Environmental Management System Development Process (2013)

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15 IMPLEMENTATION PROCESS DIFFERENCES AND SIMILARITIES The airports reported using different implementation approaches for their EMS. Resources used to implement their EMS varied as shown in Figure 12. Fifteen of the 16 airports that are considering, implement- ing, or have implemented an EMS used or will use internal environmental staff. The one airport that reported not using internal environmental staff used a cross-functional develop- ment team, as did (or will) nine other airports. The use of a cross-functional team in developing an EMS was highly corre- lated with the answers for important benefits reported to have been achieved with the EMS (correlation coefficient 0.81). Thirteen included or will include their operations and mainte- nance staff in the implementation effort. However, including operations and maintenance staff did not appear to correlate with the number of benefits achieved. Three EMS included tenant representatives and/or stakeholder representatives in the effort. External resources included, or will include, consul- tants (11), training (five), and the purchase of EMS templates and software (three). One airport reported using internal train- ing and another used internal consultants from the government entity of which it is a part. In general, of the 12 respondents with an EMS, the envi- ronmental group was most often identified as responsible for developing the EMS. For one airport, however, the fuel- ing facilities and civil environmental engineering group was primarily responsible for EMS development; for another, the public works and transportation department group was responsible. The survey attempted to collect the cost of development and implementation, including internal labor costs, internal man hours, external costs, consultant costs, and hardware and software costs, from all airports that developed an EMS. Only half of these airports provided information on these costs, and responses were incomplete. However, internal labor costs were reported at under $100,000, although it is not clear if this was for both development and implementa- tion or simply implementation. As for internal staff hours, the responses ranged from unknown to about two full-time equivalents (FTEs), and up to 20,000 and 45,000 hours. The high labor hours were associated airports with larger staffs. CONTENT DIFFERENCES Specific elements or components of an EMS can vary. While the elements of each EMS vary slightly by airport, how each element is addressed shows greater variety. The survey found that all 16 airports that were consid- ering, developing, or had developed an EMS had most, if not all, of the elements identified as part of a generic EMS. Table 2 identifies the elements and quantifies how the air- ports include each element. Seven of the 12 airports that have implemented EMS include all the elements listed. Five of them did not identify chapter five SIMILARITIES AND DIFFERENCES IN APPROACH AND CONTENT Case Study: Incremental vs. Universal Implementation The cost to develop an EMS can vary broadly based on the magnitude of the system and the approach taken. Boston Logan (BOS) implemented an ISO 14001 EMS using a relatively low budget of $60,000, $10,000 of which was spent on internal labor and $50,000 that was spent on a consultant and a registrar. Boston Logan’s EMS, which was developed as part of Massport’s EMS Program, was limited to only part of its operations, the HVAC and boiler plants. The airport plans to expand its EMS incrementally facility by facility. This approach allows BOS to pilot an EMS and then cost-effectively expand the pilot to include other operations. The EMS developed at Dallas Love Field (DAL) is also ISO 14001 certified. It was developed as part of a massive city-wide effort to certify all Dallas government operations to ISO 14001. The cost for developing and implementing the entire city of Dallas EMS, covering 11 city departments and approximately 11,000 of the city’s 13,000 employees, was $11,000,000. It included not only DAL but all city operations, such as water and wastewater treatment, and solid waste operations. During development of the EMS, DAL assigned two people full-time to the project. The city of Dallas Office of Environmental Quality (OEQ) had ultimate responsibility for developing the city-wide EMS. The $11,000,000 included all of the costs for the consultant, registrar, hardware, software, and licenses.

16 external communications; four of those also reported that they did not include other elements. For example, two did not include work procedures or instructions. One airport did not include identification of impacts or risks, legal requirements, and emergency planning and response. Another airport did not include a management review. Each element in the generic EMS structure was then fur- ther examined for similarities and differences. The elements were set out fairly similarly to the structure of ISO 14001, as the PDCA structure is universally recognized as the appropri- ate structure for management systems. It is important to note that including all of the generic elements in their EMS does not necessarily mean the airports have met the ISO 14001 requirements (see chapter one, EMS Models). For discussion purposes, those who report that they include an element in their EMS, or intend to include an element in their EMS, are reported together with no differentiation. 15 13 11 10 5 3 3 3 2 0 2 4 6 8 10 12 14 16 Int er na l e nv iro nm en ta l s ta ff Op er ati on s a nd /o r m ain te na nc e s ta ff Ex te rn al co ns ult an ts Cr os s f un cti on al de ve lop m en t t ea m Ex ter na l tr ain ing Te na nt re pr es en ta tiv es St ak eh old er re pr es en ta tiv es Ex te rn al EM S t em pla te s o r s oft wa re Ot he r FIGURE 12 Resources used to implement the EMS. TABLE 2 SIMILARITIES AND DIFFERENCES IN EMS CONTENT EMS Components Considering or Thinking About an EMS Developing an EMS Have Developed an EMS Total Yes No Yes No Yes No Yes No Policy 2 1 1 0 12 0 15 1 Identification of Impacts or Risks 1 2 1 0 11 1 13 3 Legal Requirements 3 0 1 0 11 1 15 1 Goal Setting 2 1 1 0 12 0 15 1 Defined Roles and Responsibilities 3 0 1 0 12 0 16 0 Training: Awareness and Competency 3 0 1 0 12 0 16 0 Internal Communication 3 0 1 0 12 0 16 0 External Communication 3 0 1 0 7 5 11 5 Work Procedures or Instructions 1 2 1 0 10 2 12 4 Emergency Planning and Response 1 2 0 1 11 1 12 4 Monitoring and Measurement 3 0 1 0 12 0 16 0 Audits 2 1 1 0 12 0 15 1 Preventive and Corrective Action 2 1 1 0 12 0 15 1 Records and Documentation 3 0 1 0 12 0 16 0 Management Review 3 0 1 0 11 1 15 1 Source: First Environment, Inc.

17 Goals Fifteen of the 16 airports report goal-setting as an element in their EMS. Of those: • All include measurable environmental performance goals. The metrics used are specific to the goal. • Five include ACI-NA environmental goals. • The frequency with which goals are set ranges from quarterly to biannually, with the most frequent inter- val being yearly. Twelve of the 15 include the goal setting in the yearly planning and budgeting process, which is an indicator of integration of the EMS into airport activities. • Responsibility for achieving goals is shared with opera- tions and maintenance personnel in 14 cases. • At five airports, responsibilities for goals are also assigned to tenants and other operators, which is an indicator of a broad approach to the scope of the EMS. Roles and Responsibilities All 16 airports reported assigning roles and responsibilities in their EMS: • The majority, 11 airports, report assigning EMS respon- sibility between environmental and operations and main- tenance staff. However, of the 12 with implemented EMS, five report that in actuality the environmental department takes on most of the responsibility. • Environmental staff is assigned the greatest responsi- bility for the EMS at four airports. • Operations and maintenance is assigned the major respon- sibility at one airport; however, it reports that in actuality responsibilities are broadly shared. • Five airports include EMS responsibilities in job descrip- tions. Five include a designated contact for tenants and Policy All airports reported having an environmental policy except for one which is considering developing an EMS. This would indicate that most EMS do include a policy to set the expec- tations for the EMS. Environmental Impacts or Risks Identification and Evaluation Thirteen of 16 airports include identification of environmental impacts or risks in their EMS. Of the 13 airports that identify environmental impacts or risks: • All the airports identify the negative environmental impacts or risks. • Ten airports evaluate them quantitatively and three do not. • Approximately half include tenants’ and operators’ impacts and risks. • More than two-thirds include contractors’ impacts and risks. • Ten airports include the positive environmental impacts; three do not. Legal Requirements Fifteen of the 16 airports list legal requirements as part of their EMS. Of those 15: • Twelve provide compliance support to tenants and operators. In nine cases, this includes compliance train- ing, as well as tools and procedures. • Ten also provide compliance support to contractors. Of these, – six provide regulatory training, and – nine provide tools and procedures. Case Study: Assessing Aspects/Impacts/Risks— A Tale of Three Airports The approach to the identification of aspects and impacts of environmental risks varies widely. Some airports use a carefully defined quantification methodology while others use a more qualitative methodology. Some use cross-functional teams to evaluate and some limit assessment to the environ- mental department. At Toronto (YYZ), an ISO 14001 certified airport, the environmental department reviews the airport aspects yearly, examining any issues associated with the aspect that has occurred in the last year. The issues are then scored to determine those which are significant. The scoring addresses two components, the environmental risk and the business risk. Sub-categories under each type of risk are scored 1 to 5. Any aspect with an average risk of 3 or above is considered significant. No positive aspects are included. Miami Airport (MIA), also certified to ISO 14001, uses a qualitative method. Managers and personnel of various operations review their operations and identify areas of concern which are then considered significant. Miami includes positive as well as negative aspects in its assessment. Philadelphia has an EMS that is compliance focused. The EMS is not based on ISO 14001 or any other standard. To identify their environmental risks, they review their regulatory permits and National Environmental Policy Act (NEPA) issues. These are then ranked for importance by all of the departments at the airport, considering the regulatory and sustainability concerns associated with them. No positive impacts are included in the assessment.

18 other operators. Most (13) include an internal cross- functional advisory team. Only one included external stakeholders on this team. Training All 16 airports report that they provide EMS awareness and regulatory/compliance training. Personnel who receive such training are described in Figures 13 and 14. Internal Communication All of the 16 airports manage internal communication within their EMS; 13 maintain a website to provide access to EMS information, either on an intranet or an internet site. All share information on environmental performance. The majority shares this information very broadly within their own oper- ations. A few also share this information with parties such as tenants or contractors. Of the 16 airports, environmental performance is reported to the following: • management (15 airports), • environmental staff (15 airports), • maintenance staff (12 airports, • operations staff (11 airports), • administrative and finance staff (10 airports), • tenants (five airports). Individual airports also identified that they reported perfor- mance information to: • the board of directors, • construction consultants and contractors, • business partners. External Communication Only 11 of the 16 airports include External Communication within their EMS. Of these airports: • All communicate on an intranet site. • Seven provide a public report of environmental per- formance. • Four meet with tenants and other operators to report on environmental performance. • Three make publicly available their sustainability reports. • Three report on environmental performance at public meetings. • One provides a report on sustainability at public meet- ings; and Case Study: Westchester County Airport—A Technical Committee Structured to Meet the Strategic Intent of the EMS Westchester County Airport, which includes general and com- mercial aviation operations, has been operating since 1949. The airport is located partially within a watershed associated with a New York City and Westchester County drinking water reservoir. This results in a complicated regulatory regime involving the EPA, New York State Department of Environmental Conserva- tion, New York City Department of Environmental Protection, and the Westchester County Health Department. It is located within three municipalities, further adding to the complexity of compliance. Additionally, the airport exists in a community where the environment and its protection are highly valued. As a result of these issues, the airport exceeds its regulatory requirements with a long-standing groundwater monitoring program and a voluntary restraint-from-flying program that includes extensive community noise monitoring. It has also set up an airport advisory committee made up of stakehold- ers within the community. In 2001, in further response to community concerns, the airport committed to the develop- ment of an ISO 14001 EMS that would ensure stakeholder confidence in the environmental management of this facility and would include all parties that have the potential to impact the environment at the airport. It was decided that all airport operations, along with those of air carriers, tenants (FBOs, car rentals, corporate facilities, ground support, etc.), contractors, vendors, and eight county departments with airport responsibilities, would be included to meet the goal of exceptional environmental performance. A technical committee was set up to provide broad oversight and strategic direction to the EMS. The members included representatives from each of the eight county departments with airport responsibilities (planning, public works, public safety, health, environmental facilities, law, transportation, and infor- mation technology), a major tenant representative, an airline representative, the chairman of the airport advisory committee, and airport officials, including the environmental manager. The county department representatives were appointed by their respective commissioners and were responsible for ensuring the training and implementation of the EMS by their employees with airport responsibilities. The tenant and airline representatives articulated the broad interests of their groups in the decision-making process. In addition, each tenant and airline named a responsible employee who ensured that EMS training was provided and EMS responsibilities were met within their organizations. To support communica- tion among the participants, all parties were provided access to an intranet site with tools and training. In 2005, the EMS received an Environmental Achievement Awards Honorable Mention from Airports Council International.

19 16 14 14 11 10 9 8 5 0 2 4 6 8 10 12 14 16 En vir on m en ta l S ta ff Op er ati on s S ta ff M ain te na nc e S ta ff Em er ge nc y R es po ns e S ta ff Ma na ge me nt Ad m ini str ati ve an d F ina nc ial St aff Te na nt s a nd O th er O pe ra to rs Co nt ra cto rs FIGURE 13 Awareness training. 15 15 15 10 9 7 0 2 4 6 8 10 12 14 16 En vir on m en ta l S ta ff Op er ati on s S ta ff M ain te na nc e S ta ff Em er ge nc y R es po ns e S ta ff Te na nt s a nd O th er O pe ra to rs Co nt ra cto rs FIGURE 14 Compliance training.

20 • One prepares and submits a report based on the GRI guidelines. Emergency Response and Planning Twelve of the 16 airports included emergency response and planning in their EMS. Of those: • Nine airports identified environmental related planning and response as the responsibility of both emergency response and the environmental staff. • Two airports identified it as the responsibility of emer- gency response staff. • One airport identified it as the responsibility of environ- mental staff; and • Three airports include environmental personnel in Part 139 fire drills, which might be an indicator of inte- gration of the EMS with airport operations. Monitoring and Measurement All of the 16 airports include monitoring and measurement of the EMS: • Fifteen monitor and measure progress on goals. • Thirteen monitor and measure training; and • Thirteen monitor and measure non-compliances and/or nonconformances. All 16 airports surveyed also collect and report environmental performance data as shown in Table 3. Other performance measurements identified by individual airports included clean air vehicle conversions, monitoring of groundwater, site restorations, and air quality conformity. Twelve airports reported that they normalize performance data. One reports that it normalizes all performance data. Environmental Management System and Compliance Audits Fifteen of the 16 airports include audits as part of their EMS. • Eleven of the 15 airports perform EMS audits of the management system. – The frequency of the EMS audits varies from twice annually to every three years. Five audit annually, and one uses a variable schedule. • Twelve of the 15 airports perform compliance audits. – The frequency of compliance audits varies from quar- terly (one airport) to every three years (three airports). Five audit annually. One reported a variable schedule. • Six of the 15 airports require tenants to perform compli- ance audits. • Eight perform compliance audits on tenants. – The frequency of tenant compliance audits ranges from yearly (six airports) to up to three years. • Eleven airports evaluate audit findings for trends. Case Study: Denver—Internal Communication Denver International Airport (DEN) has implemented a cutting-edge approach to internal communications. DEN includes its business partners in its EMS. These partners include tenants and other operators such as airlines, rental car agencies, restaurants, fuel service providers, and air kitchens at the airport. DEN routinely distributes environmental achieve- ments and performance information to them electronically. Since these partners are within the scope of DEN’s EMS, these advisories are considered internal communications. The 2011 Annual Report “Managing the Environment at Denver International Airport” illustrates this approach. The report addresses environmental stewardship, the EMS, environmen- tal performance report card, sustainability with altitude, social and cultural programs at DEN, renewable energy (solar, waste management, greenhouse gases), and looking ahead. The report identifies DEN’s awards and recognition for 2011, and sets out its ambitions for environmental stewardship and the objectives in this arena; for example, becoming a zero waste facility by 2020 and carbon-neutral by 2050. Specifically for the EMS, DEN identifies its significant environmental aspects. The performance report card provides normalized data for energy use, waste generation, and collection of deicing fluids, including the baseline from past performance, the goal, and the actual performance. The report also addresses the improvements planned for the coming year, and reflects DEN’s view that sustainability should be fostered through its EMS. The report can be viewed at: http://business. flydenver.com/community/enviro/documents/annual Report2011.pdf.

21 Corrective and Preventive Action Fifteen of the 16 airports reported addressing corrective and preventive action in their EMS. Within the corrective and preventive action process: • 14 address audit findings; • 14 address environmental incidents; • seven address employee suggestions; • four address complaints from the public; • two address drill results; and • three airports independently identified that they address housekeeping issues such as labeling, storage, and clean- liness. • Ten of the 15 airports report that they use a formal root cause analysis process as part of their corrective and preventive action process. (For more information on using root cause methodologies, go to http://www. epa.gov/sectors/sectorinfo/sectorprofiles/shipbuilding/ module_15.pdf.) Potential participants in the root cause process are provided in Figure 15. Document and Record Controls All 16 airports have established or plan to establish and main- tain records as necessary for their EMS. Management Review Top management at 15 of the 16 airports reviews the airports’ EMS at planned intervals to ensure their effectiveness. TOOLS Eleven of the 12 airports with established EMS report using information technology tools to support their EMS. Performance Indicators CollectData Report Internally Report Externally Not Included Stormwater Quality/Quantity 14 13 13 0 Spills 14 14 10 0 Recycling 13 14 10 1 Solid Waste 13 12 10 2 Air Emission 12 12 11 3 Hazardous and Universal Waste 13 10 9 2 Wastewater Discharges 12 10 9 3 Energy Conservation 11 11 8 4 Energy Consumption 12 12 6 3 Deicing Chemicals Use 10 11 7 4 Chemical Use 10 10 7 4 Water Usage 12 10 5 3 Greenhouse Gas Reductions 9 10 8 5 Greenhouse Gas Emissions 10 9 8 4 Noise Levels 9 9 8 7 Petroleum Use 8 9 7 7 Noise Complaints 8 9 6 7 Noise Mitigation Efforts 8 8 7 8 Endangered Species 8 7 7 8 Water Conservation 9 9 4 6 Green Buildings 8 8 5 8 Green Purchasing 7 7 4 8 Renewable Energy/Green Energy Production 6 7 4 9 Habitat Restoration 4 6 6 9 Fines Associated with Environmental Noncompliance 6 5 4 9 Environmentally Sensitive Areas and Receptors 6 5 4 9 Renewable/Alternative Fuels Use 5 6 4 10 Environmental Related Spending 4 5 2 11 Climate Change Adaptation Efforts 2 3 2 13 Source: First Environment, Inc. TABLE 3 PERFORMANCE MONITORING

22 This includes the EMS database, shared drive, maintenance scheduling and tracking system, intranet or internet website, geographic information system, noise monitoring software, and flight tracking software. The tools used are as illustrated in Table 4. Access to the tools by type of tool is illustrated in Figure 16. Greatest access was provided to the environmental group with operations and maintenance close behind. Root cause is a methodology used to identify underlying causes of an incident, event, or undesired outcome that aims to find the proper corrective and preventive actions to remove those causes and ultimately prevent both a reoccur- rence of the incident and its potential occurrence in other parts of the organization. For more information on using root cause methodologies: (http://www.epa.gov/sectors/ sectorinfo/sectorprofiles/shipbuilding/module_15.pdf). Case Study: San Diego International Airport Uses GRI Reporting Guidelines San Diego International Airport (SAN) prepares its annual sustainability report based on the GRI guidelines. GRI, an international non-profit organization, provides a comprehen- sive sustainability reporting framework that enables all organi- zations to measure and report their economic, environmental, social, and governance performance. The guidelines can be found at https://www.globalreporting.org/resourcelibrary/ G3-Guidelines-Incl-Technical-Protocol.pdf. SAN’s report addresses the economic, environmental, and social criteria that the GRI guidelines suggest, as well as certain specific criteria from the GRI airport operators supplement. The SAN report includes metrics that track economical, environmental, and social performance. SAN’s environmental performance reporting specifically addresses: • waste reduction and recycling; • water conservation; • energy conservation; • air quality; • endangered species protection; • sustainable building methods; • noise issues; and • employee awareness. The report demonstrates SAN’s commitment to managing sustainability within its EMS. It is available on the SAN’s website and has social media buttons, making it easy to share. (http://sustain.san.org/wp-content/uploads/2012/05/Airport- Sustainability-Report_FINAL.pdf ). 0 En vir on m en ta l S ta ff Op er ati on s a nd M ain te na nc e S ta ff M an ag em en t Co nt ra cto rs Co ns ult an ts Co un ty D ep t. Pe rso nn el Te na nt s Un ion Re pr es en ta tiv es 1 2 3 4 5 6 7 8 9 10 FIGURE 15 Participants in root cause analysis.

23 EMS Tools Use Do Not Use EMS Database 11 1 Shared Drive 11 1 Maintenance Scheduling and Tracking System 10 2 Intranet or Internet Website 10 2 Geographic Information System 9 3 Noise Monitoring Software 8 4 Flight Tracking Software 7 5 Source: First Environment, Inc. TABLE 4 TOOLS IN USE 11 11 8 10 8 6 5 7 9 8 8 7 3 5 3 22 2 0 2 4 6 8 10 12 EMS Database Shared Drive Maintenance Scheduling and Tracking System Intra or internet website Geographic Information System Noise monitoring software Flight tracking software Environmental group Operations and Maintenance FIGURE 16 Access to tools.