Impact of Regulatory Compliance Costs on Small Airports (2013)

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43 This chapter discusses the environmental actions with the greatest potential to result in cost-related impacts to small airports. A more detailed analysis of the cost data obtained for environmental requirements appears in Technical Appendix 3. 4.1 Published Cost Estimates The research team found cost-related information from published sources for some of the regulatory environmental actions identified in the Federal Register notices and reports prepared to comply with EO 12866 and the RFA (refer to Section 3.1). Table A-2 presents available published cost infor- mation for the environmental requirements. Fourteen of the 39 items listed include specific cost projections. The remaining regulatory environmental actions either did not have a signifi- cant economic impact triggering an economic analysis or did not have cost-related publications prepared or obtainable. For some of the regulatory actions with cost data, it was possible to estimate the specific cost impact on each affected entity. For other regulatory actions, only annual national costs or annualized costs over a period of years was presented. Eleven of the regulatory actions with cost data had multiple cost components with costs projected separately for each component. A “rolled up” annual cost could not be calculated. Eleven regulatory actions had projections of minimal costs. For these actions a zero value was assigned in the cost column of Table A-2. There were no published cost estimates for 14 compliance actions (six regulatory actions, seven FAA Orders/ACs, and EO 13158). These actions are indicated by a dash in the cost column. 4.2 Airport Population Affected by Requirements The environmental actions identified for the study period encompass a variety of regulatory topics and programs. As with the other areas described in this report, identifying the airport population subject to environmental regulations adopted during the study period is not straightforward. For example, a regulatory requirement may apply to some airports but not others. When requirements apply, compliance is typically achieved on an airport-specific basis and based on existing infrastructure and feasible/cost-effective best management practices or controls. Compliance actions are influenced by the environment surrounding the airport and regional environ- mental concerns. Each airport’s level of upfront planning or coordination also varies, and this effort can ultimately affect overall costs. As a result, the Phase 1 survey questions did not focus exclusively on the requirements adopted during the study period. Rather, the questions were related to typical activities; plans or documents; and permits, certifications, or registrations related to the actions identified for the study period. The Phase 1 survey questionnaire identified 33 activities that could trigger environmental requirements in the areas addressed during the study period. Technical Appendix 3 presents data on the percentage of airports involved in each of the activities. Figure 21 summarizes responses to the questions and activities for which cost data is discussed in this chapter. The Phase 1 survey questionnaire identified 13 environ- mental plans or documents that airport operators might be required to prepare; the data on the percentage of airports actually preparing these documents and plans is presented in Technical Appendix 3. Figure 22 summarizes the results for the nine environmental plans or documents for which cost data is discussed in this chapter. The Phase 1 survey questionnaire identified 16 typical permits, certifications, or registrations applied for or held by airports to meet regulatory requirements. Technical Appen- dix 3 provides data on the percentage of airports that reported holding or applying for these documents. Figure 23 provides the participation rates for the four items for which cost data was collected in the Phase 2 survey. The full impact of regulatory changes in some cases may depend not only on the regulatory changes themselves, but C H A P T E R 4 Cost Impacts from Environmental Requirements

44 0% 10% 20% 30% 40% 50% Airports 60% 70% 80% 90% 100% Aboveground Storage Tanks (AST) Animal Carcass Management Used Oil Generation/Recycling/Disposal Hazardous Material Generation/Storage/Disposal Drum Storage/Handling Universal Waste Generation/Disposal Underground Storage Tanks (UST) Drinking Water Supplier Mobile Refueler Operations Figure 21. Airport operator participation in environmentally regulated activities for which cost data was generated. 0% 10% 20% 30% 40% 50% Airports 60% 70% 80% 90% 100% Spill Prevention, Control, and Countermeasure Plan Environmental Assessment (EA) Phase I, II, or III Environmental Site Assessment Environmental Impact Statement (EIS) Tier I/II Report Construction Stormwater Pollution Prevention Plan Categorical Exclusion (CATEX) Part 150 or 161 Study Air Emissions Inventory Figure 22. Airport participation in preparing environmental plans and documents for which cost data was generated. 0% 10% 20% 30% Airports 40% 50% 60% Construction Notice of Intent Bulk Fuel or Chemical Storage Tank Registration Pesticide Applicator Offer of Hazardous Material Figure 23. Airports applying for or holding environmental permits, certifications, or registrations for which cost data was generated.

45 also on links between airport operations like those listed in Figure 21 and documents listed in Figures 22 and 23. Particu- larly, rule amendments and regulatory guidance related to the SPCC rule, stormwater programs, NEPA documentation for airport actions, and environmental site assessments (ESAs) were promulgated during the study period. A summary of the regulatory changes is provided in the following sections. A summary of other regulatory changes made during the study period is provided in Technical Appendix 3. 4.2.1 Bulk Oil Storage Operations and Spill Prevention, Control, and Countermeasure The SPCC rule was 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 subject to the rule. Amendments with a potential impact on airport costs included the following: • Exemptions • Administrative Requirements • Plan Certification • Records and Testing A total of 80 percent of airports responding to the Phase 1 survey reported an SPCC plan was prepared for their opera- tions (Figure 22). Operations or activities related to the air- port’s SPCC program (Figure 21) include: • Aboveground storage tanks—68 percent • Underground storage tanks—35 percent • Mobile refuelers—17 percent • Drum storage and handling—39 percent In addition to the federal SPCC regulations, state or local agencies may require bulk fuel or oil storage tanks to be registered with the agency. A total of 41 percent of airports reported being responsible for registering bulk storage tanks (Figure 23), which may include chemical storage. Chemical storage tanks are not subject to state registration requirements for petroleum storage. 4.2.2 Construction Stormwater Requirements EPA and/or state environmental/natural resource agencies require notification prior to commencement of development activities through submittal of a notice of intent (NOI) for stormwater runoff from construction sites. As part of autho- rization under the NOI, most state agencies also require preparation and implementation of a construction stormwater pollution prevention (SWPP) plan to minimize impacts on stormwater discharges from construction sites. Prior to 2009, numeric effluent limitation guidelines (ELGs) were not estab- lished for stormwater discharges. On December 1, 2009, EPA established a numeric ELG for stormwater discharges from construction sites. However, EPA has stayed the numeric limitation pending future rulemaking. FAA AC 150/5370-10, Specifying Construction of Airports, was also issued during the study period and primarily incorporates information related to airport safety, design, and construc- tion standards. The AC also incorporates information related to controls to implement during earthwork activities to help minimize stormwater pollution. Use of the AC is mandatory for AIP- or PFC-funded projects. Construction activities at an airport of any size are almost inevitable, and 48 percent of airports responding to the Phase 1 survey reported preparing a construction NOI (Figure 23). Seventy-one percent of airports also reported preparing a construction SWPP plan (Figure 22). 4.2.3 National Environmental Policy Act Requirements The FAA relies on two guidance documents in its implemen- tation of NEPA. Order 1050.1E, Environmental Impacts: Policies and Procedures, sets the agency-wide protocol for implementing NEPA. The FAA updated this order twice during the study period (Table A-2, Items 24 and 25). Order 5050.4B, NEPA Implementing Instructions for Airport Actions (2006), supple- ments 1050.1E and provides specific guidance for evaluating potential environmental effects resulting from major FAA actions affecting airports (Table A-2, Item 26). The revisions to the two orders updated thresholds for impacts requiring additional analyses and added new projects to the list of Categorical Exclusions (CATEX). The analyses to support NEPA are tailored to the type of project and necessary documents that demonstrate the FAA has appropriately evaluated the environmental impacts of a proposed action and its reasonable alternatives. Specifically, a CATEX applies to actions that do not individually or cumula- tively have a significant effect on the environment. Most FAA actions affecting airports qualify for a CATEX. If the proposed action does not meet the criteria for a CATEX, preparation of an Environmental Assessment (EA) begins. If no significant impacts are identified from the EA, the FAA will issue a “finding of no significant impacts,” and the airport is able to undertake the action. If significant impacts are iden- tified or likely based on the type of action, an Environmental Impact Statement (EIS) may be required. Projects such as major runway extensions trigger an EIS.

46 In the Phase 1 survey, the following percentages of airports reported participating in the NEPA review process (Figure 22): • Categorical Exclusion—65 percent • Environmental Assessment—69 percent • Environmental Impact Statement—37 percent As expected, a higher percentage of small airports report completing a CATEX and EA compared to an EIS. Proposed projects qualifying for an EIS are generally limited at small airports primarily based on the level of operations and need for new or updated facilities. The higher percentage of air­ ports participating in EAs than participating in CATEXs is not consistent with the overwhelmingly high percentage of FAA actions affecting airports qualifying for a CATEX. The most likely explanation is that in many cases, the FAA can make the CATEX determination without the airport’s participation. 4.2.4 All Appropriate Inquiries (Land Acquisition) 40 CFR Part 312 establishes procedures to protect poten­ tial property purchasers from buying property that may have existing environmental contamination under the Comprehen­ sive Environmental Response, Compensation and Liability Act (CERCLA). The rule includes criteria for innocent land­ owner defense through conduct of “all appropriate inquiries” (AAI) into the previous ownership and uses of the property. EPA amended the AAI standards three times during the study period. Airports must provide a Certificate of Environmental Site Assessment to the FAA after conducting a Phase 1 ESA when purchasing properties using AIP funds. Airports should also consider performing ESAs when purchasing any property as a standard practice to prevent encumbering liabilities of previous owner’s activities. Fifty­six percent of airports responded that an ESA has been prepared (Figure 22). 4.2.5 FAA Noise Compatibility Program (including land acquisition) The FAA Noise Compatibility Program (14 CFR Part 150) provides funding for airports to develop and implement noise compatibility programs. The purchase of land for noise com­ patibility or for development is subject to uniform federal requirements on land acquisition. The FAA treats the admin­ istration of the land acquisition requirements as an environ­ mental issue. Thirty­seven percent of airports reported a noise study was conducted (Figure 22). During the study period, the FAA issued two PGLs related to Part 150—PGL 03­02 (November 12, 2003), requiring peri­ odic updates or revalidation of noise exposure maps (NEMs) (Table A­1, Item 23), and PGL 08­02 (February 1, 2008), requir­ ing development of noise land reuse plans for land acquired for noise compatibility with AIP funds (Table A­1, Item 101). The DOT implements the land acquisition through regulation 49 CFR Part 24. The DOT amended Part 24 during the study period, and the FAA’s Airport Planning and Environmental Division revised its implementing guidance to incorporate the rule changes (Order 5100.37B) (Table A­1, Items 148 and 69, respectively). The amendments to the regulation were intended to bring Part 24 up to date, improve service to property owners, and reduce the costs of government regulation. Figure 24 summarizes the percentage of airports affected by these modifications. Seventeen percent of responding airports reported revising their NEMs in response to the new guidance on this subject. Sixteen percent reported acquiring noise land with AIP funds and were potentially required to complete a noise reuse plan. 17% 21% 85% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% NEM Update Requirement New Requirements for Federally Assisted Land Acquisition Ai rp or ts A ff ec te d Noise Land Reuse Plan Requirement (Airports with Noise Land) Figure 24. Airports affected by modifications to noise compatibility and land acquisition requirements.

47 Eighty-five percent of these airports had done so. Forty percent of responding airports reported acquiring real property with AIP funds for any purpose and were potentially affected by the revisions to Part 24 and the implementing guidance. Twenty-one percent of these airports reported being affected by the revisions to the regulations and guidance on federally assisted land acquisition. 4.3 Unit Cost Estimates from Phase 2 Survey Results Questions for the Phase 2 survey built upon the Phase 1 information by focusing on initial/capital and ongoing operating costs associated with implementing an activity or preparing a plan/document/permit. The survey was also supplemented by telephone interviews and the case studies. Costs were totaled to indicate the overall costs associated with compliance, and not necessarily the incremental costs of new requirements or regulatory changes. It is important to note that reported costs related to operational activities may be incurred more than once (i.e., monthly, annually, etc.). The complete list of environmental actions and reported costs is presented in Technical Appendix 3. The following activities were determined to contribute to the majority of costs for the small airport population, based on the inter- quartile mean as the measure of average costs: • Bulk oil storage (aboveground storage tanks and mobile refuelers) • Construction stormwater • NEPA-related documents (EISs and EAs) • All appropriate inquiries (land acquisition) • Noise compatibility Table 7 summarizes the costs in each of the categories listed above. A total cost for each individual activity or requirement listed in the table is presented. In many cases, a particular activity or requirement may have multiple cost drivers. As with the FAA requirements in Chapter 3, each individual airport may not have experienced all of the cost drivers that contribute to the average total cost for a requirement. The table presents the interquartile mean as the measure of average costs and 25th- and 75th-percentile values to indicate the typical range of costs based on the interquartile range. The use of these measures is explained in Section 3.3. For bulk petroleum storage and SPCC plans, the installation of equipment and controls and equipment/material replace- ment for aboveground storage tanks and mobile refueler spill prevention are the primary reported cost drivers. The cost of the SPCC plan itself is relatively minor (less than 25 percent of the cost of complying with requirements for aboveground storage tanks and mobile refuelers). SPCC plan costs include annual training. The reported average annual cost of training is $4,000, as reflected in Technical Appendix 3. This result is higher than the range of published estimates for training costs ($1,930 to $3,650 per year). In contrast, for construction stormwater requirements, the initial registration/application requirements for a con- struction NOI are the primary cost driver ($50,000). The cost of required controls, equipment, or mitigation is modest but may increase as a result of compliance with future construc- tion stormwater ELGs. In addition, as reflected in Technical Requirement(s) Estimated Cost of Compliance 25th Percentile 75th Percentile Interquartile Mean Bulk Petroleum Storage and SPCC Plans Mobile refueler operations $87,100 $210,243 $121,000 Aboveground storage tanks $44,625 $128,125 $77,750 SPCC plan $5,328 $51,750 $15,452 Construction Stormwater Requirements Construction Notice of Intent $51,920 $110,640 $81,280 Construction SWPP plan $8,000 $19,000 $10,417 NEPA Requirements Environmental Assessment $44,000 $419,588 $152,102 Environmental Impact Statement $13,500 $378,000 $48,000 Categorical Exclusion $2,125 $3,325 $2,650 All Appropriate Inquiries Phase I, II, or III Environmental Site Assessment $33,250 $74,250 $38,500 Noise Compatibility Noise exposure map update requirement $25,250 $150,025 $74,175 Noise land inventory and reuse plan requirement $2,375 $29,051 $3,600 Table 7. Summary of per-airport costs of significant environmental requirements.

48 Appendix 3, the average cost of preparing and submitting a construction SWPP is only 12 percent of the total costs per airport reported for a construction NOI. However, the survey results are not consistent with airport field experience of pre- paring construction NOIs. This experience suggests that fees associated with NOI submittals are typically less than $500, with the contractor preparing the NOI and incorporating the fee into the contract price. As presented in Table 7, the total average cost for an EA was $152,102, more than three times higher than the average cost of an EIS at approximately $48,000. The greater costs reported for an EA are attributed to the additional mitigation or controls reported as part of proposed projects. Although studies, mitigation, and/or controls are also typically appli- cable to projects qualifying for an EIS, it appears that airports did not report this information for an EIS. However, the average cost of preparing the EA itself is reported at $60,000. This is 41 percent higher than the average cost of preparing an EIS ($42,500). The results are unexpected, because the pro- cedures and types of analysis required for an EIS is generally more detailed than what is required for an EA. The average cost associated with preparation of a CATEX ($2,650) is much lower compared to an EA or EIS. Inclusion of additional CATEXs and triggering thresholds in the updated FAA Orders, as discussed above, likely saved many airports money that would have been needed for an EA or EIS. The average cost of Phase I, II or III ESAs combined, as reflected in Table 7, is $38,500. This figure includes costs for controls, equipment, remediation, mitigation, and specialized training. The average published cost of preparing the ESA itself is $16,750. Estimated costs per Phase I ESA from the regulatory economic analysis ranged from $2,185 to $2,190. Costs for Phase I ESAs for airport and related properties based on industry experience are usually between $5,000 and $9,000. Thus, the survey results show a higher average cost than either agency projections or previous industry experience. The survey question requested airport costs to prepare either a Phase I, Phase II, or Phase III ESA. Therefore, the higher average in the survey could reflect the results of including more complex and costly Phase II or Phase III ESAs. For the noise compatibility requirements, survey questions focused on the incremental costs of the new requirements. A total per airport cost was not calculated because the com- pliance actions affected different populations of airports. Only one airport reported a cost for the changes to the land acquisition requirements. Therefore, the data is not included in the table. The average cost of the NEM update is more than 20 times higher than the cost of developing the noise land inventory and reuse plan. This result reflects the need to use a computer-based model, validated with noise exposure mea- surements, to complete the NEM update. 4.4 Relationship between Costs and Activity Levels Analyses were performed to determine any possible rela- tionship between the costs of environmental requirements and two measures of activity—passenger enplanements and commercial operations. Because the same airports did not respond to the same individual questions, correlation was evaluated for each aspect contributing to the overall compli- ance cost (e.g., separate analysis for document development, controls, and training). Correlation of costs was not evalu- ated for questions that had three or fewer responses because of the lack of statistical reliability of the results. Section 3.4 describes the process used to evaluate the relationship between requirements and activities in more detail. After excluding the highest and lowest costs, no relation- ship was found between environmental compliance costs and activity level measured by either enplanements or commercial operations. Of the most costly environmental compliance actions, four involve preparation of a plan, report, or study, which does not depend on airport operations or enplanements. For example, costs to develop an EA vary depending on the amount of data readily available, type of project, and level of coordination with public and regulatory authorities, etc., not on the number of operations or enplanements. For bulk storage operations, one might expect compliance costs to increase with fuel use, which in turn increases with airport operations or enplanements. However, some small airports contract out aircraft fueling and only utilize bulk storage tanks for minor equipment or vehicle maintenance activities. In these instances, costs are too small to be correlated with enplanements and operations. The number of responses for mobile refueler activities was too small to perform cor- relation analysis. 4.5 Industry Cost Impacts of Environmental Requirements Table 8 summarizes the industry cost impacts for the five categories of environmental requirements addressed in Table 7. Industry cost impacts for environmental require- ments were determined using the process described in Section 3.5. Cost per airport was used, because there did not appear to be a relationship between cost and activity (after accounting for the impact of outliers and qualitative considerations). Reported costs in many cases represent full compliance costs, not the incremental costs of modifications or new require- ments added during the study period. As shown, total indus- try costs for the significant environmental requirements are $94.5 million. The most costly compliance category is bulk petroleum storage and SPCC plans with an overall cost of

49 $26.6 million. The most costly individual requirement within this category relates to the operation of aboveground storage tanks at a cost of $16.4 million. This requirement had only the second highest cost on a per-airport basis ($77,750). Because of the high percentage of airports impacted by the requirement, industry costs are the highest. The least costly separate requirement is the preparation of a CATEX under NEPA. The low industry cost is a result of the low individual cost ($2,650) and the low percentage of airports required to provide CATEX documentation (37 percent). The average cost for preparation and submission of a construction NOI reported in the survey probably overstates the true industry average. Therefore the industry cost for con- struction NOIs is probably also overstated. For noise compatibility, the per-airport cost for the NEM update is 20 times higher than the cost of the noise land reuse plan requirement. The industry cost is only nine times higher because of the low number of airports affected by the NEM requirement. Technical Appendix 6 includes the estimates of industry costs for environmental requirements with lesser impacts. Additional requirements appear in Appendix B. The total industry costs for these items are $34,743,000. Combining this amount with the total costs presented in Table 8 results in total industry cost impact from environmental requirements of $129,226,000. 4.6 Funding Sources 4.6.1 Potential Funding Sources A variety of funding sources is potentially available to help airports finance environmental compliance costs. The AIP and the PFC program administered by the FAA are sources of funding for certain requirements. Other federal agencies may also provide funding, either directly or through state programs. State funding sources may also be available. A comprehensive discussion of federal and state funding sources for environ- mental initiatives is contained in ACRP Synthesis 24. AIP Funding The AIP statute explicitly provides for AIP eligibility of projects for compliance with the Clean Water Act and the Federal Water Pollution Control Act. Systems for collection of aircraft deicing fluid are also eligible. In addition, funds from the “Noise Set-Aside” established by 49 USC §47117 may be used for defined projects to comply with the Clean Air Act. Table 8. Summary of industry cost impacts of significant environmental requirements. Requirement(s) Estimated Cost per Airport (Interquartile Mean) Estimated Industry Environmental Cost Airports Subject to Requirement Airports Affected by Requirement1 Industry Env. Cost Bulk Petroleum Storage and SPCC Plans Aboveground storage tanks $77,750 310 68% $16,390,000 Mobile refuelers $121,000 310 17% $6,377,000 SPCC plan $15,452 310 80% $3,832,000 Total Cost $214,202 $26,599,000 Construction Stormwater Requirements Construction Notice of Intent $81,280 310 63% $15,874,000 Construction SWPP plan $10,417 310 71% $2,293,000 Total Cost $91,697 $18,167,000 NEPA Requirements Environmental Assessment $152,102 310 65% $30,648,000 Environmental Impact Statement $48,000 310 69% $10,267,000 Categorical Exclusion $2,650 310 37% $304,000 Total Cost $202,752 $41,219,000 All Appropriate Inquiries Phase I, II, or III Environmental Site Assessment $38,500 310 56% $6,684,000 Noise Compatibility Noise exposure map update requirement $74,175 129 17% $1,627,000 Noise land inventory and reuse plan requirement2 $3,600 52 100% $187,000 Total Costs $77,775 $1,814,000 Grand Total Significant Environmental Costs $94,483,000 1 Percentage based on Phase 1 survey results unless otherwise noted. 2 Per terms of PGL, all airports with AIP-funded noise land required to prepare inventory and plan.

50 The primary use of the Noise Set-Aside is to fund development of NEMs and development and implementation of noise compatibility programs under 14 CFR Part 150. The Noise Set-Aside was potentially available to defray a portion of any increased costs associated with the modifications to Part 150 program requirements, subject to certain conditions. If a development project is eligible for AIP funding, pre- paration of the EA or EIS is also eligible for AIP funding as a project formulation cost. Required mitigation measures may also be eligible for AIP funding. The AIP share of environmental projects at small airports was 95 percent during most of the study period. In FY 2012, the AIP share for most small airports was reduced to 90 percent. PFC Funding PFC eligibility for environmental requirements is com- parable to AIP eligibility. PFCs can be used to pay the local matching share of AIP-funded projects or can be used to pay the full costs of projects. One difference is that AIP funds (with limited exceptions) can be used to fund Part 150 noise compatibility projects only if the project is included in an FAA- approved noise compatibility program. PFCs can be used for a project that is eligible for approval under Part 150, even if it is not in an approved plan. Other Federal Funding Sources ACRP Synthesis 24, Table 1, summarizes federal funding opportunities for environmental initiatives. Eight other federal agencies provide environmental funding. For some of the fed- eral agencies or programs, funds are provided only for volun- tary actions, not for mandatory compliance actions. State Funding Sources State funds are also available for many environmental ini- tiatives. ACRP Synthesis 24, Table 2, summarizes state funding opportunities. Funding opportunities are listed by state and category of initiative. Many of the state program funds are available only for voluntary actions. State airport grant programs may also be available to fund environmental initiatives. These programs are also summarized in ACRP Synthesis 24, Table 2. 4.6.2 Use of Financial Assistance The Phase 2 survey requested information on cost of com- pliance with environmental requirements and the amounts funded by or received from third parties. Airports did not specify the sources of third-party funding. Several airports reported receiving funds from third parties for various envi- ronmental requirements, including the categories of envi- ronmental requirements discussed previously. The reported financial assistance is described in the following paragraphs. Additional information is provided in Technical Appendix 3. Bulk Oil Storage Operations and SPCC Two airports reported receiving third-party funds in the amounts of $17,300 and $61,750 to implement the airport’s SPCC program. In the first case, the amount was exactly equal to reported cost of preparing the SPCC plan and was 87 percent of the combined cost of the plan and equip- ment purchases or facility retrofits. In the second case, the amount was 95 percent of the reported cost of equipment purchase or retrofits. This percentage is consistent with receipt of an AIP grant for the capital costs associated with compliance. Construction Stormwater Requirements In many cases, stormwater controls implemented as part of an airport’s construction SWPP plan also meet the pollution prevention criteria for earthwork activities required under FAA AC 150/5370-10, Specifying Construction of Airports. Use of the AC is also mandatory for AIP- or PFC-funded projects. Two airports reported receiving funds associated with the construction SWPP plan from third parties in the amounts of $2,438 and $14,250. These funding amounts represented 97.5 and 95 percent of the cost of preparing the construction SWPP plan, respectively. These percentages are consistent with the receipt of an AIP grant by a small airport, with the former airport receiving additional assistance to cover one-half of the matching share requirement. If the projects triggering the construction SWPP plan were funded with AIP grants, the costs of developing the plan would have been eligible for AIP funding. National Environmental Policy Act Requirements Two out of six airports reporting costs for a CATEX also reported receiving third-party funding. One airport received 95 percent of the cost; the other received 97.5 percent. These percentages are consistent with the receipt of an AIP grant by a small airport, with the latter airport receiving additional assis- tance to cover one-half of the matching share requirement. Figure 25 depicts the number of airports reporting third- party funding for EAs and EISs. Because many projects trig- gering EAs or EISs are eligible for AIP funding, the figure presents the data in terms of the federal share of the costs of the EA or EIS. The airports reporting receipt of more than the federal share from third parties probably received additional assistance to pay for the local matching requirement.

51 An equal number of airports that conducted EAs received no third-party funding as received at least the full federal AIP share (six each). Three airports performing EISs received no third-party assistance, and three received at least the full federal share. The seventh airport that received third-party assistance received less than the full federal AIP share. All Appropriate Inquiries (Land Acquisition) Airports must provide an ESA certificate to the FAA after conducting a Phase 1 ESA when purchasing properties using AIP funds. Three airports reported funding was provided by a third party for work related to Phase I, II, and III ESAs. For two of the airports, the third-party payment was 95 per- cent of the total costs to prepare the ESA—a figure consistent with AIP funding. The third airport received 50 percent of the reported costs to perform the ESA. It is possible that this percentage represented the share of AIP funding provided by the FAA for the underlying land acquisition project, but the basis of funding cannot be determined with certainty. FAA Noise Compatibility Program Requirements Airports reported using only airport funds (other than PFCs) to fund development of noise land inventories and reuse plans. The analysis of funding for Noise Compatibility Program requirements focuses on the use AIP and PFC funds, similar to the analysis of other FAA requirements in Chapter 3. Figure 26 summarizes the use of AIP funds. Seven out of eight airports received the full federal share of funds for their NEM updates. One airport did not receive any AIP funding. Figure 27 summarizes the use of PFCs to fund compliance with the noise compatibility requirements. The same number of airports used no PFCs (four) as used some PFCs. The single airport that used PFCs for more than the local match funded its project entirely with PFCs. 0 1 2 3 4 5 6 7 None Less Than Federal Share Third-Party Funding Ai rp or ts Full Federal Share More Than Federal Share Environmental Assessment Environmental Impact Statement Figure 25. Third-party funding of NEPA documents. 1 0 7 None Less Than Federal Share Full Federal Share Use of AIP Funds Ai rp or ts 0 1 2 3 4 5 6 7 8 9 10 Figure 26. AIP funding levels for noise compatibility requirements.

52 Use of PFC Funds 0 Ai rp or ts 10 None Less Than Local Share Local Share Only More Than Local Share 4 1 2 1 1 2 3 4 5 6 7 8 9 Figure 27. PFC funding levels for noise compatibility requirements.