the terms of the requirement or other information clearly indicated the survey results were inaccurate, the percentage was adjusted to conform to the percentage indicated by the terms of the requirement or other percentage. For example embedded in the total costs of Part 139 requirements is the cost of preparing a new airport certification manual. This requirement applied to 100% of certificated airports by the terms of the regulation; therefore, the percentage of airports was adjusted to 100%. 3. The average cost per airport of the requirement was multiplied by the number of affected airports. When available, the interquartile mean, instead of the arithmetic mean, was used to avoid skewing results by extreme high or low values. The industry cost estimates presented in the succeeding sections represent the best possible estimate obtainable from the Phase 2 survey results. For many reported costs, few airports responded (in some cases, a single airport). The length of the survey and the level of detail of the questions made it difficult for many small airports to respond. Much like the Page TA-120
compliance requirements that are the subject of this research, the survey was an additional work- load item for the limited staff resources that typically perform multiple operational and administrative functions. For consistency of presentation, the estimates of industry cost impacts are organized in the same way as the data on individual airport costs presented in Technical Appendix 2 through Technical Appendix 5. Where applicable, initial and recurring costs are presented in a single table. B. Industry Cost Impacts of FAA/DOT Requirements Total initial costs of compliance with FAA/DOT requirements are $1.392 billion. Almost half of this total is attributable to a single requirement â the modification of RSAs to meet FAA standards. Total recurring industry costs are $67.5 million. These figures include initial and recurring costs of $1.0 million and $656,000, respectively, for compliance requirements documented in Appendix B, which are not otherwise discussed. B.1 Airfield Design, Standards and Operations Requirements Table TA-32 presents the estimate of the industry costs of the airfield design, standards and operations requirements. Total industry initial costs are $1.063 billion, and total recurring costs are $3.9 million. Based on initial costs, the single most expensive requirement for the industry is the RSA requirement at $695 million. The RSA requirement is also the most expensive on a per airport basis. The high cost may reflect the fact that RSA projects can involve grading, filling, relocation of roads, navigational aids and other costly civil construction. The requirement for airfield signs is the most expensive on a recurring cost basis at cost of $2.4 million and was also the most costly on a per airport basis. Page TA-121
Table TA-31. Industry Costs, Airfield Design, Standards and Operations Requirements Question(s) Average Cost($)1 Airports Subject to Requirement Estimated Industry Cost of Compliance Percentage of Airports Reporting Impact2 Industry Cost ($) Initial Costs Since March 28, 2007, how much did it cost your airport to move 36. an automobile parking, a roadway, or other facility improvement outside a runway protection zone (RPZ) as a result of an advisory circular (AC) issued by the FAA on that date (AC 150/5300-13, Change 11)? How much has your airport spend on projects in the last 10 years 73. to comply with new or updated regulations related to the Runway Safety Area? Total Runway Protection Costs (RPZ and RSA) Since the beginning of CY 2000, how much did it cost your 18. airport to modify its perimeter fencing in response to FAA guidance on minimizing deer hazards? 74. How much has your airport spend on projects in the last 10 years to comply with new or updated regulations or requirements related to security fencing surrounding the AOA? Total Fencing Costs Since January 1, 2000, how much has it cost your airport to add, 43. modify or replace airfield signs as a result of new or modified requirements or guidance adopted by the FAA? Total Initial Costs, Airfield Design, Standards & Operations $1,492,556 $3,676,184 $5,168,740 $782,660 $777,269 $1,559,929 $90,003 310 $310 $310 $310 $310 13% 61% 57% 61% 79% $60,150,000 $695,166,000 $755,316,000 $138,296,000 $146,982,000 $285,278,000 $22,042,000 $1,062,636,000 Recurring Costs Since March 28, 2007, how much did it cost your airport to move an automobile parking, a roadway, or other facility improvement 36. outside a runway protection zone (RPZ) as a result of an advisory circular (AC) issued by the FAA on that date (AC 150/5300-13, Change 11)?3 43. Since January 1, 2000, how much has it cost your airport to add, modify or replace airfield signs as a result of new or modified requirements or guidance adopted by the FAA? Since the beginning of CY 2000, how much did it cost your 18. airport to modify its perimeter fencing in response to FAA guidance on minimizing deer hazards? Total Recurring Costs $1,500 $10,000 $6,600 $310 $310 $310 57% 79% 57% $265,000 $2,449,000 $1,166,000 $3,880,000 1 Interquartile mean cost, unless otherwise indicated 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Single airport response. Value of response used. Page TA-122
B.2 Part 139 Certification Requirements Table TA-32 presents the estimated industry cost of compliance with the amendments to Part 139 requirements for newly certificated airports. As discussed in Technical Appendix 2, Class II airports, which held limited certificates in 2004 are included in the category. Table TA-32. Industry Costs of Part 139 Amendments for Newly Certificated Airports1 Question(s) Average Cost ($)2 Airports Subject to Requirement Estimated Industry Cost of Compliance ($) Percentage of Airports Impacted by Requirements3 Industry Cost ($) Initial Costs What capital expenditures were required for compliance with the 11. Part 139 ARFF requirements?4 b. ARFF vehicles, clothing and ARFF personnel equipment Initial Costs Total Initial Costs How much did it cost your airport to modify its perimeter fencing 12. in order to comply with Part 139?4 How much did it cost your airport use to develop its airport 13. certification manual?4 How much did it cost your airport to develop a snow and ice 15. control plan? How much did it cost did your airport to develop its certificate 16. application? Total Initial Costs $1,462,733 $1,462,733 $784,390 $1,516 $2,248,640 15 15 15 15 15 15 38% 50% 100% 65% 100% $8,338,000 $8,338,000 $5,883,000 $23,000 $14,244,000 Recurring Costs What capital expenditures were required for compliance with the 11. Part 139 ARFF requirements?5 How much did it cost your airport to modify its perimeter fencing 12. in order to comply with Part 139?4 How much did it cost your airport use to develop its airport 13. certification manual? How much did it cost your airport to develop a snow and ice 15. control plan? Total Recurring Costs $575,000 $10,000 $585,000 15 15 15 15 15 38% 50% 100% 65% $3,278,000 $75,000 $0 $0 $3,353,000 1 Airports holding limited certificates in 2004 are classified as newly certificated airports 2 Interquartile mean cost, unless otherwise indicated 3 Unless otherwise indicated, percentage of airports is based on Phase 1 survey results 4 Single airport response. Value of response used. 5 Interquartile mean cannot be calculated for items with less than three responses. Arithmetic mean value used The estimates are based on small samples â one or two airports, and therefore may have limited reliability. For two requirements, no newly-certificated airport reported costs. However, based on the results from existing certificate holders, the costs of these requirements is likely modest. Also, the potentially affected population of small hub and non-hub airports is only 15 airports. Total initial costs are $14.2 million and total recurring costs are $3.4 million. The requirement Page TA-123
with the highest initial costs is the ARFF requirement at $8.3 million. This requirement also had the highest recurring cost at $3.3 million. The ARFF requirement also had the highest initial and recurring cost per airport. The high initial costs probably reflect acquisition of additional equipment and construction of new ARFF facilities. The high recurring costs may reflect additional staff costs to meet new requirements for response time or to staff new or expanded ARFF fleets. Table TA-33 presents the estimated industry cost of compliance with the Part 139 amendments for existing certificate holders. Total initial costs are $133.9 million, and recurring costs are $3.2 million. Compliance with new ARFF requirements is the most costly at $106 million in initial costs and $2.6 million in recurring costs. The ARFF requirements also the have the highest per airport costs. As with newly-certificated airports, the high initial costs probably reflect acquisition of additional equipment and construction of new ARFF facilities. The high recurring costs may reflect additional staff costs to meet new requirements for response time, or to staff expanded ARFF fleets. Table TA-33. Industry Costs of Compliance with Part 139 Amendments for Existing Certificate Holders1 Question(s) Average Cost ($)2 Airports Subject to Requirement Estimated Industry Cost of Compliance ($) Percentage of Airports Impacted by Requirements3 Industry Cost ($) Initial Costs 17. For airports holding an Airport Operating certificate in 2004, when the FAA amended Part 139, was there a cost to the airport to modify any of the following: Cost per Airport a. ARFF facilities, vehicles, equipment, staffing or procedures? b. Modify perimeter fencing? c. Modify the airport certification manual?4 d. Modify the snow and ice control plan? Total Initial Costs $998,360 $257,706 $3,136 $1,871 $1,261,074 295 295 295 295 36% 35% 100% 61% $106,026,000 $26,608,000 $925,000 $337,000 $133,896,000 Recurring Costs For airports holding an Airport Operating certificate in 2004, when the FAA amended Part 139, was there a cost to the airport to 17. modify any of the following: a. ARFF facilities, vehicles, equipment, staffing or procedures? b. Modify perimeter fencing? c. Modify the snow and ice control plan? Total Recurring Costs $24,083 $5,000 $563 $29,646 295 295 295 36% 35% 61% $2,558,000 $516,000 $101,000 $3,175,000 1 Airports holding limited certificates in 2004 are classified as newly certificated airports 2 Interquartile mean cost, unless otherwise indicated 3 Unless otherwise indicated, percentage of airports is based on Phase 1 survey results 4 Under terms of regulation, 100 percent of airports were required to develop new certification manuals B.3 Vehicles in Aircraft Operations Areas Table TA-34 presents the estimated industry costs of compliance with new requirements for vehicle operation in the aircraft operations area. Total initial costs are $118.4 million, and total recurring costs are $48.3 million. Compliance with enforcement and control requirements has both the highest initial industry cost ($101.8 million) and highest recurring industry cost ($29.2 million). These requirements has the highest per airport costs in this category as well. Page TA-124
The high initial costs likely represent upgrades to facilities and equipment to support better control over vehicle access. The high recurring costs likely represent operational costs of ongoing security patrols and staffing of vehicle checkpoints. Table TA-34. Industry Costs of Modifications to Requirements for Vehicle Operation in Aircraft Operations Area Question(s) Average Cost($)1 Airports Subject to Requirement Estimated Industry Cost of Compliance Percentage of Airports Reporting Impact2 Industry Cost ($) Initial Costs Since the beginning of CY 2000, how much did it cost your airport to modify any policies or procedures related to vehicle operation in the Aircraft Operations Area as it relates to any of the 5. following? a. Vehicle Access b. Vehicle inspection and marking c. Driver training curriculum d. Emergency operations e. Enforcement and control Total Initial Costs $22,227 $12,014 $6,459 $26,933 $450,000 $517,634 310 310 310 310 310 88% 60% 92% 77% 73% $6,064,000 $2,235,000 $1,842,000 $6,429,000 $101,835,000 $118,405,000 Recurring Costs Since the beginning of CY 2000, how much did it cost your airport to modify any policies or procedures related to vehicle operation in the Aircraft Operations Area as it relates to any of the 5. following? a. Vehicle Access b. Vehicle inspection and marking c. Driver training curriculum d. Emergency operations e. Enforcement and control Total Recurring Costs $11,144 $16,200 $3,040 $51,230 $128,992 $210,606 310 310 310 310 310 88% 60% 92% 77% 73% $3,040,000 $3,013,000 $867,000 $12,229,000 $29,191,000 $48,340,000 1 Interquartile mean cost, unless otherwise indicated 2 Percentage based on Phase 1 survey results unless otherwise indicated B.4 PFC Requirements Table TA-35 presents the estimated industry costs of compliance with selected PFC requirements adopted during the study period. Page TA-125
Table TA-35. Industry Cost of Changes to PFC Requirements Question(s) Average Cost($)1 Airports Subject to Requirement Estimated Industry Cost of Compliance Percentage of Airports Reporting Impact2 Industry Cost ($) 24. What was the annual reduction in net PFC revenue due to the FAA's $7,067 260 100% $1,837,000 increase in carrier compensation?3 35. How much in additional costs your airport incur to prepare the application or amendment to comply with new FAA requirements on documentation of costs issued on that date (PFC Update 50-06)? $17,167 260 18% $807,000 48. Has your airport experienced any costs due to FAA staff requesting the airport or the airportâs PFC consultant to provide any additional data, documentation or analysis to assist them in meeting the requirements of PFC Update 59-09? $6,333 260 19% $314,000 Total Cost of Requirements Applicable to All Airports $30,567 $1,121,000 27. What are the airport's cost savings per PFC application or amendment request as a result of the new filing procedures? (Non-hub airports) $2,300 188 19% $82,000 $1,039,000 Net Costs 1 Interquartile mean cost, unless otherwise indicated 2 Unless otherwise indicated, percentage of airports is based on Phase 1 survey results 3 Under terms of regulation, 100 percent of airports were required to pay the new rate of carrier compensation. The change in required carrier compensation had the highest dollar impact to the industry at $1.8 million. However, this figure represents an annual reduction in net PFC revenue received by airports. The requirement increases the time it takes for an airport to accumulate a specified amount of PFC revenue, but does not reduce the total amount of PFCs an airport can collect. For the two program changes that increased airport expenditures on the PFC program, total industry costs are $1,121,000. Non-hub airports are saving $82,000 from the non-hub pilot program. Net industry costs are thus $1,039,000. B.5 DBE Requirements Table TA-36 presents the estimated industry costs of changes to the DOTâs DBE requirements during the study period. Total initial costs are $2.8 million and total recurring costs are $2.2 million. The recurring costs of modification to the DBE project participation rule are equal to the initial costs. The reason for this is unclear. Page TA-126
Table TA-36. Industry Costs of DBE Rule Changes Question(s) Average Cost($)1 Airports Subject to Requirement Estimated Industry Cost of Compliance Percentage of Airports Reporting Impact2 Industry Cost ($) Initial Costs Was there a cost to your airport as a result of the DOTâs issuance of modified regulations for the Airport Concession DBE Program 20. in 2005? Was there a cost to your airport resulting from the DOTâs issuance in 2003 of modified regulations for DBE participation in 21. federally funded projects? Total Initial Costs $7,620 $11,000 $18,620 310 310 44% 52% $1,039,000 $1,773,000 $2,812,000 Recurring Costs Was there a cost to your airport as a result of the DOTâs issuance of modified regulations for the Airport Concession DBE Program 20. in 2005? Was there a cost to your airport resulting from the DOTâs issuance in 2003 of modified regulations for DBE participation in 21. federally funded projects? Total Recurrent Costs $2,900 $11,000 $13,900 310 310 310 44% 52% $396,000 $1,773,000 $2,169,000 1 Interquartile mean cost, unless otherwise indicated 2 Unless otherwise indicated, percentage of airports is based on Phase 1 survey results B.6 Miscellaneous FAA Administrative Requirements Table TA-37 presents the estimate of industry cost of miscellaneous AIP administrative requirements. Total initial costs are $57.8 million, and total recurring costs are $5.9 million. Changes to consultant selection requirements have the highest initial industry costs at $29.3 million. GIS requirements are almost as costly with industry costs of $28.4 million. GIS requirements generate the highest recurring cost ($5.6 million) and have the highest per airport initial and recurring costs. Total costs for consultant selection are higher because a higher number of airports reported being affected. Page TA-127
Table TA-37. Industry Costs of Miscellaneous AIP Administrative Requirements Question(s) Average Cost($)1 Airports Subject to Requirement Estimated Industry Cost of Compliance Percentage of Airports Reporting Impact2 Industry Cost ($) Initial Costs How much did it cost your airport to comply with the new guidance issued on September 30, 2005, by the FAA on the 32. subject of consultant selection (AC 150/5100-14D)? Has much has it costs your airport to conduct or engage consultants to conduct survey, mapping or charting work using Geospatial Information System (GIS) techniques or methodology 40. in response to FAA guidance or requirements on this subject? How much did it cost your airport to prepare a revised snow and ice control plan in response to a new AC issued by the FAA on 45. December 8, 2008 (AC 150/5200-30C)? How much did it cost your airport to prepare or update an Airport Emergency Plan in response to guidance issued by the FAA on 54. May 21, 2010 (AC 150/5200-31C)? Total Initial Costs $157,500 $176,000 $639 $4,490 310 310 310 310 60% 52% 61% 95% $29,295,000 $28,371,000 $121,000 $1,322,000 $57,787,481 Recurring Costs How much has it cost your airport to conduct or engage consultants to conduct survey, mapping or charting work using Geospatial Information System (GIS) techniques or methodology 40. in response to FAA guidance or requirements on this subject? How much did it cost your airport to prepare a revised snow and ice control plan in response to a new AC issued by the FAA on 45. December 8, 2008 (AC 150/5200-30C)? How much did it cost your airport to prepare or update an Airport Emergency Plan in response to guidance issued by the FAA on 54. May 21, 2010 (AC 150/5200-31C)? Total Recurring Costs $35,000 $150 $867 310 310 310 52% 61% 95% $5,642,000 $28,000 $255,000 $5,925,000 1 Interquartile mean cost, unless otherwise indicated 2 Unless otherwise indicated, percentage of airports is based on Phase 1 survey results C. Industry Cost Impacts of General Environmental Requirements Industry costs for the general environmental requirements are based on the data reported in the Phase 2 survey, and not specifically the incremental cost for the requirements adopted during the study period. Total costs of compliance with general environmental requirements are $57.4 million. The most expensive requirements relate to above-ground storage tanks (ASTs) with a cost of $16.4 million. Operation of ASTs are subject to various regulatory programs. The costs are reported in two separate tables in the following sections, but were counted only once as part of the total industry cost. C.1 Air Quality â General Conformity Amendments Table TA-38 presents the estimated industry costs for air emission inventories and the effects on costs from modifications to general conformity requirements. Total industry cost of air emission inventories is $704,000. The share of industry costs attributable to the general Page TA-128
conformity requirements is $117,000, as discussed in Technical Appendix 3. The most expensive component was attributed to completing the inventory itself at total industry cost of $524,000. The share of this cost attributable to the general conformity requirements is $87,000. Table TA-38. Industry Costs for Air Emission Inventories Average Cost ($)1 Estimated Industry Cost of Compliance Share of Costs Attributable to PM2.5 Airports Subject to Requirement Percentage of Airports Impacted by Requirements2 Industry Cost ($) Average Share of Cost Industry Share of Cost Of those plans/documents that have been prepared for activities/operations at the airport, please enter the requested follow- 56. up information: Air Emissions Inventory a. Initial cost to prepare plan, document, or report b. Installation/construction for control(s)/equipment/mitigation/remediation3 c. Specialized training3 Total Costs $5,833 $1,000 $1,000 $7,833 310 310 310 310 29% 29% 29% 29% $524,000 $90,000 $90,000 $704,000 $972 $167 $167 $1,306 $87,000 $15,000 $15,000 $117,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Single airport response. Value of response used. C.2 Air Quality â Hazardous Air Pollution Requirements Table TA-39 presents the estimated industry costs for ASTs and underground storage tanks (USTs) and the cost impacts from modifications to hazardous air pollution requirements. Total costs for AST requirements are $16.4 million. The cost for installation of controls, equipment is $13.4 million or 82% of the total. Industry cost for UST requirements is only $109,000, which is fully attributable to the cost of consultants or contractors. Table TA-39. Industry Costs for ASTs and USTs Average Cost ($)1 Estimated Industry Cost of Compliance Airports/Activity Subject to Requirement Percentage of Airports Impacted by Requirements2 Industry Cost ($) Of those activities the airport authority is responsible for, please 55 enter the requested follow-up information: Aboveground Storage Tanks (AST) a. Contractor/consultants b. Installation/construction for control(s)/equipment c. Material/equipment replacement d. Specialized training3 Total Costs $1,667 $63,333 $10,000 $2,750 $77,750 310 310 310 310 310 68% 68% 68% 68% 68% $351,000 $13,351,000 $2,108,000 $580,000 $16,390,000 Underground Storage Tanks (UST) a. Contractor/consultants b. Installation/construction for control(s)/equipment c. Material/equipment replacement d. Specialized training Total Costs $1,000 - - - $1,000 310 - - - 310 35% - - - 35% $109,000 - - - $109,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Interquartile mean value cannot be determined for items with less than 3 responses. Arithmetic mean value is used Page TA-129
C.3 Planning and Development â Emergency Planning and Response Requirements Table TA-40 presents estimated industry costs for preparation of Tier I/II reports under the EPCRA. Total compliance cost is $143,000, which is divided equally between initial document preparation cost and cost for controls, equipment, mitigation or remediation. Only one airport reported costs in the latter category, and therefore the results may not represent a reliable estimate of industry costs. Table TA-40. Industry Costs for Tier I/Tier II Reports Average Cost ($)1 Estimated Industry Cost of Compliance Airports/Activity Subject to Requirement Percentage of Airports Impacted by Requirements2 Industry Cost ($) Of those plans/documents that have been prepared for activities/operations at the airport, please enter the requested follow- 56. up information: Tier I/II Report a. Initial cost to prepare plan, document, or report b. Installation/construction for control(s)/equipment/mitigation/remediation3 c. Specialized training Total Costs $1,000 $1,000 - $2,000 310 310 - 310 23% 23% - 23% $71,000 $71,000 - $143,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Single airport response. Value of response used. C.4 Planning and Development â All Appropriate Inquiries (ESA) Requirements Table TA-41 presents estimated industry costs for environmental site assessments (ESAs). Total cost is $6.7 million. Of this amount, $2.9 million is attributed to the cost of preparing the assessments and $3.5 million to the cost of controls/equipment/ mitigation/remediation. The remaining amount is attributed to specialized training, but is based on a single response. Table TA-41. Industry Costs for Documents Related to All Appropriate Inquiries (Environmental Site Assessments) Average Cost ($)1 Estimated Industry Cost of Compliance Airports/Activity Subject to Requirement Percentage of Airports Impacted by Requirements2 Industry Cost ($) Of those plans/documents that have been prepared for activities/operations at the airport, please enter the requested follow- 56. up information: Phase I, II, or III Environmental Site Assessment a. Initial cost to prepare plan, document, or report b. Installation/construction for control(s)/equipment/mitigation/remediation c. Specialized training3 Total Costs $16,750 $20,000 $2,000 $38,750 310 310 310 310 56% 56% 56% 56% $2,908,000 $3,472,000 $347,000 $6,727,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Single airport response. Value of response used. Page TA-130
C.5 Waste Management â Hazardous Waste Requirements Table TA-42 presents estimated industry costs for compliance with waste management requirements. Combined costs of hazardous waste, universal waste and used oil requirements are $1.6 million. Universal waste requirements are the most costly with industry costs of $595,000. The cost savings associated with changes to record-keeping requirements for âofferors of hazardous materialsâ are negligible, as reported in Technical Appendix 3. Table TA-42. Industry Costs for Activities and Documents Related to Waste Management Average Cost ($)1 Estimated Industry Cost of Compliance Airports/Activity Subject to Requirement Percentage of Airports Impacted by Requirements2 Industry Cost ($) Of those activities the airport authority is responsible for, please 55. enter the requested follow-up information: Hazardous Material Generation/Storage/Disposal a. Contractor/consultants b. Installation/construction for control(s)/equipment3 c. Material/equipment replacement d. Specialized training Total Costs $2,733 $500 - - $3,233 310 310 - - 310 45% 45% - - 45% $381,000 $69,750 - - $451,000 Universal Waste Generation/Disposal $2,333 310 35% $253,000 a. Contractor/consultants b. Installation/construction for control(s)/equipment3 $400 310 35% $43,000 c. Material/equipment replacement4 $2,750 310 35% $298,000 d. Specialized training - - - - Total Costs $5,483 310 35% $595,000 Used Oil Generation/Recycling/Disposal $2,175 310 62% $418,000 a. Contractor/consultants b. Installation/construction for control(s)/equipment - - - - c. Material/equipment replacement4 $600 310 62% $115,000 d. Specialized training - - - - Total Costs $2,775 310 62% $533,000 Combined Cost of Waste Management Requirements $11,492 310 62% $1,579,000 Of those permits, certifications, or registrations the airport is subject to, or has applied for, please enter the requested follow-up 57. information: Offeror of Hazardous Materials a. Application/ certification/ registration (initial application and/or annual fee) b. Contractor/consultants c. Installation/construction for control(s)/ equipment d. Material/equipment replacement e. Specialized training3 Total Costs - - - - $1,000 $1,000 - - - - 310 310 - - - - 8% 8% - - - - $25,000 $25,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Single airport response. Value of response used. 4 Interquartile mean value cannot be determined for items with less than 3 responses. Arithmetic mean value is used Based on a single response, the small airport industry also spends $25,000 for specialized training required for entities considered âofferors of hazardous materialsâ. Page TA-131
C.6 Water Resources â Drinking Water Requirements Table TA-43 presents the estimated industry cost for compliance with drinking water supplier requirements. Total costs are $4.3 million, with $3.7 million spent for contractors and consultants. The estimates are based on a single response. Table TA-43. Industry Costs for Drinking Water Suppliers Average Cost ($)1 Estimated Industry Cost of Compliance Airports/Activity Subject to Requirement Percentage of Airports Impacted by Requirements2 Industry Cost ($) Of those activities the airport authority is responsible for, please 55. enter the requested follow-up information: Drinking Water Supplier a. Contractor/consultants3 b. Installation/construction for control(s)/equipment c. Material/equipment replacement3 d. Specialized training3 Total Costs $50,000 - $2,000 $6,350 $58,350 310 - 310 310 310 24% - 24% 24% 24% $3,720,000 - $149,000 $472,000 $4,341,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Single airport response. Value of response used. C.7 Water Resources âSPCC Rules Table TA-44 presents estimated industry costs for complying with the spill prevention control and countermeasures (SPCC) rule. Specific cost categories include ASTs, mobile refuelers, drum storage and handling, and preparation of SPCC plans. Compliance with AST requirements is the most costly at $16.4 million, with $13.4 million attributable to construction/installation of controls/equipment. Page TA-132
Table TA-44. Industry Costs for Activities and Documents Related to SPCC Amendments Average Cost ($)1 Estimated Industry Cost of Compliance Airports/Activity Subject to Requirement Percentage of Airports Impacted by Requirements2 Industry Cost ($) Of those activities the airport authority is responsible for, please 55. enter the requested follow-up information: Aboveground Storage Tanks (AST) a. Contractor/consultants b. Installation/construction for control(s)/equipment c. Material/equipment replacement d. Specialized training3 Total Costs $1,667 $63,333 $10,000 $2,750 $77,750 310 310 310 310 310 68% 68% 68% 68% 68% $351,000 $13,351,000 $2,108,000 $580,000 $16,390,000 Mobile Refueler Operations a. Contractor/consultants3 b. Installation/construction for control(s)/equipment c. Material/equipment replacement4 d. Specialized training3 Total Costs $7,800 $50,000 $50,000 $13,200 $121,000 310 310 310 310 310 17% 17% 17% 17% 17% $411,000 $2,635,000 $2,635,000 $696,000 $6,377,000 Drum Storage/Handling a. Contractor/consultants4 b. Installation/construction for control(s)/equipment4 c. Material/equipment replacement d. Cost for specialized training Total Costs $1,500 $1,500 $1,500 - $4,500 310 310 310 - 310 39% 39% 39% - 39% $181,000 $181,000 $181,000 - $544,000 Of those plans/documents that have been prepared for activities/operations at the airport, please enter the requested follow- 56. up information: Spill Prevention, Control and Countermeasure Plan a. Initial cost to prepare plan, document, or report b. Installation/construction for control(s)/equipment/mitigation/remediation c. Specialized training Total Costs $7,800 $5,750 $1,902 $15,452 310 310 310 310 80% 80% 80% 80% $1,934,000 $1,426,000 $472,000 $3,832,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Interquartile mean value cannot be determined for items with less than 3 responses. Arithmetic mean value is used 4 Single airport response. Value of response used. C.8 Water Resources â Pesticide Applicator Permit Requirements Table TA-45 presents estimated industry costs for pesticide application requirements. Total costs are 1.8 million, with $1.1 million attributed to material and equipment replacement. The latter figure is based on a single response and likely represents the cost associated with purchasing pesticides for use at the airport. Page TA-133
Table TA-45. Industry Costs for Activities and Documents Related to Pesticide General Permits Average Cost ($)1 Estimated Industry Cost of Compliance Airports/Activity Subject to Requirement Percentage of Airports Impacted by Requirements2 Industry Cost ($) Of those permits, certifications, or registrations the airport is subject to, or has applied for, please enter the requested follow-up 57. information: Pesticide Applicator a. Application/certification/ registration (initial application/annual fee)3 b. Contractor/consultants3 c. Installation/construction for control(s)/ equipment d. Material/equipment replacement4 e. Specialized training3 Total Costs $350 $5,100 - $10,000 $350 $15,800 310 310 - 310 310 310 36% 36% - 36% 36% 36% $39,000 $569,000 - $1,116,000 $39,000 $1,763,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Interquartile mean value cannot be determined for items with less than 3 responses. Arithmetic mean value is used 4 Single airport response. Value of response used. C.9 Water Resources â Construction Storm Water Requirements Table TA-46 presents estimated industry costs for compliance with construction storm water permitting requirements and standards. Costs for developing a construction storm water pollution prevention plan (CSWPP plan) and construction notice of intent (NOI) were reported separately. Total costs for construction NOIs at $12.1 million are more than five times higher than costs of preparing the CSWPP plan ($2.3 million). The costs for construction NOI compliance are based on samples of only one or two airports. Specialized training ($1.1 million) accounts for almost half of costs associated with CSWPP plans. Page TA-134
Table TA-46. Industry Costs for Activities and Documents Related to Construction Storm Water Requirements Average Cost ($)1 Estimated Industry Cost of Compliance Airports/Activity Subject to Requirement Percentage of Airports Impacted by Requirements2 Industry Cost ($) 56. Of those plans/documents that have been prepared for activities/operations at the airport, please enter the requested follow- up information: Construction Storm Water Pollution Prevention Plan a. Initial cost to prepare plan, document, or report b. Installation/construction of control(s)/equipment/mitigation/remediation3 c. Specialized training4 Total Costs $3,417 $2,000 $5,000 $10,417 310 310 310 310 71% 71% 71% 71% $752,000 $440,000 $1,101,000 $2,293,000 Construction Notice of Intent $50,030 310 48% $7,444,000 a. Application/certification/registration (initial cost and/or annual fee)4 b. Contractor/consultants4 $11,250 310 48% $1,674,000 c. Installation/construction of control(s)/equipment/mitigation/etc.3 $20,000 310 48% $2,976,000 d. Cost for material/equipment replacement - - - - e. Specialized training - - - - Total Costs $81,280 310 48% $12,094,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Single airport response. Value of response used. 4 Interquartile mean value cannot be determined for items with less than 3 responses. Arithmetic mean value is used D. Industry Cost Impacts of FAA/DOT Environmental Requirements Total costs of compliance are $67.1 million. Fifty-seven percent of the total cost is for NEPA compliance. D.1 NEPA Requirements Table TA-47 presents industry cost estimates for compliance with NEPA requirements. As with general environmental requirements, costs are the total costs for NEPA compliance reported in the Phase 2 survey, not incremental costs of requirements adopted during the study period. Page TA-135
Table TA-47. Industry Costs for NEPA Related Documents Average Cost ($)1 Estimated Industry Cost of Compliance Airports/Activity Subject to Requirement Percentage of Airports Impacted by Requirements2 Industry Cost ($) Of those plans/documents that have been prepared for activities/operations at the airport, please enter the requested follow- 56. up information: Categorical Exclusion (CATEX) a. Initial cost to prepare plan, document, or report b. Installation/construction of control(s)/equipment/mitigation/remediation c. Specialized training3 Total Costs $1,650 - $1,000 $2,650 310 - 310 310 65% - 65% 65% $332,000 - $202,000 $534,000 Environmental Assessment (EA) a. Initial cost to prepare plan, document, or report b. Installation/construction of control(s)/equipment/mitigation/remediation c. Specialized training Total Costs $59,602 $92,500 - $152,102 310 310 - 310 69% 69% - 69% $12,749,000 $19,786,000 - $32,535,000 Environmental Impact Statement (EIS) a. Initial cost to prepare plan, document, or report b. Installation/construction of control(s)/equipment/mitigation/remediation c. Specialized training3 Total Costs $42,500 $5,000 $500 $48,000 310 310 310 310 37% 37% 37% 37% $4,875,000 $574,000 $57,000 $5,506,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Single airport response. Value of response used. Costs for CATEXs are the lowest, at $534,000. This outcome is to be expected because of the very low reported average cost per airport ($2,600). Total industry cost for EAs are the highest at $32.6 million, which reflects the high average cost per airport and the high percentage of airports incurring costs (69%). $19.8 million of the total is attributable to the cost of mitigation and remediation measures. D.2 Sensitive Areas and Wildlife The survey questions did not specifically address the costs of recent FAA requirements for wildlife hazard planning, management and training. Rather, the survey included questions on handling of animal carcasses, which results from airport wildlife management activities. Table TA-48 provides the estimated industry costs. Total costs are $403,000, with more than half ($202,000) spent for contractors and consultants. Page TA-136
Table TA-48. Industry Costs for Wildlife-Related Activities Average Cost ($)1 Estimated Industry Cost of Compliance Airports/Activity Subject to Requirement Percentage of Airports Impacted by Requirements2 Industry Cost ($) Of those activities the airport authority is responsible for, please 55. enter the requested follow-up information: Animal Carcass Management a. Contractor/consultants b. Installation/construction for control(s)/equipment c. Material/equipment replacement3 d. Specialized training Total Costs $1,000 - $500 $500 $2,000 310 - 310 310 310 65% - 65% 65% 65% $202,000 - $101,000 $101,000 $403,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Single airport response. Value of response used. D.3 Noise Compatibility Requirements Table TA-49 presents estimated industry costs for the two requirements related to AIP- funded noise compatibility programs adopted during the study period. As noted in Technical Appendix 2, costs for compliance with changes in requirements for AIP-funded land acquisition are not presented because the data is unreliable. Total costs are $1.8 million, with $1.6 million attributed to the cost of updating noise exposure maps. Table TA-49. Industry Costs for Noise Compatibility Program Requirements Question(s) Average Cost($)1 Airports Subject to Requirement Estimated Industry Cost of Compliance Percentage of Airports Reporting Impact2 Industry Cost ($) Since the beginning of CY 2000, how much did FAA requirements cost your airport to update airport Noise Exposure Maps (NEMs) to justify issuing AIP grants for your noise compatibility program 7. or to provide documentation of the validity of your existing NEM? How much did it cost your airport to develop the noise land inventory and reuse plan as required by FAA Program Guidance 39. Letter (PGL) 08-02 (February 1, 2008)?3 Total Part 150 Compliance Costs $74,175 $3,600 $77,775 129 52 17% 100% $1,627,000 $187,000 $1,814,000 1 Interquartile mean cost, unless otherwise indicated 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Under terms of PGL, 100 percent of airports were required to develop noise land inventory & reuse plan certification manuals D.4 Industrial Waste Handling Requirements Table TA-50 presents estimated industry costs for complying with new FAA requirements for handling industrial waste adopted during the study period. Initial industry costs of $25.7 million are based on a single survey response. Recurring industry costs of $670,000 are based on a limited sample of two responses. Page TA-137
Table TA-50. Industry Compliance Costs for FAA Industrial Waste Requirements Question(s) Average Cost($)1 Airports Subject to Requirement Estimated Industry Cost of Compliance Percentage of Airports Reporting Impact2 Industry Cost ($) Initial Costs How much has it cost your airport to modify its policies, practices or procedures for disposing of industrial waste, including deicing fluid, as a result of FAA guidance issued on 41. September 8, 2008 (AC 150/5320-15A)?3 $306,881 310 27% $25,686,000 Recurring Costs How much has it cost your airport to modify its policies, practices or procedures for disposing of industrial waste, including deicing fluid, as a result of FAA guidance issued on 41. September 8, 2008 (AC 150/5320-15A)?4 $8,000 310 27% $670,000 1 Interquartile mean cost, unless otherwise indicated 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Single airport response. Value of response used. 4 Interquartile mean cannot be calculated for items with less than three responses. Arithmetic mean value used E. Industry Cost Impacts for Security Requirements Total costs of compliance with security requirements are $610.8 million. Seventy-nine percent of the total is for costs of physical access systems and other security equipment. E.1 Access Control and Security Equipment Table TA-51 presents estimated industry cost of compliance with requirements for access control and related security equipment. Total costs are $481.8 million. The largest single expense item is âother equipment or systemsâ, at $265.6 million, but this estimate is based on responses from only two airports. Table TA-51. Industry Cost for Installing Security Equipment or Systems Questions Average Cost ($)1 Estimated Industry Cost of Compliance Airports Subject to Requirement Percentage of Airports Reporting Impact2 Industry Cost ($) How much has it cost your airport to install or modify any of the following between January 1, 2000, and December 31, 2010, as a result of a new Transportation Security Administration (âTSAâ) regulation, security directive or other TSA or Department of Homeland Security 69 (âDHSâ) requirement? Physical Access System Closed Circuit Television ("CCTV" ) Monitoring System Credentialing and biometric (including biometric info on credentialing media) Any breach prevention systems or equipment3 Any perimeter security systems or equipment Any other equipment or systems related to access control3 Total Initial Cost $538,137 $234,617 $46,750 $62,500 $93,333 $1,260,000 310 310 310 310 310 310 78% 71% 56% 49% 58% 68% $130,122,000 $51,639,000 $8,116,000 $9,494,000 $16,781,000 $265,608,000 $2,235,337 $481,760,000 1 Interquartile mean cost unless otherwise indicated 2 Percentage based on Phase 1 survey results, unless otherwise noted 3 Interquartile mean cannot be determined for items with less than three responses. Arithmetic mean value is used. Page TA-138
E.2 Screening Facilities and Equipment Table TA-52 presents estimated industry costs for screening requirements, including Customs and Border Protection (CBP). Total costs for passenger and baggage screening are $122.1 million. Cost of CBP facility requirements is $6.9 million. The lower cost is based on both a low reported cost per airport and low percentage of airports affected. Table TA-52. Industry Costs for Screening and Inspection Projects Questions Average Cost ($)1 Airports Subject to Requirement Estimated Industry Cost of Compliance Percentage of Airports Reporting Impact2 Industry Cost ($) How much has it cost your airport to execute any project in the last 10 70 years to accommodate enhanced checked baggage screening? Total Project Costs How much has it cost your airport to execute any projects in the last 10 71 years to accommodate enhanced passenger screening? Total Project Costs Total Security Screening Costs Since the beginning of Calendar Year (CY) 2000, how much has the adoption or modification of Airport Technical Design Standards by U.S. Customs and Border Protection (CBP), or its predecessor cost 73 your airport? i. Total initial cost: $768,055 $637,377 $1,405,432 $375,000 29% 27% 6% $68,028,000 $54,101,000 $122,129,000 $6,920,000 1 Interquartile mean cost unless otherwise indicated 2 percentage based on Phase 1 survey results, unless otherwise noted F. Industry Cost Impacts of OSHA Requirements As noted in Technical Appendix 5, airports are not under the direct jurisdiction of OSHA. Rather, they may be subject to state regulation or voluntary programs. Some states maintain their own airport assistance programs. Total costs of compliance with OSHA requirements are $12.3 million. F.1 Typical Programs Generating OSHA Costs Table TA-53 presents the estimated industry cost for typical programs that generate OSHA costs. Total cost is $11.7 million. Payment to workersâ compensation insurance carriers is the largest single item with an industry cost of $8.8 million, but this estimate is based on a single airport response. Page TA-139
Table TA-53. Industry Costs of Typical Programs for OSHA Compliance Questions Average Cost($)1 Airports Subject to Requirement Estimated Industry Cost of Compliance Percentage of Airports Reporting Impact2 Industry Cost ($) How much has it cost your airport to add staff since 2000 to handle Occupational Safety and Health Administration (OSHA) related 58 activities?3 How much has it cost your airport to utilize your workers 61 compensation insurance carrier for health and safety support?3 How much has it cost your airport to track the amount of hours staff 63 spends in health and safety training? What is the cost of staff time in health and safety training? How much is the annual cost of personal protective equipment used by 64 your staff? Total Costs $25,000 $125,000 $9,138 $6,267 310 310 310 310 9% 23% 43% 50% $698,000 $8,765,000 $1,218,000 $971,000 $11,652,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Single airport response. Value of response used F.2 Use of Staff and Contractors for OSHA Related Activities Table TA-54 presents industry cost estimates for OSHA compliance associated with construction activity and work in confined spaces. Total costs are $670,000. Requirements for protection of workers entering confined spaces are the most costly ($481,000), but the estimate is based on only two responses. Table TA-54. Industry Costs for Use of Staff and Contractors for OSHA-Regulated Activities Questions Average Cost($)1 Airports Subject to Requirement Estimated Industry Cost of Compliance Percentage of Airports Reporting Impact2 Industry Cost ($) What is the cost of complying with health and safety requirements $3,875 310 40% $481,000 65 related to airport maintenance staff entering confined spaces?3 How much has it cost your airport to comply with health and safety 66 requirements related to new construction completed by airport staff?3 $1,500 310 26% $121,000 How much has it cost your airport to comply with health and safety requirements related to major building renovations completed by 67 airport staff? $1,000 310 22% $68,000 Total Costs $6,375 310 $670,000 1 Interquartile mean value unless otherwise noted 2 Percentage based on Phase 1 survey results unless otherwise noted 3 Interquartile mean value cannot be determined for items with less than three responses. Arithmetic mean value is used Page TA-140
