This is the accessible text file for GAO report number GAO-10-50 
entitled 'Aviation And The Environment: Systematically Addressing 
Environmental Impacts and Community Concerns Can Help Airports Reduce 
Project Delays' which was released on September 21, 2010. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as 
part of a longer term project to improve GAO products' accessibility. 
Every attempt has been made to maintain the structural and data 
integrity of the original printed product. Accessibility features, 
such as text descriptions of tables, consecutively numbered footnotes 
placed at the end of the file, and the text of agency comment letters, 
are provided but may not exactly duplicate the presentation or format 
of the printed version. The portable document format (PDF) file is an 
exact electronic replica of the printed version. We welcome your 
feedback. Please E-mail your comments regarding the contents or 
accessibility features of this document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

September 2010: 

Aviation And The Environment: 

Systematically Addressing Environmental Impacts and Community Concerns 
Can Help Airports Reduce Project Delays: 

GAO-10-50: 

GAO Highlights: 

Highlights of GAO-10-50, a report to congressional requesters. 

Why GAO Did This Study: 

The Federal Aviation Administration (FAA) estimates that the number of 
flights in the United States will increase 20 percent by 2024. It also 
has identified numerous airports that will need to expand to handle 
more flights. However, increasing airport capacity and operations 
poses potentially significant impacts on the environment and quality 
of life for surrounding communities. 

This report addresses (1) airports’ actions to reduce their 
environmental impacts, (2) the extent airports believe environmental 
issues delay development or operational changes, and (3) the 
strategies airports can adopt to address environmental issues. GAO 
reviewed pertinent federal laws and regulations; interviewed airport 
officials, state and local regulatory agencies, metropolitan planning 
organizations, and community groups for 10 selected airports, as well 
as federal officials and national industry and advocacy groups; and 
surveyed the 150 busiest airports as measured by the number of 
operations. This report does not contain recommendations. A draft was 
provided to the Department of Transportation, the Environmental 
Protection Agency, and two organizations representing airports and 
airport officials. GAO incorporated technical clarifications they 
provided as appropriate. 

What GAO Found: 

Almost all the airports GAO surveyed took some actions to address 
their environmental impacts in four key areas: reducing noise levels, 
controlling water pollution, reducing emissions, and using 
environmentally sustainable practices. These include voluntary 
actions, such as asking pilots and controllers to use aircraft 
operational procedures that lower noise levels, as well as actions 
required by federal and state laws, such as in the areas of 
controlling water and air pollution. Larger airports, which can have 
more environmental impacts, were more likely than other surveyed 
airports to take a wider range of actions, such as soundproofing homes 
or installing loading bridges that supply aircraft with electric power 
to lower engine usage and emissions. Finally, GAO found that airports 
were moving toward a more holistic approach to environmental 
management, including following environmentally sustainable standards 
and implementing an Environmental Management System (EMS). 

Less than half of the surveyed airports believe that addressing 
environmental issues somewhat or greatly delayed a development project 
(35 percent) or operational change (42 percent) at their airport over 
the last 5 years, even though the vast majority had undertaken a 
capital development project or operational change during this time 
period. Both the reported delay and the extent and significance of 
delay were determined by the responding airport. Less than half 
similarly believe that addressing environmental issues will cause 
delays in the next 5 years. More airports reported that they had been 
somewhat delayed than greatly delayed. Larger airports were somewhat 
less likely than all surveyed airports to believe that addressing 
environmental issues will cause a delay in development projects (30 
percent) or operational changes (36 percent). Addressing water issues 
and noise issues was the most commonly cited environmental issue that 
led to delay in implementing development projects and operational 
changes, respectively. 

A number of airports have adopted strategies to systematically address 
environmental impacts and community concerns, which can help both 
mitigate environmental impacts and anticipate and reduce problems with 
communities and other stakeholders that can lead to delays. Airports 
are integrating environmental considerations into their planning 
process, including 7 of the 10 airports GAO visited. Some airports are 
also finding success in streamlining the federal environmental review 
process and in integrating their EMS processes with the federal 
environmental review process. Finally, effective community outreach 
that solicits stakeholder input, fosters interactive communication 
with local communities, and evaluates its outreach efforts can help 
airports better anticipate and deal with community opposition. 

View [hyperlink, http://www.gao.gov/products/GAO-10-50] or key 
components. To view the E-supplement online, click [hyperlink, 
http://www.gao.gov/products/GAO-10-748SP]. For more information, 
contact Dr. Gerald L. Dillingham, (202) 512-2834, dillinghamg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Surveyed Airports Reported Taking a Variety of Actions to Reduce or 
Mitigate Their Environmental Impacts: 

Less Than Half of Airports That Undertook or Will Undertake Capital 
Projects or Operational Changes Believed Addressing an Environmental 
Objective Resulted in Delays: 

Several Environmental Strategies and Community Outreach Practices Can 
Help Airports Mitigate Delays and Address Environmental Issues: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: List of Airports That Responded to Our Survey and We 
Visited: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Figures: 

Figure 1: Examples of Possible Airport Environmental Effects: 

Figure 2: Variety of Airport Actions Taken to Address Aircraft Noise: 

Figure 3: Variety of Airport Actions Taken to Reduce Emissions: 

Figure 4: Variety of Airport Actions Taken to Address Water Pollution: 

Figure 5: Variety of Actions Taken to Become More Environmentally 
Sustainable: 

Figure 6: Example of Features from a LEED-Certified Terminal: 

Figure 7: Number of Airports That Have Undertaken or Will Undertake a 
Capital Development Project or Operational Change: 

Abbreviations: 

ACRP: Airport Cooperative Research Program: 

ACI-NA: Airports Council International - North America: 

AIP: Airport Improvement Program: 

ANCA: Airport Noise and Capacity Act: 

ASNA: Aviation Safety and Noise Abatement Act: 

ATC: Air Traffic Control: 

AAAE: American Association of Airport Executives: 

CAA: Clean Air Act: 

CAEP: Committee on Aviation Environmental Protection: 

CDA: Continuous Descent Approach: 

CEQ: Council on Environmental Quality: 

CFEMS: Compliance-Focused Environmental Management System: 

CFR: Code of Federal Regulations: 

CNEL: Community Noise Equivalent Level: 

CO: carbon monoxide: 

CWA: Clean Water Act: 

DNL: day-night level: 

DOE: Department of Energy: 

DOT: Department of Transportation: 

EA: Environmental Assessment: 

EIS: Environmental Impact Statement: 

EMS: Environmental Management System: 

EPA: Environmental Protection Agency: 

FAA: Federal Aviation Administration: 

FACT 2: Future Airport Capacity Task 2: 

GHG: greenhouse gas: 

GSE: ground support equipment: 

HAP: hazardous air pollutants: 

ICAO: International Civil Aviation Organization: 

ISO: International Organization for Standardization: 

JPDO: Joint Planning and Development Office: 

LED: light-emitting diode: 

LEED: Leadership in Energy and Environmental Design: 

Leq: Equivalent Sound Level: 

Lmax: Maximum Sound Level: 

MPO: Metropolitan Planning Organization: 

NAS: National Airspace System: 

NEPA: National Environmental Policy Act: 

NextGen: Next Generation Air Transportation System: 

NOx: nitrogen oxides: 

NPDES: National Pollutant Discharge Elimination System: 

OEP: Operational Evolution Partnership: 

Pb: lead: 

PFC: passenger facility charge: 

PM: particulate matter: 

RNP: Required Navigation Performance: 

SAM: Sustainable Airport Manual: 

SEL: Sound Exposure Level: 

SIP: State Implementation Plan: 

SOx: sulfur oxide: 

TRB: Transportation Research Board: 

USGBC: U.S. Green Building Council: 

VALE: Voluntary Airport Low Emissions: 

Aviation and the Environment: Survey of Airport Officials on Airport 
Environmental Issues (GAO-10-748SP, September 2010), an E-supplement 
to GAO-10-50: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

September 13, 2010: 

The Honorable Gabrielle Giffords: 
Chairman: 
The Honorable Pete Olson: 
Ranking Member: 
Subcommittee on Space and Aeronautics: 
Committee on Science and Technology: 
House of Representatives: 

The Honorable Jerry F. Costello: 
Chairman: 
The Honorable Thomas Petri: 
Ranking Member: 
Subcommittee on Aviation: 
Committee on Transportation and Infrastructure: 
House of Representatives: 

The Honorable Mark Udall: 
United States Senate: 

Balancing the capacity enhancing needs of the national airspace system 
(NAS) with the need to protect the environment can be challenging. The 
Federal Aviation Administration (FAA) estimates that the annual number 
of passengers traveling by air in the United States will grow from 750 
million in 2012 to over 1 billion by 2023. It also forecasts a 
corresponding 20 percent increase in the number of flights, which 
could add to existing flight delays and air traffic congestion. We and 
others have reported that both the NAS and airport capacity will need 
to expand to handle the projected increase in traffic.[Footnote 1] 
Even while the aviation system has grown and continues to grow, 
airports have sought to limit the environmental impacts generated by 
their construction and operations--such as noise, water, air, and 
waste pollution--in part, to meet applicable legal requirements. 
However, airports' environmental impacts have been a source of 
friction with neighboring communities. As we have previously reported, 
community opposition due to concerns about aviation noise and other 
environmental impacts can arise during the public outreach required by 
federal law when federally-funded airport expansion projects are 
proposed and can contribute to project delays at some airports. 
[Footnote 2] We have previously reported that new runway construction 
from initial planning to completion takes a median of 10 years, but 
delays from lawsuits or addressing environmental issues can add an 
additional 4 years to the median time.[Footnote 3] The Joint Planning 
and Development Office's (JPDO) 2007 Concept of Operations document 
also projected that, based on current operational trends, 
environmental impacts, particularly noise, will be the primary 
constraint on the capacity and flexibility of the Next Generation Air 
Transportation System (NextGen) unless these impacts are managed and 
mitigated. 

FAA is undertaking several efforts to ensure the safety and efficiency 
of the NAS, including NextGen-the transformation of the air 
transportation system by 2025 from the current radar-based system, 
into a more automated aircraft-centered, satellite-based system. FAA 
has also undertaken several airspace redesign efforts, including those 
in the New York/New Jersey/Philadelphia airspace, and Florida's West 
Coast airspace that will result in changes in aircraft flight paths 
around airports there. Both efforts are intended to increase 
efficiency and reduce delays, and are expected to produce substantial 
environmental benefits, such as reducing emissions growth and 
decreasing aircraft noise. Their success depends in part on changes to 
operational procedures undertaken by aircraft during their arrival and 
departure and airport expansion and improvement projects. According to 
FAA, environmental and energy issues, such as noise levels in 
communities surrounding airports, will also significantly influence 
the future capacity and flexibility of the NAS.[Footnote 4] 

FAA has identified 35 of the busiest U.S. commercial airports as 
providing critical services to the NAS either in terms of passengers, 
cargo, or as connecting airports and which may require additional 
capacity. These 35 airports are known as Operational Evolution 
Partnership (OEP) airports.[Footnote 5] More than 70 percent of U.S. 
passengers travel through OEP airports. FAA has also identified 27 
airports that it forecasts will be significantly congested by 2025 if 
currently planned improvements--such as new or extended runways, 
airspace redesign, and some NextGen improvements (e.g., reduced 
separation requirements for arrivals and departures)--do not occur at 
Future Airport Capacity Task 2 (FACT 2) airports.[Footnote 6] Nineteen 
of the 27 FACT 2 airports are OEP airports, and all but 1 of the OEP 
and FACT 2 airports are among the nation's 66 large and medium hub 
airports.[Footnote 7] Large and medium hub airports are referred to as 
larger airports throughout this report. We previously found that 
larger airports are best able to fund capital development projects. 
[Footnote 8] 

Given that successfully reducing airports' environmental impacts is 
critical to maximizing airport capacity, you asked that we update our 
work on airports' actions to address their environmental impacts. This 
report addresses (1) the actions that airports have taken to reduce 
environmental impacts of airport operations and development, (2) the 
extent to which airports believe that environmental issues have or 
will delay capital projects or operational changes, and (3) the 
strategies airports can adopt to mitigate delays in implementing 
capital projects and operational changes and address environmental 
issues. 

To answer our three objectives, we conducted a Web-based survey of 
knowledgeable officials from the 150 busiest U.S. airports, which 
include commercial airports and general aviation airports.[Footnote 9] 
The full survey and responses are contained in a separate e-supplement 
GAO-10-748SP. Of surveyed airports, 141 airports (94 percent) 
responded, including 63 of 66 larger airports--which include all 35 
OEP airports and 26 of 27 FACT 2 airports[Footnote 10]--12 small hubs, 
15 non-hubs, and 51 general aviation airports.[Footnote 11] Large and 
medium hub airports account for about 90 percent of U.S. passengers, 
35 percent of operations, and are key to the efficiency of the NAS and 
have the greatest resources to fund projects, including capital 
development projects. To determine whether there were any differences 
in the environmental actions taken by, and perspectives of, these 
larger airports, we compared the survey results from large and medium 
hub airports to the data from airports in our survey. We administered 
our survey only to airport officials. We also interviewed officials 
from 10 airports, including Chicago O'Hare International Airport in 
Illinois; Long Beach/Daugherty Field and Los Angeles International 
Airports in California; Naples Municipal, Palm Beach International, 
and Southwest Florida International Airports in Florida; John F. 
Kennedy International Airport in New York; Philadelphia International 
Airport in Pennsylvania; Portland International Airport in Oregon; and 
Seattle-Tacoma International Airport in Washington. We selected these 
airports to include airports that have one or more of the following 
characteristics: have undertaken efforts to become "green" or more 
environmentally sustainable; have been identified through FAA's OEP or 
FACT 2 as needing additional capacity; have community groups involved 
in environmental issues or have taken steps to reach out to such 
groups; are in nonattainment areas for identified criteria pollutants; 
[Footnote 12] and are located in various regions of the country. See 
appendix II for a list of the airports that we visited or responded to 
our survey. 

Additionally, we interviewed FAA representatives from headquarters and 
5 regional offices; officials from 6 regional EPA offices and 12 
relevant state and local environmental regulatory agencies; and 3 
aviation environmental experts. We also interviewed representatives 
from 7 metropolitan planning organizations, 2 environmental advocacy 
groups, and 10 community groups. We also reviewed literature to 
determine leading practices in stakeholder and community involvement 
in environmental issues, notably our past reports, as well as those of 
the Airport Cooperative Research Program (ACRP), which is sponsored by 
FAA and managed by the Transportation Research Board (TRB), a unit of 
the National Research Council within the National Academy of Sciences. 
Additional information on our scope and methodology appears in 
appendix I. 

We conducted this performance audit from January 2008 through 
September 2010 in accordance with generally accepted government 
auditing standards. Those standards require that we plan and perform 
the audit to obtain sufficient, appropriate evidence to provide a 
reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 
objectives. 

Background: 

Airports can affect the environment in a number of ways (see figure 
1). [Footnote 13] 

Figure 1: Examples of Possible Airport Environmental Effects: 

[Refer to PDF for image: illustration] 

Noise: 
Aircraft fly over nearby homes and schools during takeoffs and 
landings. 

Emissions: 
Emissions come from aircraft as well as from airport vehicles and 
traffic coming to/from the airport (including rental cars and parking 
shuttles). 

Water pollution: 
Runoff from construction activities, aircraft deicing operations, or 
from spilled fuel pollute local streams. 

Environmental sustainability: 
* Airport terminal operations including lights, computer systems, and 
air conditioning consume large amounts of energy. 
* Garbage from shops, restaurants, on-board food service, etc. 

Source: GAO. 

[End of figure] 

* Noise: Airports can be a significant source of noise for surrounding 
communities, particularly from aircraft takeoffs and landings. The 
impact of aviation noise is usually analyzed in terms of the extent to 
which noise annoys people by interfering with their normal activities, 
such as sleep, relaxation, speech, telephone conversations, television 
viewing, and school. The generally accepted model for assessing the 
cumulative effects of airport noise exposure is the Integrated Noise 
Model. FAA requires use of the model, or an FAA approved equivalent, 
to predict noise levels for its Part 150 noise compatibility programs, 
which provide federal funding under the Airport Improvement Program 
(AIP) to airport sponsors that volunteer to mitigate present and 
future noise impacts.[Footnote 14] FAA also requires use of the model 
for environmental analyses to meet requirements under the National 
Environmental Policy Act of 1969 (NEPA).[Footnote 15] Among other 
functions, the model provides a correlation of the day-night level 
(DNL)[Footnote 16] to the percentage of population highly annoyed by 
recurring noise sound events. For NEPA purposes, FAA defines a 
significant aviation noise impact as a DNL 1.5-decibel increase 
occurring over noise sensitive land uses located at or above a 65- 
decibel day night level (DNL 65 dB). Perceptions of aviation noise 
vary from one individual to another, and, as a result, even 
comparatively low levels of noise exposure can be annoying to some 
individuals. The Airport Noise and Capacity Act of 1990 
(ANCA)[Footnote 17] required the retirement or modification of older, 
noisier jet aircraft that could not meet FAA noise standards, and this 
requirement was enabled by technological advancements to jet aircraft. 
[Footnote 18] According to FAA, this contributed to reducing the 
number of people exposed to significant aviation noise levels by more 
than a third from 2000 to 2006. Local government decisions that allow 
communities to expand land uses that are noise sensitive near airports 
may, however, erode some of the noise reduction gains, according to a 
2004 FAA report to Congress.[Footnote 19] In addition, future 
increases in air traffic and changes in aircraft flight paths, which 
can expose neighborhoods to aircraft noise that had not been 
previously exposed to it or that concentrate more flights on some 
existing flight paths, could lead to more noise complaints from the 
community. 

* Emissions: Aviation-related activities produce about 3 percent of 
total U.S. greenhouse gas (GHG) emissions and less than 1 percent of 
air pollutant concentrations nationwide, but these concentrations are 
expected to increase with forecasted growth in the aviation sector, 
according to FAA. According to the EPA, in areas with busy airports, 
aircraft contribute a larger amount of total mobile source 
emissions.[Footnote 20] Aircraft are a significant source of airport 
emissions (e.g., idling at the gate, taxiing, takeoffs, and 
landings).[Footnote 21] Airport ground support equipment and passenger 
vehicles, as well as various stationary sources located on airport 
grounds, such as boilers, emergency generators, and incinerators, also 
produce emissions. Together, these sources emit nitrogen oxides and 
volatile organic compounds, which lead to the formation of ground-
level ozone (that is, smog) and other substances that contribute to 
local air pollution, as well as carbon dioxide and other GHGs that 
rise into the atmosphere and contribute to climate change. These 
pollutants can also affect the quality of human life and health. For 
example, according to a National Research Council panel, ozone can 
aggravate respiratory ailments, and even short-term exposure is likely 
to contribute to premature deaths of people with asthma, heart 
disease, and other preexisting conditions. About 160 commercial 
service airports[Footnote 22] are located in non-attainment and 
maintenance areas.[Footnote 23] 

* Water pollution: Airports and their tenants can affect water quality 
through activities such as aircraft and vehicle fueling and 
maintenance, as well as runway and aircraft deicing and anti-icing 
activity. Chemicals from such activities may contaminate groundwater 
and surface water supplies if allowed to flow from airport facilities 
to storm drains or waterways. Airports often need to take steps to 
contain or treat runoff in order to meet federal Clean Water Act 
[Footnote 24] (CWA) requirements. Fuel spills, which may contaminate 
soil or groundwater if not contained or diverted to a fuel collection 
separation system, are another concern, and may result from leaks, 
improper connections, and improperly monitored storage tanks. Toxic 
pollutants--such as solvents, dioxins, and metals that can be present 
in airport runoff--in the water supply can cause immediate short-term 
human health effects, such as respiratory irritation, and long-term, 
permanent health problems such as cancer, kidney and liver damage, 
anemia, and heart failure. 

* Resource and environmental sustainability: Environmental 
sustainability refers to sustaining our natural resources and 
safeguarding our environmental assets for future generations.[Footnote 
25] Airports, like other large businesses, can consume large amounts 
of water and energy to operate lighting, heating and cooling systems, 
and computers. Airport concession shops and food service operations, 
as well as airlines, can also generate significant quantities of solid 
waste, such as cardboard, wooden pallets, aluminum, plastic, glass 
containers, and leftover food. Airports' and their tenants' activities 
to address these issues, as well as their activities to address noise, 
emissions and water pollution, can promote sustainability. 

Airports are subject to federal, state, and local laws and regulations 
designed to protect the environment. FAA, as the lead federal agency 
for airport development and funding, has the responsibility for 
analyzing and disclosing potential environmental impacts from proposed 
airport development. Other federal agencies, such as EPA, are also 
involved in federal oversight over airport activities that impact the 
environment. Several federal environmental laws, including the CWA and 
Clean Air Act (CAA), are generally administered by states' operating 
programs that EPA has authorized. 

Aircraft noise is regulated at the source, that is, engines must meet 
International Civil Aviation Organization (ICAO) noise standards which 
have been promulgated by regulation by FAA.[Footnote 26] Congress also 
set phase out requirements for noisier aircraft under the Airport 
Noise and Capacity Act of 1990 (ANCA).[Footnote 27] In addition, the 
Aviation Safety and Noise Abatement Act of 1979 (ASNA) established 
airport noise compatibility planning grants,[Footnote 28] which are 
administered under and implemented in accordance with FAA's Part 150 
noise compatibility regulations--14 C.F.R. part 150. California has 
also set a somewhat more stringent standard for the acceptable level 
of noise in the vicinity of airports--65 Community Noise Equivalent 
Level (CNEL),[Footnote 29] and airports whose operations produce noise 
that exceeds this standard must obtain a variance from the state that 
requires that the airport develop a schedule for reducing noise 
impacts in its vicinity. 

The CAA mandates standards for mobile sources of emissions, such as 
aircraft and the equipment that services them at airports, as well as 
stationary sources, such as power plants located at airports. EPA sets 
aircraft emissions standards and has adopted those set by the ICAO. 
FAA administers and enforces these standards.[Footnote 30] The CAA, as 
amended, also regulates hazardous air pollutants (HAP), such as 
benzene, which is found in aviation fuels. Some states and local 
jurisdictions also have additional requirements pertaining to air 
pollution. As a result, air pollution control regulations can be site- 
or area-specific.[Footnote 31] 

The CWA sets the basic structure for regulating discharges of 
pollutants to waters of the United States. Under the permitting system 
established under the CWA, airports must obtain a National Pollutant 
Discharge Elimination System (NPDES) permit from EPA or an authorized 
state for covered discharges of stormwater or other wastewaters. In 
addition, under the national pretreatment program, airports are 
required to pretreat their wastewater before discharging into sewer 
systems to remove pollutants that may pass through or interfere with 
the treatment processes at municipal wastewater treatment facilities. 
Many airports are also subject to regulations that require them to 
develop programs to prevent and immediately clean up oil and chemical 
spills.[Footnote 32] EPA has also established reporting requirements 
for hazardous substance releases.[Footnote 33] 

By contrast, there are currently no federal laws or regulations that 
specifically require airports to make their buildings "green" or act 
in a more environmentally sustainable manner. Using more 
environmentally sustainable practices, however, may help airports meet 
other federal environmental requirements, such as the CAA. 

Certain federal actions, including airport expansion and large capital 
projects that use federal funding, require compliance with NEPA. 
[Footnote 34] Under NEPA, federal agencies evaluate the potential 
environmental effects of actions they are proposing or ones for which 
third parties, such as airports seek federal approval or funding. The 
agencies can meet the NEPA requirements by categorically excluding the 
project, using an environmental assessment (EA) or, if actions are 
likely to significantly affect the environment, preparing a more 
detailed environmental impact statement (EIS).[Footnote 35] NEPA 
implementing regulations set forth requirements that federal agencies 
must adhere to in the EIS process. For example, an EIS must, among 
other things, (1) describe the environment that will be affected, (2) 
identify alternatives to the proposed action and identify the agency's 
preferred alternative(s), (3) present the environmental impacts of the 
proposed action and alternatives, and (4) identify any adverse 
environmental impacts that cannot be avoided should the proposed 
action be implemented. Throughout the EIS process, FAA must make 
diligent efforts to involve the public, which may involve holding 
public hearings.[Footnote 36] For additional direction on implementing 
NEPA and related regulations, FAA developed an order[Footnote 37] that 
governs, among other things, its EIS process and issued best practices 
for EIS management. 

During the environmental review process, other substantive 
environmental laws may also be implicated. For example, under the 
CAA's conformity provision,[Footnote 38] FAA must determine whether a 
project will conform to an applicable state implementation plan (SIP); 
for example, emission increases that result from an airport project 
must not exceed the SIP's emission forecast or budget for that 
airport.[Footnote 39] Airports may be required to obtain environmental 
permits or approvals from other federal, state, and local agencies 
before they can begin construction of a proposed project. For example, 
Section 404 of the CWA generally prohibits the discharge of dredged or 
fill material into the waters of the United States, including certain 
wetlands, without a permit from the Corps of Engineers.[Footnote 40] 
State and local agencies may also require permits dealing with air and 
water quality. 

FAA provides guidance and funding for airport development projects, 
including environmental planning and mitigation. FAA's environmental 
guidance for airports is contained in a series of orders, advisory 
circulars, and handbooks.[Footnote 41] Among these are guidance on 
environmental planning, noise abatement, water quality, air emissions, 
and Environmental Management Systems (EMS).[Footnote 42] Over the past 
several years, FAA has provided over $3.5 billion annually to airports 
for airport capital projects through its AIP. Part of the cost of 
project development is the cost for environmental planning, including 
conducting an EIS, if necessary, and performing environmental 
mitigation, such as installing stormwater drainage, creating or 
enhancing wetlands, and noise soundproofing. In addition, 35 percent 
of FAA's AIP discretionary funds are reserved by FAA for noise-
abatement and emissions-reductions projects under FAA's Voluntary 
Airport Low Emissions (VALE)[Footnote 43] program if the airport is in 
a nonattainment or maintenance area.[Footnote 44] 

Surveyed Airports Reported Taking a Variety of Actions to Reduce or 
Mitigate Their Environmental Impacts: 

Our survey results and interviews with airport officials show that 
airports have taken a variety of actions to reduce the environmental 
impacts resulting from their operations and development. The majority 
of airports took at least one action in each of the four environmental 
areas included in our survey during the period 2006-2009. Some of the 
actions taken help ensure compliance with environmental laws and 
regulations, while others represent voluntary airport efforts to 
reduce their environmental impacts.[Footnote 45] Although every 
surveyed airport, regardless of size or geographic location, was asked 
whether it had taken the same list of actions, it should be noted that 
some actions are not necessarily appropriate for all airports. For 
example, smaller airports generally produce less noise, emissions and 
water pollution than larger airports and may not need to take as many 
actions to address environmental impacts. In addition, some actions 
are necessitated by an airport's location so that for instance, 
airports in areas with high annual rainfall may need to do more to 
deal with runoff than those airports located in desert climates. 
Within each environmental area we first describe the actions taken by 
all surveyed airports and then focus on the actions of the 63 large 
and medium hub airports (or "larger airports") because of their size 
and significance to the system and their level of future investments 
in NextGen and airport improvements. 

Most Airports Took Multiple Actions to Address Noise, While Larger 
Airports Were More Likely to Implement More Costly Measures: 

Over the 3-year period 2006 through 2009, most responding airports, 
sometimes in conjunction with airlines and the FAA, had taken a 
variety of actions to address or reduce or mitigate aircraft noise, 
most commonly, monitoring noise or developing aircraft operational 
procedures that reduce the amount of noise affecting nearby 
communities. (see figure 2). 

Figure 2: Variety of Airport Actions Taken to Address Aircraft Noise: 

[Refer to PDF for image: stacked horizontal bar graph] 

Number of airports: 141. 

Monitored aircraft noise: 
Large and Medium hub airports: 60; 
Other airports: 67. 

Had operational procedures: 
Large and Medium hub airports: 61; 
Other airports: 62. 

Purchased avigation easements: 
Large and Medium hub airports: 47; 
Other airports: 50. 

Purchased nearby properties: 
Large and Medium hub airports: 44; 
Other airports: 17. 

Soundproofed properties: 
Large and Medium hub airports: 47; 
Other airports: 11. 

Had sound mitigation structures or enclosures: 
Large and Medium hub airports: 23; 
Other airports: 15. 

[End of figure] 

Most responding airports, regardless of size, reported taking steps to 
assess their noise impacts on the community, although larger airports 
were more likely to use noise measurement metrics besides the 
traditional DNL to measure noise impacts. Of the responding airports 
that monitored aircraft noise, 127 airports (90 percent) collected 
noise complaints from the public during the last 3 years,[Footnote 46] 
while 83 airports (59 percent) monitored noise levels in the areas 
surrounding the airport, including 54 airports that used supplemental 
noise metrics for this purpose. As we have previously reported, 
supplemental noise metrics can define noise exposure in ways that the 
public can understand more readily than the DNL metric required by FAA 
in noise studies under the Part 150 program. The three most commonly 
used supplement metrics were, in descending order, Maximum Sound Level 
(Lmax), Sound Exposure Level (SEL), and Equivalent Sound Level (Leq). 
[Footnote 47] FAA reports supplemental metrics in an EIS when its NEPA 
analysis shows a proposed action would cause significant noise impacts 
on communities. Projects at larger airports are more likely to require 
such statements, according to FAA. Also, 31 airports voluntarily used 
supplemental metrics, while 20 airports said they were required to do 
so. 

At the majority of airports we surveyed, including most larger 
airports, operational procedures that reduce noise levels on 
surrounding communities were in place, such as noise abatement flight 
paths (90 airports), preferential runway use (79 airports), or 
procedures to reduce noise aircraft produce during routine aircraft 
engine maintenance tests known as ground run ups (77 airports). 
[Footnote 48] At a few surveyed airports, air carriers participated in 
new flight procedures that are part of FAA's NextGen initiative. For 
example, Continuous Descent Approach (CDA), which allow aircraft to 
stay at cruise altitudes longer and use lower power levels as they 
approach the airport, thereby reducing noise and emissions, was used 
at 9 airports while at 21 airports Required Navigation Performance 
(RNP), which permits aircraft to descend on a precise route and 
thereby potentially avoid noise sensitive areas, was used.[Footnote 
49] Larger airports were slightly more likely than smaller airports to 
have CDA and RNP procedures in place, constituting 6 of the 9 and 11 
of the 21 airports that had these procedures in place, respectively. 
Twenty-seven airports impose curfews on aircraft operations, a number 
which may not increase significantly in the future given the fact that 
since 1991, airports are required under FAA's Part 161 regulations, 
which implement ANCA, to meet more stringent requirements in order to 
impose a restriction. Only one airport, Naples Airport in Florida, has 
successfully completed the process since 1991. 

Most responding airports, including a majority of larger airports, 
also took actions to limit the amount of residential property exposed 
to high levels of aircraft noise, including purchasing or otherwise 
obtaining avigation easements[Footnote 50] (97 airports), purchasing 
nearby homes (50 airports), purchasing nearby land (47 airports), and 
erecting sound mitigation structures or enclosures (38 airports). 
Airports also soundproofed a variety of buildings within the DNL 65 dB 
contour, most commonly homes (50 airports), but also schools, 
hospitals, and certain commercial buildings.[Footnote 51] Airports 
soundproofed anywhere from two to thousands of homes; 20 of the 21 
airports that reported soundproofing 1,000 or more homes were larger 
airports. Airports often obtain funding for home and land purchases, 
sound mitigation structures and enclosures, and soundproofing from AIP 
grants or can use PFC for these purposes. As figure 2 shows, while 
larger airports, which generally have a larger noise footprint than 
smaller airports, took many of the actions to address noise, they 
implemented the majority of the non-operational noise reduction 
measures reported in our survey. For example, 47 larger airports 
soundproofed homes, which represented 81 percent of all responding 
airports that reported doing so. And only 18 larger airports reported 
that they did not purchase some type of property to address noise 
issues, while the majority of all responding airports reported not 
doing so. 

Although most airports we surveyed took a variety of actions to reduce 
or mitigate aircraft noise, only a few airports quantified the impact 
these actions had on noise levels in surrounding communities. We did 
not assess these quantifications.[Footnote 52] Nine airports 
quantified the impact of their actions on noise, one noting that new 
departure procedures implemented with the opening of a new runway 
reduced the number of people within the 60 plus DNL contour by 4,349 
and the number of dwellings by 1,926. Some airports cited other non-
quantified results of what they viewed as successful noise reduction 
and mitigation actions, including an improved environment around the 
airport (49 airports), improved relationships with the community (33 
airports), reduced noise complaints (31), and more compatible land use 
around the airport (17 airports). 

Most Responding Airports Addressed Emissions in Some Way, but Larger 
Airports Reported Taking a Wider Variety of Actions: 

Our survey results show that responding airports, often in conjunction 
with the air carriers that serve them, have taken measures to reduce 
and quantify emissions from major sources (figure 3). Most common are 
providing transportation facilities, followed by having on-airport 
systems to reduce emissions (like the use of electric vehicles), 
transportation programs for employees that encourage reducing vehicle 
emissions, conducting emission studies, and voluntary actions by air 
carriers to reduce their emissions. Although some airports may be 
required to mitigate emission increases arising from projects covered 
by NEPA and the CAA, our previous work indicated that most emission 
reduction actions are done so voluntarily.[Footnote 53] 

Figure 3: Variety of Airport Actions Taken to Reduce Emissions: 

[Refer to PDF for image: stacked horizontal bar graph] 

Number of airports: 141. 

Had transportation facilities to reduce emissions: 
Large and Medium hub airports: 63; 
Other airports: 48. 

Had systems to reduce emissions: 
Large and Medium hub airports: 62; 
Other airports: 24. 

Transportation programs to reduce emissions: 
Large and Medium hub airports: 40; 
Other airports: 39. 

Conducted studies of airport emissions: 
Large and Medium hub airports: 47; 
Other airports: 21. 

Had voluntary policies to encourage air carriers to reduce aircraft 
emissions: 
Large and Medium hub airports: 20; 
Other airports: 10. 

Source: GAO survey. 

[End of figure] 

Most responding airports have taken some actions to reduce emissions 
from vehicular traffic. For example: 

* 101 airports provided access to a public bus stop; 

* 84 airports provided a staging area for taxis to reduce idling; 

* 62 airports provided a cell phone lot to reduce circling the 
airport; and: 

* 47 airports had consolidated rental car facilities to reduce the 
number of passenger pick up vans at the airport. 

While 78 percent of airports reported that voluntary air carrier 
operational procedures to reduce aircraft emissions were not used at 
their airport, some airports have encouraged carriers to voluntarily 
reduce emissions through modified operational procedures. A ground no- 
idle policy was the most frequently policy cited (17 airports), 
followed by single-engine taxiing (11 airports). Aircraft ground 
operational procedures to reduce aircraft emissions are at the 
discretion of the pilot, and it is unknown to what extent such 
procedures are used at airports that have them. 

The widest variety of emissions reducing actions reported in our 
survey were undertaken by larger airports, which tend to produce more 
emissions and which may have more funding and staff available to 
address them than smaller airports. Almost all larger airports 
provided public bus access and taxi staging areas, while about 40 to 
50 percent of larger airports also provided consolidated rental car 
facilities and access to rail stations. Most of the airports that 
reported encouraging air carriers to use modified operational 
procedures to reduce emissions were larger airports. In addition, the 
vast majority of larger airports had invested in emissions reducing 
systems, which are expensive and possibly more cost effective for 
larger airports than for smaller airports, which have limited numbers 
of commercial operations. These systems include: 

* loading bridges that supply aircraft with electricity (59 airports) 
and pre-conditioned air (55 airports), which eliminate the need for 
aircraft to run their auxiliary engines to power and cool the aircraft 
at the gate; 

* underground hydrant systems (47 airports), which reduce the need for 
fueling trucks and thus the emissions they produce; and: 

* fueling or charging stations for alternative fuel vehicles, 
including those using compressed natural gas, bio-diesel, electric, or 
hybrid technology (43 airports). Larger airports made up 54 of the 94 
airports that reported having alternative fuel vehicles, including 21 
of the 29 airports with vehicle fleets made up of at least 50 percent 
alternative fuel vehicles. 

Airports in air quality nonattainment and maintenance areas can apply 
for funding from FAA's VALE program for the purchase of emissions 
reducing systems, as well as for alternative fuel vehicles. As of 
April 2010, 17 airports had qualified for a total of about $49 million 
in VALE funding. 

Larger airports also represented 42 of the 53 airports that undertook 
general emissions inventories, which estimate the amounts of emissions 
produced by airport sources (e.g., ground support equipment (GSE), and 
aircraft) in tons and may be required for environmental reviews of 
proposed airport projects. However, few larger airports conducted a 
more detailed analysis to determine the concentration of various 
pollutants in the airport vicinity--e.g., hazardous air pollutant 
analyses (17 airports) and air pollutant measurements (9 airports)--or 
conducted studies that assess the human health risks, such as the 
incidence of pollution related health effects in the airport vicinity, 
from emissions (3 airports).[Footnote 54] These types of detailed 
analyses and studies can be complex and resource intensive to conduct. 
In addition, according to FAA there is no clear federal guidance on 
conducting human health risk assessments. 

Of the 92 airports that reported taking some action to reduce 
emissions, 9 provided estimates of reductions. For example, one 
airport estimated that providing electricity and preconditioned air at 
its gates reduced aircraft auxiliary engine usage and thus nitrogen 
oxide emissions by up to 10 tons per year. Another airport reported 
that it had constructed a compressed natural gas fueling station and 
converted its fleet of buses to natural gas, which eliminated 76 tons 
of emissions per year.[Footnote 55] 

Almost All Responding Airports Took Multiple Steps to Control Water 
Pollution, Many of Which Were Required: 

Over 90 percent of responding airports have multiple systems and 
procedures in place to address water pollution. Many of these systems 
and procedures are those generally required to meet various 
environmental laws and regulations, such as those required to obtain 
National Pollution Discharge Elimination System (NPDES) 
permits.[Footnote 56] For example, nearly all the airports we surveyed 
had Stormwater Pollution Prevention Plans, and a large majority had 
Spill Prevention, Control and Countermeasure Plans, which, as noted, 
many airports are required to develop in order to prevent and 
immediately clean up oil, chemical, and fuel spills. The vast majority 
of the airports we surveyed also had individual systems and procedures 
in place to prevent or control spills, which can be part of the 
aforementioned plans, as well as systems in place to minimize the 
impact of such spills (see figure 4). 

Figure 4: Variety of Airport Actions Taken to Address Water Pollution: 

[Refer to PDF for image: stacked horizontal bar graph] 

Had systems to minimize impact of spills: 
Large and Medium hub airports: 63; 
Other airports: 77. 

Had systems to prevent or control spills: 
Large and Medium hub airports: 63; 
Other airports: 75. 

Had written plans to control pollution: 
Large and Medium hub airports: 63; 
Other airports: 74. 

Had procedures to prevent or control spills: 
Large and Medium hub airports: 62; 
Other airports: 75. 

Had systems to control runoff: 
Large and Medium hub airports: 61; 
Other airports: 73. 

Obtained water pollution control permits: 
Large and Medium hub airports: 60; 
Other airports: 66. 

Monitored stormwater outflows: 
Large and Medium hub airports: 58; 
Other airports: 52. 

Had systems to minimize the impact of deicing fluids: 
Large and Medium hub airports: 28; 
Other airports: 32. 

Source: GAO survey. 

[End of figure] 

Likewise, most of the airports in our survey had obtained discharge 
permits such as a state issued NPDES permit, and 69 airports have 
state government water discharge permits, as appropriate. Surveyed 
airports have installed a variety of systems to control storm water 
runoff, many of which may have been necessary to meet their permit 
requirements, with the most common being catch basins (99 airports), 
detention ponds (96 airports), and vegetative filter strips, which are 
constructed areas of vegetation that remove sediment and other 
pollutants from surface water runoff by filtration, absorption, and 
decomposition (59 airports).[Footnote 57] Most of the airports we 
surveyed (110) also monitored the water quality of storm water 
outflows. 

Our survey indicates that larger airports are more likely to have 
systems in place to minimize the use and impact of runway and aircraft 
deicing fluids. Deicing fluids are mainly used at commercial airports 
in colder climates,[Footnote 58] and our survey shows that deicing is 
done at 82 (58 percent) of the total airports in our survey as 
compared to 53 (84 percent) of the larger airports. As indicated in 
figure 4, significantly higher percentages of larger airports that 
deice made greater use of practices and systems to minimize the use 
and impact of deicing fluids. As noted later in this report, effluent 
limit guidelines addressing airport deicing that EPA has proposed may 
require more airports to implement systems and practices to minimize 
the use and impact of deicing fluids. 

Well over half of the airports responding to our survey cited 
accomplishments resulting from their actions to control water 
pollution. Seventy-five airports said that their actions had a 
positive environmental impact, while 25 said that their actions helped 
improve compliance with water quality regulations. However, only two 
airports provided quantitative data on the impact of their actions. 
According to one of these airports, the installation of a large-scale 
deicing pad where much of the aircraft deicing was performed prevented 
250,000 gallons of deicing fluid from contaminating nearby streams. 

Most Airports Have Undertaken Various Conservation Practices, and an 
Increasing Number Intend to Make These Part of a More Holistic 
Approach to Environmental Management: 

Most surveyed airports reported using at least one "green" or 
environmentally sustainable practice. Based on the survey of airports, 
more intend to move toward a more holistic approach to environmental 
management, which involves a broader or more systematic approach to 
managing environmental impacts, such as following environmental 
sustainable standards or implementing an Environmental Management 
System (EMS) (see figure 5). 

Figure 5: Variety of Actions Taken to Become More Environmentally 
Sustainable: 

[Refer to PDF for image: stacked horizontal bar graph] 

Used at least one energy conserving device: 
Large and Medium hub airports: 59; 
Other airports: 68. 

Used at least one water conserving device: 
Large and Medium hub airports: 53; 
Other airports: 64. 

Followed a green or environmental sustainable standard: 
Large and Medium hub airports: 54; 
Other airports: 26. 

Had Environmental Management System (EMS): 
Large and Medium hub airports: 24; 
Other airports: 10. 

Had at least one building constructed in accordance with LEED 
standards: 
Large and Medium hub airports: 16; 
Other airports: 13. 

Source: GAO survey. 

[End of figure] 

The greatest number of airports reported relatively simple steps like 
using energy conserving devices. For example, 127 surveyed airports 
used at least one energy conservation device, and 117 airports used at 
least one water conservation device. Four energy conservation devices--
Light-Emitting Diode (LED) airfield lights,[Footnote 59] energy-
efficient lighting, room occupancy sensors, and light-colored roofs to 
reflect sunlight--were used by at least 49 percent of larger airports. 
Three water conservation devices--both automatic shutoff and low-flow 
restroom plumbing fixtures and landscaping with native plants to 
reduce irrigation--were used by at least 42 larger airports. Between 
50 to 80 percent of all surveyed airports reported recycling or 
reusing five of the six recyclable materials included in our survey, 
with paper, plastic, and aluminum recycled or reused by more airports 
than glass and building materials. By contrast, de-icing materials 
were reported as being recycled or reused for non aviation purposes by 
12 of 82 surveyed airports that reported using de-icing or anti-icing 
materials, although some of the airports may not use large quantities 
of these materials. 

About 71 percent of larger airports, as compared to 57 percent 
overall, reported following "green" or environmental sustainability 
standards. These standards can assist airports in implementing 
practical and measurable green building design, construction, and 
operations and maintenance solutions, such as those shown in figure 6. 
Following such a standard is generally voluntary; 34 airports, 
however, said that compliance with such a standard was a state or 
local requirement. The Leadership in Energy and Environmental Design 
(LEED) Green Building Rating Systems was the most followed "green" 
standard, used by 54 surveyed airports (38 percent).[Footnote 60] A 
LEED certified building indicates that an independent, third-party, 
has verified that the building project meets the highest green 
building and performance measures, as determined by the U.S. Green 
Building Council (USGBC). 

Figure 6: Example of Features from a LEED-Certified Terminal: 

[Refer to PDF for image: illustration] 

1) Water-efficient plumbing; 
2) Energy-efficient electric lighting; 
3) High-insulation glass; 
4) Natural lighting; 
5) Construction waste recycling; 
6) Use of recycled or local construction materials; 
7) Adhesives, sealants, paints, and carpets which contain little or no 
volatile organic compounds; 
8) Roofing and paving designed to combat the "heat island effect" by 
reflecting heat away from terminal buildings; 
9) Alternative fuels for ground transportation; 
10) Policies to encourage use of HOV lanes at airport; 
11) Stormwater filtration devices to remove suspended solids and 
phosphorous from storm runoff. 

Source: GAO. 

[End of figure] 

More airports reported plans to build in accordance with LEED 
standards than those that had already done so. For example, 29 
airports had constructed a building in accordance with LEED standards, 
and 12 airports had at least one LEED-certified building.[Footnote 61] 
Fifty-five airports reported plans to build in accordance with LEED 
standards. While an airport official noted that LEED certification can 
raise the profile of a project for sustainable construction and 
operation within the community, about half of the 51 surveyed airports 
that had or planned to build in accordance with LEED standards cited 
cost as the reason why they had not or will not seek LEED 
certification. According to the USGBC, LEED standards are flexible 
enough to apply to all building types. Some airport officials we 
interviewed, however, said that LEED standards are difficult to adapt 
to airports. Surveyed airports reported following one of three airport-
specific "green" standards.[Footnote 62] One of these three standards 
is outlined in Chicago O'Hare International Airport's Sustainable 
Airport Manual (SAM), which was completed in 2009. It expanded on the 
airport's predecessor manual, the 2003 Chicago O'Hare Modernization 
Program's Sustainable Design Manual, by including lessons learned, new 
technologies, and best environmental practices used by airports 
worldwide. According to the Chicago Department of Aviation, SAM is 
intended to be an international model for airport sustainability and 
involved approximately 160 participants, including FAA, EPA, airports, 
and industry experts. 

Survey responses to questions about voluntary EMSs also suggest that 
more airports are moving toward a more holistic, sustainable approach 
to operations and development.[Footnote 63] An EMS is a set of 
procedures and policies used to systematically identify, evaluate, and 
manage the environmental impacts of an organization's ongoing 
activities in order to improve environmental performance and 
regulatory compliance.[Footnote 64] Thirty-four airports had adopted 
an EMS, while 35 airports planned to do so. Although the International 
Organization for Standardization (ISO) 14001 standards for EMS require 
that an EMS identifies all environmental impacts, only 8 of the 34 
surveyed airports that had an EMS said it covered all their airport 
operations.[Footnote 65] 

As with all responding airports, more larger airports planned to build 
in accordance with LEED standards than those that reported having done 
so. Sixteen larger airports had built in accordance with LEED 
standards, and 32 planned to do so. Twenty-four larger airports had an 
EMS, while 22 planned having one. Larger airports comprised 70 percent 
of surveyed airports that had an EMS and 63 percent of those that plan 
to develop an EMS. In 2007 FAA expanded AIP funding eligibility for 
developing--although not maintaining--an EMS to large and medium hub 
airports.[Footnote 66] As a condition of receiving AIP funding, the 
airport must submit a self-certification that its EMS is compliant 
with a recognized EMS standard. Larger airports comprised 15 of the 19 
airports that reported their EMS followed ISO 14001 standards, EPA's 
compliance-focused EMS (CFEMS) standards, or another recognized EMS 
standard. 

Less Than Half of Airports That Undertook or Will Undertake Capital 
Projects or Operational Changes Believed Addressing an Environmental 
Objective Resulted in Delays: 

Almost All Surveyed Airports Have Undertaken or Will Undertake Capital 
Development Projects or Operational Changes: 

Almost all of the nation's 150 busiest airports have faced in the 5- 
year period 2004-2009, or expect to face in the next 5 years, the 
challenge of implementing a timely and environmentally sound capital 
development project or operational change. As figure 7 shows, the vast 
majority of responding airports reported that (1) they undertook or 
considered undertaking a capital development project in the past 5 
years, and that (2) they will undertake or are considering undertaking 
such a project in the next 5 years. The incidence is even higher for 
larger airports, where 59 of the 63 larger airports had undertaken a 
capital project in the last 5 years and 55 expect to do so over the 
next 5 years. About a third of responding airports reported that they 
implemented or considered implementing an operational change in the 
past 5 years, or will do so in the next 5 years. 

Figure 7: Number of Airports That Have Undertaken or Will Undertake a 
Capital Development Project or Operational Change: 

[Refer to PDF for image: stacked horizontal bar graph] 

Airports with capital development projects in the past 5 years (n=138): 
Large and Medium hub airports: 59; 
Other airports: 70. 

Airports with operational changes in the past 5 years (n=136): 
Large and Medium hub airports: 38; 
Other airports: 37. 

Airports planning capital development projects in the next 5 years 
(n=137): 
Large and Medium hub airports: 55; 
Other airports: 58. 

Airports planning operational changes in the next 5 years (n=136): 
Large and Medium hub airports: 30; 
Other airports: 26. 

Source: GAO survey. 

[End of figure] 

Less than Half of Surveyed Airports Implementing Capital Development 
Projects or Operational Changes Believe Environmental Issues Delayed 
Their Efforts: 

In our survey, we asked airports to estimate how much, if at all, 
addressing a specified environmental objective delayed implementation 
of a capital project or an operational change at their airport in the 
past 5 years or will delay implementation in either of those 
categories in the next 5 years.[Footnote 67] Both the reported delay 
and the extent and significance of delay were determined by the 
responding airport. During survey pre-testing, airport officials 
interpreted delay as meaning a change or deviation from the project or 
operational change's original implementation timeline. For example, an 
airport's concept of delay may include underestimating the time needed 
to comply with the NEPA process as well as unanticipated delay, such 
as delays resulting from litigation.[Footnote 68] When asked how 
addressing an environmental objective delayed or will delay 
implementation, airports cited the time it takes to do necessary 
environmental studies, obtain permits, implement the necessary 
environmental systems, and take mitigating actions required for 
approval. Also, airports said that delays can arise because of 
community opposition or disputes over requirements or regulations with 
federal, state, or local regulators, or conflicting interpretations of 
requirements among these regulators. Airports face the challenge of 
managing the proposed projects and operational changes throughout the 
environmental review and implementation process, and according to a 
2009 ACRP report, delays can significantly increase the costs or 
benefits of specific projects.[Footnote 69] 

Thirty-five percent of airports that had considered or undertaken a 
capital project, and 42 percent of those that had considered or 
undertaken an operational change, over the last 5 years reported that 
addressing environmental issues somewhat or greatly delayed their 
implementation (see figure 8). Forty-seven airports (35 percent) that 
have undertaken or considered undertaking a capital project over the 
last 5 years believe the project was greatly or somewhat delayed as a 
result of addressing an environmental objective. While fewer airports 
reported undertaking operational changes over the last 5 years, 35 
airports (42 percent) believe that environmental issues greatly or 
somewhat delayed doing so. Of those airports that reported a delay, 
far fewer airports believed that their project was "greatly delayed" 
as opposed to "somewhat delayed." For both capital projects and 
operational procedures, larger airports were slightly less likely to 
report a delay (30 percent and 36 percent, respectively). Looking to 
the future, about 40 percent of surveyed airports that reported 
implementing or considering implementing a capital development project 
or an operational change in the next 5 years believe that addressing 
an environmental objective will delay implementation. Larger airports 
were again slightly less likely than other airports to predict a delay. 

Figure 8: Number of Airports Reporting That Addressing Environmental 
Issues Somewhat or Greatly Delay Implementation of a Capital 
Development Project or an Operational Change in the Past 5 Years and 
Next 5 Years: 

[Refer to PDF for image: stacked horizontal bar graph] 

Capital development somewhat or greatly delayed in the past 5 years 
(n=135): 
Large and Medium hub airports: 18; 
Other airports: 29. 

Operational changes somewhat or greatly delayed in the past 5 years 
(n=84): 
Large and Medium hub airports: 16; 
Other airports: 19. 

Capital development somewhat or greatly delay in the next 5 years 
(n=133): 
Large and Medium hub airports: 22; 
Other airports: 32. 

Operational changes somewhat or greatly delay in the next 5 years 
(n=90): 
Large and Medium hub airports: 15; 
Other airports: 24. 

Source: GAO survey. 

[End of figure] 

Addressing Noise and Water Issues Were the Most Frequently Cited 
Sources of Past Delay: 

Airports that believed they had experienced delay in the past most 
often associated the delay with addressing noise and water pollution, 
whereas airports appear to be increasingly concerned that addressing 
GHG emissions and "green" building standards will be a potential 
source of delay. Of the four environmental objectives listed in our 
survey, reducing noise impacts and controlling water pollution were 
consistently the two most frequently cited sources of past delay--by 
all responding airports and by larger airports--for both capital 
development projects and operational changes (see figure 9).[Footnote 
70] As previously discussed, noise has traditionally been the 
environmental area of greatest concern to communities near airports, 
and airports are subject to a number of environmental requirements--
including permitting requirements--with respect to controlling water 
pollution. 

Figure 9: Environmental Objectives Cited as Sources of Delay in 
Implementation of Capital Development Projects and Operational Changes 
in the Past and Next 5 Years: 

[Refer to PDF for image: stacked vertical bar graph] 

Environmental objectives as cited sources of delay: 

Reducing the effects of noise on surrounding communities: 

Past 5 years (n=135): 
Capital improvement project at other airports: 13; 
Operational changes at other airports: 10. 

Next 5 years (n=133): 
Capital improvement project at other airports: 22; 
Operational changes at other airports: 10. 

Past 5 years (n=84): 
Operational changes at large and medium airports: 8; 
Operational changes at other airports: 8. 

Next 5 years (n=90): 
Operational changes at large and medium airports: 7; 
Operational changes at other airports: 17. 

Controlling water pollution: 

Past 5 years (n=135): 
Capital improvement project at other airports: 12; 	
Operational changes at other airports: 16. 

Next 5 years (n=133): 
Capital improvement project at other airports: 19; 	
Operational changes at other airports: 13. 

Past 5 years (n=84): 
Operational changes at large and medium airports: 8; 
Operational changes at other airports: 10. 

Next 5 years (n=90): 
Operational changes at large and medium airports: 9; 
Operational changes at other airports: 15. 

Reducing emissions of local air pollutants or greenhouse gases: 

Past 5 years (n=135): 
Capital improvement project at other airports: 7; 
Operational changes at other airports: 9. 

Next 5 years (n=133): 
Capital improvement project at other airports: 14; 
Operational changes at other airports: 17. 

Past 5 years (n=84): 
Operational changes at large and medium airports: 5; 
Operational changes at other airports: 7. 

Next 5 years (n=90): 
Operational changes at large and medium airports: 9; 
Operational changes at other airports: 10. 

Making airport buildings more “green” or environmentally sustainable: 

Past 5 years (n=135): 
Capital improvement project at other airports: 3; 	
Operational changes at other airports: 3. 

Next 5 years (n=133): 
Capital improvement project at other airports: 14; 
Operational changes at other airports: 11. 

Past 5 years (n=84): 
Operational changes at large and medium airports: 3; 
Operational changes at other airports: 5. 

Next 5 years (n=90): 
Operational changes at large and medium airports: 5; 
Operational changes at other airports: 8. 

Source: GAO survey. 

[End of figure] 

When asked about potential delays in the next 5 years, airports 
generally believed that addressing water pollution and noise would 
remain the two top environmental sources of delay.[Footnote 71] 
Substantially more airports predicted that controlling air pollution 
and making buildings more "green" or more environmentally sustainable 
may cause a delay in the next 5 years than those issues did in the 
past 5 years (see figure 9). Of the air issues, several airports 
expressed concern about controlling GHG emissions. This may reflect 
the increased attention that these other environmental issues have 
received in recent years. For example, when asked if addressing 
environmental objectives might delay the implementation of future 
projects and operational procedures, several airports said they 
anticipated increased scrutiny of environmental impacts or mentioned 
new or more stringent regulations, including the following. 

* Deicing: EPA already requires that deicing fluid runoff that reaches 
navigable waters be subject to a NPDES permit. EPA's proposed effluent 
limitations rule would require primary commercial airports with annual 
departures of at least 10,000, and over 1,000 annual jet departures, 
to collect a specified minimum percentage of the amount of deicing 
fluid sprayed and treat it or send it off site for treatment.[Footnote 
72] According to a recent ACRP report, because many large airports 
already have been working to address deicing discharges, the proposed 
rule may have its greatest affect on medium and smaller airports, 
where environmental regulators may previously have considered deicing 
operations and runoff too small to be of significant concern. 

* GHG: EPA issued a rule effective December 29, 2009, requiring the 
reporting of greenhouse gas emissions from all sectors of the economy. 
[Footnote 73] The rule applies to, among others, large facilities 
emitting 25,000 metric tons or more of CO2 equivalent GHG emissions 
per year. According to an ACI-NA representative, approximately 10 
airports may need to submit an annual GHG report to EPA. Unlike for 
noise and local air quality computations, the first specific guidance 
for airports in developing and computing GHG emission inventories was 
only issued in 2009. 

* Ozone: In January 2010, EPA proposed more stringent ground-level 
ozone standards. Sixty-six responding airports are currently either in 
nonattainment and maintenance areas. The proposed standards will, 
according to EPA and FAA, increase the number of U.S. counties, and 
hence airports, that would be in nonattainment areas or maintenance 
areas and thus required to tighten controls on nitrogen oxides and 
some types of volatile organic compounds that also contribute to ozone 
formation. 

Several Environmental Strategies and Community Outreach Practices Can 
Help Airports Mitigate Delays and Address Environmental Issues: 

Some Airports Have Proactively Integrated Environmental Considerations 
into the Airport Planning Process: 

Incorporating environmental considerations early on in the planning 
process can help airports anticipate and address environmental 
impacts, as well as navigate the NEPA process. Such a holistic 
approach to managing environmental impacts, as opposed to an issue-by-
issue approach to environmental issues, may also help airports address 
the broader range of environmental issues that a number of surveyed 
airports predicted could potentially affect implementation of capital 
projects and operational changes. We have previously reported on the 
benefits of conducting long-range environmental planning for federal 
highway projects.[Footnote 74] For example, in 2008 we reported on 
legislative changes to the planning and environmental processes 
required of state and local transportation agencies for federally 
funded transportation projects. Several of these changes required 
early stakeholder participation, including (1) requiring plans for 
coordinating the participation of the public and federal and state 
agencies responsible for natural resources, environmental protection, 
and historic preservation; (2) obtaining public and resource agency 
participation in, and comment on, environmental reviews of projects; 
and (3) involving participating agencies and the public in defining a 
project's purpose and need and developing project alternatives. 
According to state departments of transportation, participating 
agencies, and other transportation stakeholders we contacted, these 
requirements may help improve project management, increase the 
likelihood of weeding out flawed alternatives early, and better inform 
and involve resource agencies.[Footnote 75] 

Seven of the 10 airports we visited have incorporated long-range 
environmental planning into their airport master planning process. FAA 
has issued best practices for preparing EISs which stress the need for 
airports to consider environmental factors as early as possible in 
planning projects in order to successfully complete the environmental 
review process in the least amount of time,[Footnote 76] and FAA noted 
it has conducted numerous workshops and conferences that encourage 
airports to integrate environmental issues into the planning process. 
According to Portland International Airport officials, expanding their 
2000 airport master plan to include sections devoted to environmental 
planning and citizen involvement and communications reduced opposition 
to airport projects. A recent ACRP report also found that early 
stakeholder coordination and consultation generally facilitated the 
transition from the planning process to the environmental review 
process, and ultimately to the initiation of project construction. 
[Footnote 77] Some airport officials and an aviation environmental 
expert also told us that early stakeholder engagement in the planning 
phase can improve stakeholder relationships and facilitate project 
implementation.[Footnote 78] City of Chicago officials, for example, 
told us that their decision to conduct extensive outreach and 
coordination early in the planning process for a major expansion of 
O'Hare International Airport helped them address environmental 
concerns early, get resource agencies and contractors on board in 
order to prevent potential delays and litigation, and gain project 
support from numerous communities surrounding the airport. 

According to FAA, a number of airports have expressed interest in a 
new FAA pilot program that allows AIP funds to be used to support long-
term airport environmental planning, be it in an airport master plan 
or a stand-alone sustainability document. Two airports (Ithaca 
Tompkins Regional Airport in New York and St. Augustine Airport in 
Florida) participated in the pilot program, and in April 2010, another 
eight airports were selected to participate. Selected airports must 
complete their long-term environmental plans within 2 years of 
receiving funding. FAA officials said they intend to track costs 
closely and ask airports for lessons learned to determine, among other 
things, (1) if there are differences in approaching environmental 
planning through an airport master plan, which most pilot participants 
are doing, or through a separate sustainability document; and (2) 
whether to require sustainability as a critical element in airport 
master plans. 

Streamlining the Environmental Review Process for Capacity Enhancement 
Projects at Congested Airports May Reduce Delays: 

The Aviation Streamlining Approval Process Act of 2003, enacted as 
part of Vision 100, introduced environmental streamlining for three 
types of projects, including capacity enhancement projects at 
congested airports.[Footnote 79] The environmental streamlining 
process enables FAA to better coordinate and expedite the 
environmental review process for such projects while complying with 
NEPA. According to FAA officials, three projects have successfully 
completed the streamlining process--projects at Chicago O'Hare 
International Airport, Philadelphia International Airport, and Ft. 
Lauderdale-Hollywood International Airport--while three projects are 
currently being streamlined, and one or two new projects will likely 
begin the streamlining process in the next year. FAA and EPA officials 
underscored that streamlining of capacity projects is reserved for 
airports where expansion is critical for handling the growth of air 
traffic; can mandate only federal--and not state--participation in the 
coordinated and expedited review process, which according to FAA does 
not diminish the process, but makes it more efficient; and requires 
more staff resources than traditional environmental reviews. 

According to FAA officials, airports have had limited interest in 
environmental streamlining, believing that it may add time to the 
environmental review process. While these officials acknowledged that 
the streamlining process requires more up-front time--agencies, for 
example, may initially negotiate a multiagency agreement that 
specifies each agency's roles and responsibilities and establishes 
review and permitting decision deadlines--they believe it expedites 
the overall review process. Both FAA and EPA officials, for example, 
said that streamlining expedited the EIS review for Chicago O'Hare's 
major modernization project. FAA officials noted that while a 
reviewing agency has occasionally fallen behind a decision deadline 
set forth in a multiagency streamlining agreement because of limited 
resources, FAA has used a liaison to help elevate the issue and obtain 
a relatively quick resolution. FAA officials also noted that state 
participation, which is encouraged by the act, is key to effective 
streamlining. They pointed to the EIS review at Philadelphia 
International Airport, which involved the cooperation of approximately 
18 federal and state agencies. FAA officials said the Ft. Lauderdale-
Hollywood International Airport streamlining process was not quite as 
smooth because FAA had to work separately with federal and state 
agencies. Several officials from federal agencies involved in the 
streamlined review process indicated that while they have met 
deadlines for completing their reviews, the reviews required more 
staff than usual and some stated that the reviews were not as detailed 
as they would have liked because their agency lacked the staff to 
dedicate someone full time to the endeavor. 

FAA and EPA officials we interviewed generally agreed that weak 
planning by airports, which are responsible for planning projects at 
their facilities, can complicate the review process, even if the EIS 
the FAA is required to prepare was slated for environmental 
streamlining.[Footnote 80] The EIS for one environmental project, for 
example, has been through the streamlining process, but to date FAA 
has not issued its record of decision. According to FAA and EPA 
officials, the project was not a good candidate for streamlining 
because the airport was not far along enough in the environmental 
process to warrant federal agencies reviewing its documentation. 
Specifically, the airport had not fully determined the proposed 
project's benefits (e.g., reducing congestion or increasing 
operational efficiency) at the time when those benefits needed to be 
assessed against environmental impacts. As a result, the airport was 
suggesting project alternatives that were not fully vetted. 

Integrating the EMS Processes and the NEPA Process Can Help Airports 
Mitigate and Reduce Their Environmental Impacts: 

In addition to helping airports better manage their day-to-day 
environmental impacts, an EMS's continuous self-monitoring cycle can 
help airports prepare for and address environmental issues that may 
arise during the NEPA process. As discussed above, about 80 surveyed 
airports have or plan to have an EMS. Both EPA and FAA endorse EMSs, 
and EPA has encouraged organizations to adopt them, underscoring that 
such systems have produced environmental benefits.[Footnote 81] In 
addition, ACI-NA has also set goals for its member airports to 
institute an EMS. Several airport officials we interviewed or who 
responded to our survey said that their EMSs had produced 
environmental benefits. Officials from one airport, for example, said 
that their EMS helped them establish pollution prevention, waste 
reduction, and energy efficiency goals for years, reduce the airport's 
environmental effects, and raise environmental awareness. Officials 
from another airport cited reduced disposal costs, emissions, and 
regulatory violations and penalties, and improved public opinion and 
relations with regulatory agencies. No airport official, however, 
mentioned their EMS in connection with preparing for the environmental 
review process. 

FAA, the Council on Environmental Quality (CEQ), and EPA, in 
conjunction with the Department of Energy (DOE), have each recognized 
the complementary nature--and encouraged the alignment--of the 
processes used in an EMS and the NEPA process. According to FAA, 
aligning the processes can, among other things, improve the quality of 
environmental analyses and decision-making.[Footnote 82] For example, 
FAA states that an EMS's continuous evaluation of environmental 
aspects of operations may provide a compilation of information for 
analyzing the cumulative environmental effects of a proposed project. 
Similarly, EPA's EMS Primer notes that integrating the two processes 
can help ensure that the right information gets to top decision makers 
in a timely manner.[Footnote 83] CEQ guidance details how elements of 
the two processes, such as communicating with stakeholders, can be 
better aligned.[Footnote 84] 

Effective Community Outreach Could Help to Mitigate Delays and Shape 
Environmental Actions: 

Airports that anticipate and effectively address community concerns 
about the environmental impacts of their daily operations, capital 
development projects, and operational changes during planning efforts 
are better positioned both to reduce the environmental impacts that 
are of most concern to the community and to minimize the likelihood of 
project implementation delays. In our survey, 21 airports said that a 
project was delayed because the community, environmental groups, or 
politicians opposed it on environmental grounds. Effective community 
outreach efforts by airports during their planning efforts and by FAA 
during the environmental process are critical. These efforts can 
enhance community members' understanding of the roles of airport 
managers and FAA in airport operations and development and the 
competing demands that most airports must balance. This understanding 
can help manage community expectations and facilitate community and 
airport cooperative efforts to address environmental concerns while 
meeting operational needs. ACRP's Community Toolkit predicts that 
community attitudes toward expanded and new airports will become an 
even more important element of airport system planning in light of 
anticipated increases in air travel demand. 

Our survey asked airports about certain aspects of their community 
outreach efforts, including what environmental information they made 
available to the public, how they conducted community outreach, and 
whether they evaluated the effectiveness of their community outreach 
efforts. As discussed below, their responses, along with interviews 
with airport and FAA staff and community group members, show that many 
airports are using some community outreach practices that we and 
others have identified as effective.[Footnote 85] However, our survey 
results and interviews also suggest that a number of airports could 
incorporate more effective community outreach practices, particularly 
with respect to evaluating their outreach efforts. 

Actively solicit stakeholder input and make key information readily 
available and understandable to all. Airports during their planning 
efforts should seek input from all community members that could 
potentially be affected by an airport decision or airport operations 
to ensure that all viewpoints are considered. A majority of responding 
airports used each of the following outreach methods identified in our 
survey--airport Web sites, local newspapers, and mail or e-mail--to 
notify community members of meetings, events, or news, while only 9 
percent used social media, such as Facebook or Twitter. Community 
members should also have access to and understand airport 
environmental and planning information in order to meaningfully 
participate in the process. Over half of responding surveyed airports--
and about 70 percent of larger airports--used at least one of the 
methods identified in our survey to make airport-related information 
readily available to community members. Noise issues have often been 
the focus of airport efforts to make information understandable to the 
public. 

In the future, airports may need to extend their outreach efforts to 
communities that they have not worked with in the past in order to 
reach all community members that could potentially be affected by 
airport operations, capital development projects, and new operational 
procedures. For example, with the changes in aircraft flight paths 
that will accompany NextGen and airspace redesign efforts, some 
communities that were previously unaffected by noise will be exposed 
to noise and may have concerns about those higher noise levels. We 
have also reported that noise complaints and demands for action to 
address noise are coming increasingly from outside the DNL contours 
where homes are not eligible for federal soundproofing assistance. 
[Footnote 86] 

Actively foster responsive, interactive communications. Interactive 
communication--both through formal forums, such as hearings, and 
informal meetings, which tend to provide a more collegial atmosphere-- 
promotes understanding between community members and decision makers. 
[Footnote 87] The results of our survey, which focused on more formal 
community participation methods, show that 109 airports, including 49 
larger airports--or just over 75 percent of all airports--reported 
holding public meetings. Several airport officials also told us they 
hosted informal meetings and other informal community events. In 
addition, 79 surveyed airports (56 percent), including 30 larger 
airports (48 percent) reported that their airport had a community 
roundtable or advisory committee that meets on a regularly-scheduled, 
ongoing basis. Our survey asked airports how often FAA officials, 
community group representatives, the general public, airport staff, 
air carrier staff, and consultants, attend community roundtable or 
community advisory committee meetings. As shown in figure 10, the 79 
airports that had community roundtables and advisory committees 
reported varying levels of participation by FAA officials. 
Furthermore, of the six stakeholder groups identified in the survey, 
airports said FAA officials were the least likely group to "always" or 
"usually" attend and the most likely group to "seldom" or "never" 
attend. Our survey did not ask the extent to which airports invited 
these stakeholder groups to attend community roundtables or advisory 
meetings.[Footnote 88] 

Figure 10: Surveyed Airports Responses to How Often FAA Officials 
Attend Community Roundtable or Advisory Committee Meetings: 

[Refer to PDF for image: stacked vertical bar graph] 

Always: 
Large and medium hub airports: 6; 
Other airports: 4. 

Usually: 
Large and medium hub airports: 6; 
Other airports: 2. 

Sometimes: 
Large and medium hub airports: 7; 
Other airports: 15. 

Seldom: 
Large and medium hub airports: 9; 
Other airports: 16. 

Never: 
Large and medium hub airports: 0; 
Other airports: 8. 	 

No answer: 
Large and medium hub airports: 1; 
Other airports: 3. 

Source: GAO survey. 

Note: Of 141 surveyed airports, 79 airports responded to this question. 

[End of figure] 

Because FAA plays a critical role in everyday airport operations, as 
well as in development projects and operational changes, its 
involvement in airport community forums can also enhance the 
effectiveness of community outreach efforts. FAA's Best Practices for 
EIS Management acknowledges that community confidence in FAA's 
commitment to effective environmental mitigation, as well as 
reasonable access to FAA staff to answer questions, help build local 
consensus and address community opposition. Accordingly, it recommends 
that knowledgeable people, "usually a combination of airport 
proprietor staff, EIS consultants, and FAA," attend informal community 
workshops during the environmental review process. Several airports we 
visited indicated that these roundtables or advisory committees were 
their most effective airport community participation program. 

Evaluate outreach efforts to enhance strategic community outreach. 
Both our previous work and ACRP's Community Toolkit underscore the 
importance of approaching community outreach strategically. We 
previously reported that a strategic approach requires that an airport 
identify all potentially affected or interested community members, 
define participation goals, create a plan for community participation, 
evaluate the results of its strategic approach, and make adjustments 
as needed. ACRP's Community Toolkit recommends that airports evaluate 
their community outreach program, including conducting a self- 
assessment of their program at least annually. Few airports responding 
to our survey, however, indicated that they had ever evaluated the 
effectiveness of their community outreach activities (see figure 11). 
Larger airports were not more likely to evaluate the effectiveness of 
their community outreach activities: Of the 29 airports (21 percent) 
that had done so, 11 were larger airports (17 percent). Airports that 
do not evaluate the effectiveness of their outreach efforts may be 
missing opportunities to identify and address weaknesses from their 
community participation efforts. For example, after surveying local 
communities, one of the airports we surveyed focused its outreach 
around those issues the public said they did not fully understand. 

Figure 11: Surveyed Airport Responses to Question about Evaluating 
Effectiveness of Community Outreach Activities: 

[Refer to PDF for image: pie-chart] 

Has your airport ever evaluated the effectiveness of its community 
outreach activities? 

Yes: 21%; 
No: 55%; 
Don't know: 24%. 

Source: GAO survey. 

[End of figure] 

Agency Comments: 

We provided a draft of this report to the Department of Transportation 
(DOT) and EPA for review and comment. We also provided a draft to the 
American Association of Airport Executives (AAAE) and ACI-NA in order 
to obtain comments reflecting the perspectives of airports and airport 
officials. DOT, EPA, and ACI-NA provided technical clarifications, 
which we incorporated into the report as appropriate. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no distribution of this report until 8 
days from the report date. At that time, we will send copies of this 
report to the Administrators of FAA and EPA and appropriate 
congressional committees. In addition, the report is available at no 
charge on the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions concerning this report, please 
contact me at (202) 512-2834 or dillinghamg@gao.gov. Contact points 
for our offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. GAO staff that made major 
contributions to this report are listed in appendix IV. 

Signed by: 

Gerald L. Dillingham, Ph.D. 
Director, Physical Infrastructure Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This report addressed the following objectives: (1) the actions that 
airports have taken to reduce environmental impacts of airport 
operations and development, (2) the extent to which airports believe 
that environmental issues have or will delay capital projects or 
operational changes, and (3) the strategies airports can adopt to 
mitigate delays in implementing capital projects and operational 
changes and address environmental issues. 

To address all of these objectives, we used a variety of methods and 
sources of information. We reviewed and synthesized information from 
relevant literature and our body of work on airport-related 
environmental issues. We interviewed officials from the Federal 
Aviation Administration (FAA), the Environmental Protection Agency 
(EPA), associations representing major airports in the United States, 
and selected environmental advocacy groups. We also interviewed 
officials from 10 airports (see appendix II), selected to include 
airports that have one or more of the following characteristics: have 
undertaken efforts to become "green" or more environmentally 
sustainable; have participated in FAA's Voluntary Airport Low 
Emissions (VALE) program; have been identified by FAA's Operational 
Evolution Partnership (OEP) or Future Airport Capacity Task 2 (FACT 2) 
studies as needing additional capacity; have community groups involved 
in environmental issues or have taken steps to reach out to such 
groups; are located in nonattainment or maintenance areas for 
identified criteria pollutants; and are dispersed in various regions 
of the country. As part of our work regarding these airports, we also 
interviewed FAA representatives from headquarters and 5 regional 
offices, officials from 6 regional EPA offices, 12 relevant state and 
local environmental regulatory agencies, 2 environmental advocacy 
groups, 7 metropolitan planning organizations, 3 aviation 
environmental experts, and 10 community groups. 

We also conducted a Web-based survey of knowledgeable airport 
officials from the 150 busiest U.S. airports in terms of the number of 
operations (departures or arrivals) from FAA's 2008 Air Carrier 
Activity Information System database. The survey and its results are 
available on the GAO Web site at GAO-10-748SP. Since responses to 
surveys are often subject to non-sampling errors, we attempted to 
minimize these errors by taking several precautions during the 
questionnaire design. To structure and gather expert opinions from the 
airport officials for the survey, we employed a pilot survey and 
obtained opinions from 19 airport officials using questionnaires 
administered over the Internet, which ran from September 28 to October 
10, 2008. We asked the airport officials to respond to 16 open-ended 
questions about the actions they take to reduce or control noise 
problems, water pollution, airport emissions and other environmental 
problems, and about the factors that help and that hinder airports in 
doing so. We performed a content analysis of the responses to these 
open-ended questions in order to help us design a comprehensive 
airport environmental survey consisting of both close-ended and open-
ended questions on the environmental impacts associated with the 
development and operations of airports and the actions airports are 
taking to balance these concerns. We pre-tested the comprehensive 
airport environmental survey with seven airports to ensure that the 
questionnaire was clear and unambiguous, and did not place undue 
burden on individuals completing it. We made relevant changes to the 
content and format of the final questionnaire as a result of these 
pretests. The questionnaire was administered on the Internet to the 
150 busiest U.S. airports from March 25 to June 8, 2009. We received 
responses from 141 airports, resulting in a 94 percent response rate. 
Appendix II provides the complete list of airports that responded to 
our survey. 

We conducted this performance audit from January 2008 through 
September 2010 in accordance with generally accepted government 
auditing standards. Those standards require that we plan and perform 
the audit to obtain sufficient, appropriate evidence to provide a 
reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 
objectives. 

[End of section] 

Appendix II: List of Airports That Responded to Our Survey and We 
Visited: 

Airport, location, and type: 

Name: Acadiana Regional; 
ID: ARA; 
City: New Iberia; 
State: LA; 
Type: GA; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Addison; 
ID: ADS; 
City: Dallas; 
State: TX; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Albuquerque International Sunport; 
ID: ABQ; 
City: Albuquerque; 
State: NM; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: 2009; 
Nonattainment: [Check]. 

Name: Arlington Municipal; 
ID: GKY; 
City: Arlington; 
State: TX; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Austin-Bergstrom International; 
ID: AUS; 
City: Austin; 
State: TX; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Baltimore/Washington International Thurgood Marshall; 
ID: BWI; 
City: Baltimore; 
State: MD; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Barnstable Municipal-Boardman/Polando Field; 
ID: HYA; 
City: Hyannis; 
State: MA; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Bob Hope; 
ID: BUR; 
City: Burbank; 
State: CA; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Boeing Field/King County International; 
ID: BFI; 
City: Seattle; 
State: WA; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Brackett Field; 
ID: POC; 
City: La Verne; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Bradley International; 
ID: BDL; 
City: Windsor Locks; 
State: CT; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Buffalo Niagara International; 
ID: BUF; 
City: Buffalo; 
State: NY; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Camarillo; 
ID: CMA; 
City: Camarillo; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Castle; 
ID: MER; 
City: Merced; 
State: CA; 
Type: GA; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Centennial; 
ID: APA; 
City: Denver; 
State: CO; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Charlotte/Douglas International; 
ID: CLT; 
City: Charlotte; 
State: NC; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Chicago Midway International; 
ID: MDW; 
City: Chicago; 
State: IL; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Chicago O'Hare International*; 
ID: ORD; 
City: Chicago; 
State: IL; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Chino; 
ID: CNO; 
City: Chino; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Cincinnati/Northern Kentucky International; 
ID: CVG; 
City: Covington; 
State: KY; 
Type: MH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: 2009; 
Nonattainment: [Check]. 

Name: City of Colorado Springs Municipal; 
ID: COS; 
City: Colorado Springs; 
State: CO; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Cleveland-Hopkins Municipal; 
ID: CLE; 
City: Cleveland; 
State: OH; 
Type: MH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Craig Municipal; 
ID: CRG; 
City: Jacksonville; 
State: FL; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Dallas Love Field; 
ID: DAL; 
City: Dallas; 
State: TX; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Dallas/Fort Worth International; 
ID: DFW; 
City: Dallas/Ft Worth; 
State: TX; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Daytona Beach International; 
ID: DAB; 
City: Daytona Beach; 
State: FL; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Dekalb-Peachtree; 
ID: PDK; 
City: Atlanta; 
State: GA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Denver International; 
ID: DEN; 
City: Denver; 
State: CO; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Detroit Metropolitan Wayne County; 
ID: DTW; 
City: Detroit; 
State: MI; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: 2007; 
Nonattainment: [Check]. 

Name: Eppley Airfield; 
ID: OMA; 
City: Omaha; 
State: NE; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Ernest A. Love Field; 
ID: PRC; 
City: Prescott; 
State: AZ; 
Type: NH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Executive; 
ID: ORL; 
City: Orlando; 
State: FL; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Falcon Field; 
ID: FFZ; 
City: Mesa; 
State: AZ; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Flying Cloud; 
ID: FCM; 
City: Eden Prairie; 
State: MN; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Fort Lauderdale Executive; 
ID: FXE; 
City: Fort Lauderdale; 
State: FL; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Fort Lauderdale/Hollywood International; 
ID: FLL; 
City: Fort Lauderdale; 
State: FL; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Fort Worth Meacham International; 
ID: FTW; 
City: Fort Worth; 
State: TX; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: General Edward Lawrence Logan International; 
ID: BOS; 
City: Boston; 
State: MA; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: General Mitchell International; 
ID: MKE; 
City: Milwaukee; 
State: WI; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: George Bush Intercontinental/Houston; 
ID: IAH; 
City: Houston; 
State: TX; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: 2005; 
Nonattainment: [Check]. 

Name: Gillespie Field; 
ID: SEE; 
City: San Diego/El Cajon; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Glendale Municipal; 
ID: GEU; 
City: Glendale; 
State: AZ; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Grand Forks International; 
ID: GFK; 
City: Grand Forks; 
State: ND; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Hartsfield-Jackson Atlanta International; 
ID: ATL; 
City: Atlanta; 
State: GA; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Hayward Executive; 
ID: HWD; 
City: Hayward; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Honolulu International; 
ID: HNL; 
City: Honolulu; 
State: HI; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Indianapolis International; 
ID: IND; 
City: Indianapolis; 
State: IN; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: John F. Kennedy International*; 
ID: JFK; 
City: New York; 
State: NY; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: John Wayne Airport-Orange County; 
ID: SNA; 
City: Santa Ana; 
State: CA; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Kahului; 
ID: OGG; 
City: Kahului; 
State: HI; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Kansas City International; 
ID: MCI; 
City: Kansas City; 
State: MO; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Kendall-Tamiami Executive; 
ID: TMB; 
City: Miami; 
State: FL; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Kissimmee Gateway; 
ID: ISM; 
City: Orlando; 
State: FL; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Kona International at Keahole; 
ID: KOA; 
City: Kailua/Kona; 
State: HI; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: LaGuardia; 
ID: LGA; 
City: New York; 
State: NY; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Lakeland Linder Regional; 
ID: LAL; 
City: Lakeland; 
State: FL; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Lambert-St. Louis International; 
ID: STL; 
City: St. Louis; 
State: MO; 
Type: MH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Laurence G. Hanscom Field; 
ID: BED; 
City: Bedford; 
State: MA; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Lehigh Valley International; 
ID: ABE; 
City: Allentown; 
State: PA; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Livermore Municipal; 
ID: LVK; 
City: Livermore; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Long Beach/Daugherty Field*; 
ID: LGB; 
City: Long Beach; 
State: CA; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Long Island MacArthur; 
ID: ISP; 
City: Islip; 
State: NY; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Los Angeles International*; 
ID: LAX; 
City: Los Angeles; 
State: CA; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Louis Armstrong New Orleans International; 
ID: MSY; 
City: New Orleans; 
State: LA; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Louisville International-Standiford Field; 
ID: SDF; 
City: Louisville; 
State: KY; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Luis Munoz Marin International; 
ID: SJU; 
City: San Juan; 
State: PR; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: McCarran International; 
ID: LAS; 
City: Las Vegas; 
State: NV; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: McClellan-Palomar; 
ID: CRQ; 
City: Carlsbad; 
State: CA; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: McGhee Tyson; 
ID: TYS; 
City: Knoxville; 
State: TN; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Meadows Field; 
ID: BFL; 
City: Bakersfield; 
State: CA; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Melbourne International; 
ID: MLB; 
City: Melbourne; 
State: FL; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Memphis International; 
ID: MEM; 
City: Memphis; 
State: TN; 
Type: MH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Merrill Field; 
ID: MRI; 
City: Anchorage; 
State: AK; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Metropolitan Oakland International; 
ID: OAK; 
City: Oakland; 
State: CA; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Check]; 
VALE: 2010; 
Nonattainment: [Check]. 

Name: Miami International; 
ID: MIA; 
City: Miami; 
State: FL; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Minneapolis-St Paul International/Wold Chamberlain; 
ID: MSP; 
City: Minneapolis; 
State: MN; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Montgomery Field; 
ID: MYF; 
City: San Diego; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Morristown Municipal; 
ID: MMU; 
City: Morristown; 
State: NJ; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Nantucket Memorial; 
ID: ACK; 
City: Nantucket; 
State: MA; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Napa County; 
ID: APC; 
City: Napa; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Naples Municipal*; 
ID: APF; 
City: Naples; 
State: FL; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Nashville International; 
ID: BNA; 
City: Nashville; 
State: TN; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Newark Liberty International; 
ID: EWR; 
City: Newark; 
State: NJ; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Norman Y. Mineta San Jose International; 
ID: SJC; 
City: San Jose; 
State: CA; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: 2009; 
Nonattainment: [Check]. 

Name: North Las Vegas; 
ID: VGT; 
City: Las Vegas; 
State: NV; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: North Perry; 
ID: HWO; 
City: Hollywood; 
State: FL; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Oakland County International; 
ID: PTK; 
City: Pontiac; 
State: MI; 
[Empty]; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Ontario International; 
ID: ONT; 
City: Ontario; 
State: CA; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Orlando International; 
ID: MCO; 
City: Orlando; 
State: FL; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Orlando Sanford International; 
ID: SFB; 
City: Orlando; 
State: FL; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Ormond Beach Municipal; 
ID: OMN; 
City: Ormond Beach; 
State: FL; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Palm Beach International*; 
ID: PBI; 
City: West Palm Beach; 
State: FL; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Palo Alto Airport of Santa Clara County; 
ID: PAO; 
City: Palo Alto; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Philadelphia International*; 
ID: PHL; 
City: Philadelphia; 
State: PA; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: 2008; 
Nonattainment: [Check]. 

Name: Phoenix Deer Valley; 
ID: DVT; 
City: Phoenix; 
State: AZ; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Phoenix Goodyear; 
ID: GYR; 
City: Goodyear; 
State: AZ; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Phoenix Sky Harbor International; 
ID: PHX; 
City: Phoenix; 
State: AZ; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Phoenix-Mesa Gateway; 
ID: IWA; 
City: Phoenix; 
State: AZ; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Pittsburgh International; 
ID: PIT; 
City: Pittsburgh; 
State: PA; 
Type: MH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Pompano Beach Airpark; 
ID: PMP; 
City: Pompano Beach; 
State: FL; 
Type: GA; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Port Columbus International; 
ID: CMH; 
City: Columbus; 
State: OH; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Portland International*; 
ID: PDX; 
City: Portland; 
State: OR; 
Type: MH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Portland-Hillsboro; 
ID: HIO; 
City: Portland; 
State: OR; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Pueblo Memorial; 
ID: PUB; 
City: Pueblo; 
State: CO; 
Type: CS; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Raleigh-Durham International; 
ID: RDU; 
City: Raleigh/Durham; 
State: NC; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Ramona; 
ID: RNM; 
City: Ramona; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Reid-Hillview of Santa Clara County; 
ID: RHV; 
City: San Jose; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Reno-Tahoe International; 
ID: RNO; 
City: Reno; 
State: NV; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Republic; 
ID: FRG; 
City: Farmingdale; 
State: NY; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Richard Lloyd Jones Jr; 
ID: RVS; 
City: Tulsa; 
State: OK; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Rocky Mountain Metropolitan; 
ID: BJC; 
City: Denver; 
State: CO; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Ronald Reagan Washington National; 
ID: DCA; 
City: Arlington; 
State: VA; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Ryan Field; 
ID: RYN; 
City: Tucson; 
State: AZ; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Sacramento International; 
ID: SMF; 
City: Sacramento; 
State: CA; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Salt Lake City International; 
ID: SLC; 
City: Salt Lake City; 
State: UT; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: San Antonio International; 
ID: SAT; 
City: San Antonio; 
State: TX; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: San Carlos; 
ID: SQL; 
City: San Carlos; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: San Diego International; 
ID: SAN; 
City: San Diego; 
State: CA; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: San Francisco International; 
ID: SFO; 
City: San Francisco; 
State: CA; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: 2009; 
Nonattainment: [Check]. 

Name: Santa Monica Municipal; 
ID: SMO; 
City: Santa Monica; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Sarasota/Bradenton International; 
ID: SRQ; 
City: Sarasota/Bradenton; 
State: FL; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Scottsdale; 
ID: SDL; 
City: Scottsdale; 
State: AZ; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Seattle-Tacoma International*; 
ID: SEA; 
City: Seattle; 
State: WA; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Snohomish County (Paine Field); 
ID: PAE; 
City: Everett; 
State: WA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Space Coast Regional; 
ID: TIX; 
City: Titusville; 
State: FL; 
Type: GA; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: St. Lucie County International; 
ID: FPR; 
City: Fort Pierce; 
State: FL; 
Type: GA; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: St. Petersburg-Clearwater International; 
ID: PIE; 
City: St. Petersburg-Clearwater; 
State: FL; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Stinson Municipal; 
ID: SSF; 
City: San Antonio; 
State: TX; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Tampa International; 
ID: TPA; 
City: Tampa; 
State: FL; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Ted Stevens Anchorage International; 
ID: ANC; 
City: Anchorage; 
State: AK; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Teterboro; 
ID: TEB; 
City: Teterboro; 
State: NJ; 
Type: NP; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Tucson International; 
ID: TUS; 
City: Tucson; 
State: AZ; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Tulsa International; 
ID: TUL; 
City: Tulsa; 
State: OK; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Van Nuys; 
ID: VNY; 
City: Van Nuys; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Vero Beach Municipal; 
ID: VRB; 
City: Vero Beach; 
State: FL; 
Type: GA; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Washington Dulles International; 
ID: IAD; 
City: Chantilly; 
State: VA; 
Type: LH; 
OEP: [Check]; 
FACT 2: [Check]; 
VALE: [Empty]; 
Nonattainment: [Check]. 

Name: Westchester County; 
ID: HPN; 
City: White Plains; 
State: NY; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: 2008; 
Nonattainment: [Check]. 

Name: Wichita Mid-Continent; 
ID: ICT; 
City: Wichita; 
State: KS; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: Will Rogers World; 
ID: OKC; 
City: Oklahoma City; 
State: OK; 
Type: SH; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Name: William P. Hobby; 
ID: HOU; 
City: Houston; 
State: TX; 
Type: MH; 
OEP: [Empty]; 
FACT 2: [Check]; 
VALE: 2006; 
Nonattainment: [Check]. 

Name: Zamperini Field; 
ID: TOA; 
City: Torrance; 
State: CA; 
Type: R; 
OEP: [Empty]; 
FACT 2: [Empty]; 
VALE: [Empty]; 
Nonattainment: [Empty]. 

Source: GAO analysis of FAA data. 

Notes: 

An asterisk beside an airport indicates we visited that airport. We 
also visited but did not survey Southwest Florida International 
Airport (RSW) in Fort Myers, Fl., for a total of 10 airports. 

Airport categories based on passenger boardings: 

LH = large hub commercial service airport with 1 percent or more of 
total annual passenger boardings: 

MH = medium hub commercial service airport with at least 0.25 percent 
but less than 1 percent of total annual passenger boardings: 

SH = small hub commercial service airport with at least 0.05 percent 
but less than 0.25 percent of total annual passenger boardings: 

NH = nonhub commercial service airport with at least 10,000 boardings 
but less than 0.05 percent of total annual passenger boardings: 

CS = nonprimary commercial service airport with more than 2,500 
boardings but less than 10,000 enplanements: 

GA = general aviation airport: 

R = reliever airport, an airport designated by the FAA to relieve 
congestion at a commercial service airport and to provide improved 
general aviation access to the overall community. A reliever airport 
may be publicly or privately-owned. 

Large and medium hub airports are from FAA's 2008 Enplanement Data. 

The Future Airport Capacity Task 2 (FACT 2) airports are airports and 
metropolitan areas needing additional capacity in 2025 without planned 
improvements. 

VALE = Voluntary Airport Lower Emissions program and the year the 
airport first participated. 

Nonattainment and maintenance = If the airport resided within this EPA 
designated area as of January 23, 2009. 

[End of table] 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Gerald Dillingham, Ph.D. (202) 512-2834 or dillinghamg@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Paul Aussendorf (Assistant 
Director), Ed Laughlin (Assistant Director), Mark Braza, Lauren 
Calhoun, Jim Geibel, Brandon Haller, Nick Jepson, Delwen Jones, 
Kirsten Lauber, Rosa Leung, Jessica Lucas-Judy, Heather May, Kelly 
Rubin, and Jerry Sandau made key contributions to this report. 

[End of section] 

Related GAO Products: 

National Airspace System: FAA Reauthorization Issues Are Critical to 
System Transformation and Operations. [hyperlink, 
http://www.gao.gov/products/GAO-09-377T]. Washington, D.C.: February 
11, 2009. 

Aviation and the Environment: Initial Voluntary Airport Low Emissions 
Program Projects Reduce Emissions, and FAA Plans to Assess the 
Program's Overall Performance as Participation Increases. [hyperlink, 
http://www.gao.gov/products/GAO-09-37]. Washington, D.C.: November 7, 
2008. 

Aviation and the Environment: NextGen and Research and Development Are 
Keys to Reducing Emissions and Their Impact on Health and Climate. 
[hyperlink, http://www.gao.gov/products/GAO-08-706T]. Washington, 
D.C.: May 6, 2008. 

Aviation and the Environment: FAA's and NASA's Research and 
Development Plans for Noise Reduction Are Aligned, but the Prospects 
of Achieving Noise Reduction Goals Are Uncertain. [hyperlink, 
http://www.gao.gov/products/GAO-08-384]. Washington, D.C.: February 
15, 2008. 

Aviation and the Environment: Impact of Aviation Noise on Communities 
Presents Challenges for Airport Operations and Future Growth of the 
National Airspace System. [hyperlink, 
http://www.gao.gov/products/GAO-08-216T]. Washington, D.C.: October 
24, 2007. 

Aviation and the Environment: Strategic Framework Needed to Address 
Challenges Posed by Aircraft Emissions. [hyperlink, 
http://www.gao.gov/products/GAO-03-252]. Washington, D.C.: February 
28, 2003. 

Aviation and the Environment: Transition to Quieter Aircraft Occurred 
as Planned, but Concerns about Noise Persist. [hyperlink, 
http://www.gao.gov/products/GAO-01-1053]. Washington, D.C.: September 
28, 2001. 

Aviation and the Environment: Federally Authorized Funding for Noise- 
Related Projects. [hyperlink, 
http://www.gao.gov/products/GAO/RCED-00-285R]. Washington, D.C.: 
September 27, 2000. 

Aviation and the Environment: Results from a Survey of the Nation's 50 
Busiest Commercial Service Airports. [hyperlink, 
http://www.gao.gov/products/GAO/RCED-00-222]. Washington, D.C.: August 
30, 2000. 

Aviation and the Environment: Airport Operations and Future Growth 
Present Environmental Challenges. [hyperlink, 
http://www.gao.gov/products/GAO/RCED-00-153]. Washington, D.C.: August 
30, 2000. 

Aviation and the Environment: FAA's Role in Major Airport Noise 
Programs. [hyperlink, http://www.gao.gov/products/GAO/RCED-00-98]. 
Washington, D.C.: April 28, 2000. 

Aviation and the Environment: Aviation's Effects on the Global 
Atmosphere Are Potentially Significant and Expected to Grow. 
[hyperlink, http://www.gao.gov/products/GAO/RCED-00-57]. Washington, 
D.C.: February 18, 2000. 

[End of section] 

Footnotes: 

[1] GAO, National Airspace System: Regional Airport Planning Could 
Help Address Congestion If Plans Were Integrated with FAA and Airport 
Decision Making, [hyperlink, http://www.gao.gov/products/GAO-10-120] 
(Washington, D.C.: Dec. 23, 2009). DOT OIG, Observations on Short-term 
Capacity Initiatives, AV-2008-087 (Washington, D.C.: Sept. 26, 2008). 
Adie Turner and Robert Puentas, Expect Delays: An Analysis of Air 
Travel Trends in the United States, Metropolitan Policy Program at 
Brookings (October 2009).   

[2] GAO, Aviation and the Environment: Impact of Aviation Noise on 
Communities Presents Challenges for Airport Operations and Future 
Growth of the National Airspace System, [hyperlink, 
http://www.gao.gov/products/GAO-08-216T] (Washington, D.C.: Oct. 24, 
2007). 

[3] See GAO, Aviation Infrastructure: Challenges Related to Building 
Runways and Actions to Address Them, [hyperlink, 
http://www.gao.gov/products/GAO-03-164] (Washington, D.C.: Jan. 30, 
2003). 

[4] See Statement of Victoria Cox, Vice President for Operations 
Planning Services, FAA, Before the House Committee on Transportation 
and Infrastructure, Subcommittee on Aviation on Air Traffic Control 
Modernization and NextGen: Near Term Achievable Goals (Mar. 18, 2009). 

[5] OEP airports are commercial U.S. airports with significant 
activity. These airports serve major metropolitan areas and also serve 
as hubs for airline operations. The OEP airports were identified in 
2000 based on lists from FAA and Congress, as well as a study that 
identified the most congested U.S. airports. 

[6] FAA's 2007 report, Capacity Needs in the National Airspace System 
2007-2025: An Analysis of Airports and Metropolitan Area Demand and 
Operational Capacity in the Future, (Washington, D.C.: May 2007) (FACT 
2), among other things, identifies airports that it predicts will face 
significant capacity constraints by 2015 and 2025 under two different 
scenarios: (1) if planned improvements, such as airspace redesign or 
new or extended runways, are carried out and (2) if planned 
improvements do not occur. See GAO, National Airspace System: Regional 
Airport Planning Could Help Address Congestion If Plans Were 
Integrated with FAA and Airport Decision Making, [hyperlink, 
http://www.gao.gov/products/GAO-10-120] (Washington, D.C.: Dec. 23, 
2009) for a detailed discussion of the FACT 2 report and its forecasts. 

[7] FAA categorizes the nation's commercial airports into four main 
groups based on the number of passenger enplanements--large hubs, 
medium hubs, small hubs, and nonhubs. The categories are based on the 
number of passengers boarding an aircraft (enplaned) within the United 
States. A large hub enplanes at least 1 percent of all systemwide 
passengers, a medium hub at least 0.25 but fewer than 1 percent, a 
small hub at least 0.05, but fewer than to 0.25 percent, and a nonhub 
less than 0.05 percent. See 49 U.S.C. § 47102. The 66 large and medium 
hub airports are based on FAA's 2008 enplanement data. 

[8] GAO, Airport Finance: Observations on Planned Airport Development 
Costs and Funding Levels and the Administration's Proposed Changes in 
the Airport Improvement Program, [hyperlink, 
http://www.gao.gov/products/GAO-07-885] (Washington, D.C.: June 29, 
2007). 

[9] We surveyed the 150 busiest airports as measured by operations 
(the number of landings and takeoffs) for calendar year 2008, as 
reported by FAA. 

[10] One FACT 2 airport, T.F. Green Airport in Warwick, Rhode Island, 
was not included in our survey. 

[11] The group of general aviation airports we surveyed includes 
reliever airports, which according to FAA, are airports designated by 
FAA to relieve congestion at commercial service airports and to 
provide improved general aviation access to the overall community. 
General aviation airports are the largest single group of airports in 
the U.S. system. This category also includes privately owned, public 
use airports that enplane 2,500 or more passengers annually and 
receive scheduled airline service. 

[12] The Clean Air Act of 1970, as amended, requires the Environmental 
Protection Agency (EPA) to set national ambient air quality standards 
for six air pollutants, known as criteria pollutants, to protect 
public health and the environment: nitrogen oxides (NOx), sulfur 
oxides (SOx), carbon monoxide (CO), ozone (O3), particulate matter 
(PM), and lead (Pb). 42 U.S.C. 7409; 40 C.F.R. part 50. Geographic 
areas that have levels of a criteria pollutant above those allowed by 
the standard are called nonattainment areas. 

[13] This report focuses on airport-level sources of pollution, 
specifically, those environmental impacts we asked about in depth on 
our survey: noise, water pollution, emissions, and environmental 
sustainability. Airports can also have other environmental impacts, 
including those that may affect endangered species, wetlands, cultural 
sites (such as historic buildings, churches, and cemeteries), and 
protected lands (such as national and state parks). 

[14] 14 C.F.R. part 150. 

[15] Pub. L. No. 91-190, 83 Stat. 852, codified, as amended, at 42 
U.S.C. § 4321 et seq. According to FAA, Environmental Impacts: 
Policies and Procedures Order 1050.1E, March 20, 2006, all formal 
actions taken by FAA officials are subject to NEPA review unless 
statutory law applicable to the FAA's operations expressly prohibits 
or makes compliance impossible, or are otherwise excepted by NEPA 
regulations. Actions covered by NEPA review include grants, loans, 
contracts, leases, construction, research activities, rulemaking and 
regulatory actions, certifications, licensing, permits, plans 
submitted to the FAA that require FAA approval, and legislation 
proposed by FAA. 

[16] DNL is a noise descriptor or metric that takes into account the 
magnitude of the sound levels of all individual events that occur 
during a 24-hour period, the number of events, and an increased 
sensitivity to noise during typical sleeping hours (between 10:00 p.m. 
and 7:00 a.m.). Although FAA requires the use of DNL for airport 
analyses, it also promotes the use of supplemental metrics, which 
according to the Federal Interagency Committee on Aviation Noise, are 
also useful in addressing various public noise concerns and helping 
the public to further understand airport-related noise impacts. 

[17] Pub. L. No. 101-508, 104 Stat. 1388, 1388-378--384. 

[18] 14 CFR Part 36. 

[19] FAA, Aviation and the Environment: A National Vision Statement, 
Framework for Goals and Recommended Actions (Washington, D.C.: 
December 2004). 

[20] According to EPA, in 2002, for the 10 non-attainment areas with 
busy airports, nitrogen oxide emission contributions ranged from 1 
percent to 7.1 percent; for volatile organic compounds (which 
contribute to ozone formation) the range was 0.9 to 2.3 percent and 
the range for PM (2.5 micrometers) was 0.8 to 3.2 percent. EPA noted 
that the percentages are expected to increase by a factor of 2 to 3 in 
the upcoming decade. 

[21] An ACRP report estimates that commercial airlines account for 11 
percent of U.S. GHG emissions from transportation sources, the third 
largest source of transportation GHG emissions, behind automobiles and 
personal trucks. For a discussion of options that airlines and others 
are taking to reduce aircraft GHG and other emissions, see GAO, 
Aviation and Climate Change: Aircraft Emissions Expected to Grow, but 
Technological and Operational Improvements and Government Policies Can 
Help Control Emissions, [hyperlink, 
http://www.gao.gov/products/GAO-09-554] (Washington, D.C.: June 8, 
2009). 

[22] According to FAA, commercial service airports are publicly-owned 
airports that have at least 2,500 passenger boardings each calendar 
year and receive scheduled passenger service. 

[23] Maintenance areas are areas that did not meet the standard for a 
criteria pollutant in the past but have reached attainment and met 
certain procedural requirements. 

[24] 33 U.S.C. § 1251 et seq. 

[25] See GAO, Measuring Our Nation's Natural Resources and 
Environmental Sustainability: Highlights of a Forum Jointly Convened 
by the Comptroller General of the United States and the National 
Academy of Science, [hyperlink, 
http://www.gao.gov/products/GAO-08-127SP] (Washington, D.C.: Oct. 24, 
2007). 

[26] 14 C.F.R. part 36. ICAO is an organization affiliated with the 
United Nations that aims to promote the establishment of international 
civilian aviation standards and recommended practices and procedures. 
FAA, as the U.S. representative to ICAO, in consultation with EPA, 
works with representatives from other countries to set certain 
environmental standards, including for noise. 

[27] Pub. L. No. 101-508, 104 Stat. 1388, 1388-378--384. ANCA required 
the phase-out Stage 2 aircraft (older aircraft that did not meet the 
ICAO standard existing at the time for aircraft, i.e. Stage 3 
aircraft) by December 31, 1999, with certain exceptions. Pursuant to 
this requirement, specific aircraft operators had to transition from 
Stage 2 to Stage 3 aircraft. ANCA also resulted in new regulations 
affecting the airport proprietors, the Part 161 regulations (14 C.F.R. 
part 161) that limit the ability of airports to impose limits on their 
operations. Now, regardless of the nature of the local Stage 2 
restrictions--whether involving aircraft flight procedures or ground 
restrictions--ANCA requires airports to seek public and FAA comment 
before instituting any such restrictions. 

[28] Pub. L. No. 96-193, § 103, 94 Stat. 50, 51, codified as amended 
at 49 U.S.C. § 47505. 

[29] The CNEL, like DNL, is used to characterize average noise levels 
over a 24-hour period. Both assign additional weight to aircraft 
sounds occurring between 10:00 p.m. and 7:00 a.m. However, CNEL 
assigns an additional weight for aircraft sounds occurring between 
7:00 p.m. and 10:00 p.m. 

[30] For example, according to FAA, it ensures compliance by reviewing 
and approving certification test plans, procedures, test reports, and 
engine emissions certification levels. 

[31] Other federal laws may affect airport expansion, such as the 
National Historic Preservation Act, which requires any agency 
providing federal assistance to a project, prior to the approval of 
the expenditure of any federal funds, to take into account the effect 
of the undertaking on any district, site, building, structure, or 
object that is included in or eligible for inclusion in the National 
Register. The act may apply when airport operations or airport 
development projects, including their associated air pollution 
emissions, affect cultural or historic resources. 

[32] See 40 C.F.R. part 112. 

[33] 40 C.F.R. part 117. 

[34] 42 U.S.C. § 4321 et seq. According to FAA, Environmental Impacts: 
Policies and Procedures Order 1050.1E, March 20, 2006, all formal 
actions taken by FAA officials are subject to NEPA review unless 
statutory law applicable to the FAA's operations expressly prohibits 
or makes compliance impossible, or are otherwise excepted by NEPA 
regulations. Actions covered by NEPA review include grants, loans, 
contracts, leases, construction, research activities, rulemaking and 
regulatory actions, certifications, licensing, permits, plans 
submitted to the FAA that require FAA approval, and legislation 
proposed by the FAA. 

[35] According to FAA, approximately 40 percent of airport projects 
undergo the less rigorous EA, while less than 1 percent of airport 
projects require an EIS. The remaining 60 percent of projects, 
according to FAA, are categorically excluded under NEPA. When an 
agency determines that proposed activities fall within a category of 
activities the agency has already determined has no significant impact-
-called a categorical exclusion--then the agency generally need not 
prepare an environmental assessment or environmental impact statement. 
A federal action may be categorically excluded--thus exempting it from 
the federal environmental review process--if, based on agency 
experience, the proposed action does not individually or cumulatively 
have a significant effect on the environment. See 40 C.F.R. § 1508.4. 

[36] 40 C.F.R. § 1506.6 (c). 

[37] FAA Order 1050.1E, Chg 1, which is the most recent version, was 
updated on March 20, 2006. FAA Order 5050.4B addresses NEPA 
requirements specifically for airport actions. 

[38] 42 U.S.C. § 7506(c)(1) (the Conformity Provision). 

[39] States are required to submit implementation plans to EPA setting 
forth the state strategy for eliminating or reducing emissions in 
areas that fail to meet the National Ambient Air Quality Standards set 
by EPA under the Clean Air Act for criteria pollutants. 

[40] 33 U.S.C. § 1344(a). 

[41] FAA, National Environmental Policy Act (NEPA) Implementing 
Instructions for Airport Actions, Order 5050.4B April 28, 2006; Desk 
Reference for Airport Actions, October 2007; Environmental Impacts: 
Policies and Procedures, Order 1050.1E, Change 1, March 20, 2006; 
Environmental Management Systems for Airport Sponsors, Advisory 
Circular 150/5050-8, September 26, 2007; and Air Quality Handbook, 
June 2, 2005. 

[42] An EMS is a management tool that enables an organization to 
identify and control the environmental impact of its activities; 
improve its environmental performance; and implement a systematic 
approach to setting environmental goals and demonstrating that they 
have been achieved. 

[43] Vision 100-Century of Aviation Reauthorization Act, Pub. L. No. 
108-176, 177 Stat. 2490, §§ 121, 151, 158, and 159 (2003), established 
a voluntary program to reduce ground emissions at commercial service 
airports in air quality nonattainment and maintenance areas. To 
implement the Vision 100 provisions relating to airport emissions 
reductions, FAA created and began administering the VALE program in 
2005. Consistent with the authorizing legislation, airports eligible 
for the VALE program can apply for federal AIP funds "set aside" for 
noise and air quality projects or, with FAA approval, use Passenger 
Facilities Charges (PFC), which airports can collect from passengers 
to use for eligible airport development projects, to fund low-
emissions projects. See GAO, Aviation and the Environment: Initial 
Voluntary Airport Low Emissions Program Projects Reduce Emissions, and 
FAA Plans to Assess the Program's Overall Performance as Participation 
Increases, [hyperlink, http://www.gao.gov/products/GAO-09-37] 
(Washington, D.C.: Nov. 7, 2008). 

[44] FAA's VALE program seeks to reduce airport ground emissions by 
providing financing for low emission vehicles, refueling and 
recharging stations, gate electrification, and other airport air 
quality improvements at commercial service airports located in 
designated air quality nonattainment and maintenance areas. 

[45] Our survey did not ask airports to distinguish between actions 
taken to reduce their environmental impacts as part of their day-to-
day operations and those taken to mitigate their environmental impacts 
identified in the NEPA process in connection with an airport project 
or operational change. 

[46] The most common methods of complaint collection was by phone 
hotline (111 airports), Web site (71 airports), and an online 
complaint form (53 airports). 

[47] Sound Exposure Level (SEL) is a measure of duration and magnitude 
of a single noise event. Equivalent Sound Level (Leq) is the average 
noise level over a specified time period, such as during school hours. 
Maximum Sound Level (Lmax) is commonly used to describe the maximum 
noise level from a single event. 

[48] Although often voluntary, some noise abatement operational 
procedures may be instituted at airports to mitigate noise problems 
identified in a NEPA environmental review. 

[49] These new flight procedures are currently used only for a limited 
number of approaches and landings at airports. RNP procedures also can 
have other environmental benefits including reducing an aircraft's 
consumption of fuel and lowering its emissions of carbon dioxide and 
nitrogen oxides. GAO, Next Generation Air Transportation System: FAA 
Faces challenges in Responding to Task force Recommendations, 
[hyperlink, http://www.gao.gov/products/GAO-10-188T] (Washington, 
D.C.: Oct. 28, 2009) and GAO, Aviation and the Environment: Impact of 
Aviation Noise on Communities Presents Challenges for Airport 
Operations and Future Growth of the National Airspace System, 
[hyperlink, http://www.gao.gov/products/GAO-08-216T] (Washington, 
D.C.: Oct. 24, 2007). 

[50] A navigational easement permits free flights over the land in 
question. United States v. Brondum, 272 F.2d 642, 645 (5th Cir. 1959). 

[51] Such commercial buildings include offices, portions of retail 
stores where the public is received or other noise sensitive areas 
within commercial buildings. 

[52] Nor did we evaluate airports' self-reported assessments of the 
reduced environmental impacts of their actions in the three other key 
environmental areas covered in our survey. 

[53] GAO, Aviation and the Environment: Strategic Framework Needed to 
Address Challenges Posed by Aircraft Emissions, [hyperlink, 
http://www.gao.gov/products/GAO-03-252] (Washington D.C.: Feb. 28, 
2003). 

[54] According to EPA, approximately 29 million people live within 10 
kilometers of a commercial service airport located in a nonattainment 
area. 

[55] Estimates such as these do not take into account the full 
lifecycle costs of a particular technology or all of the relevant 
pollutants and their effects. 

[56] The Clean Water Act generally prohibits the discharge of 
pollutants into waters of the United States without a permit. 33 
U.S.C. § 1342(a). In most cases, states administer the NPDES program, 
which regulates the discharge of pollutants from industrial, 
municipal, and other facilities. 

[57] Such water quality measures must be designed to minimize their 
attraction to birds and wildlife that can collide with aircraft. See 
FAA Advisory Circular 150.5200-33B, Hazardous Wildlife Attractions on 
or Near Airports. 

[58] See GAO, Aviation Safety: Preliminary Information on Aircraft 
Icing and Winter Operations, [hyperlink, 
http://www.gao.gov/products/GAO-10-441T] (Washington, D.C.: Feb. 24, 
2010). 

[59] According to an Airports Council International-North America (ACI-
NA) official, LED lights may not melt ice and snow that accumulate on 
them and are, therefore, not used at some airports in colder climates. 

[60] LEED standards promote a whole-building approach to 
sustainability by recognizing performance in nine key areas of human 
and environmental health: sustainable site development, water savings, 
energy efficiency, materials selection, indoor environmental quality, 
location linkages, awareness and education, innovation in design, and 
regional priority. 

[61] Boston's Logan International Airport opened the world's first 
LEED-certified terminal in 2006. In late 2009, it also opened the 
nation's first runway repaved with "warm-mix" asphalt, which requires 
less energy to make, produces fewer GHG emissions when applied, and 
uses a higher percentage of recycled asphalt pavement. 

[62] Four large and medium hubs reported using the O'Hare 
Modernization Program's Sustainable Design Manual. In addition, nine 
surveyed airports followed the Clean Airport Partnership's Green 
Airports Initiative, including seven large and medium hubs, and two 
large and medium hubs used the Los Angeles Airports Sustainability 
Plan. Another 37 airports, including 23 large and medium hubs, 
reported using an environmental sustainability standard other than one 
listed in our survey. 

[63] A 2008 Airport Cooperative Research Program Report also noted 
that airports are moving toward a more holistic, sustainable approach 
to operations and development. See Transportation Research Board, 
Airport Cooperative Research Program Synthesis 10 Report: Airport 
Sustainability Practices (Washington, D.C.: Oct. 23, 2008). 

[64] See CEQ guidance. According to an FAA advisory, the EMS process 
to address environmental matters includes identifying and meeting 
environmental goals, determining progress, and making changes to 
ensure continual improvement. See FAA, Advisory Circular 150/5050-8, 
Environmental Management Systems for Airport Sponsors (Sept. 26, 2007). 

[65] According to FAA, most EMS frameworks are based on the ISO 14001 
EMS model. Ten airports (about 23 percent of responding airports that 
had an EMS) reported following this standard. Seven airports reported 
using EPA's standards, and two used other EMS standards. Four 
airports, including one large and medium hub, also reported that their 
EMS was third-party certified. 

[66] FAA Advisory Circular No.150/5050-8. As a condition of receiving 
AIP funding for the development of an EMS, an airport must maintain 
environmental records, conduct internal audits to ensure that the EMS 
is kept current, and annually submit to FAA management reviews of its 
EMS to demonstrate its continued currency. To date, one medium hub 
received grant funding in 2009 for a maximum $1,250,000 to develop an 
EMS, another medium hub airport has applied for $500,000 in fiscal 
year 2010 AIP funding for its EMS development. 

[67] Specifically, responding airports could indicate that 
implementation was not delayed, somewhat delayed, or greatly delayed. 

[68] As previously discussed, FAA and airports are required under NEPA 
to identify and consider environmental issues for, among other things, 
airport construction projects that receive federal funding or 
operational changes that require FAA approval. DOT has explained that 
the NEPA environmental review process cannot be cleanly segregated 
from a project's overall planning process. DOT, Report to the U.S. 
Congress on Environmental Review of Airport Improvement Projects (May 
2001). As noted new runway construction from initial planning to 
completion takes a median of 10 years, but delays from lawsuits or 
addressing environmental issues can add an additional 4 years to the 
median time. 

[69] Transportation Research Board of the National Research Council, 
Airport Cooperative Research Program Report 15, Aircraft Noise: A 
Toolkit for Managing Community Expectations (Washington, D.C.: 2009). 

[70] Airports were also asked to predict the extent to which 
addressing environmental issues other than those specified in our 
survey had caused or would cause a delay. 

[71] We have previously reported that according to a California air 
quality official, many of the same communities that have interacted 
with airports over aviation noise have more recently recognized that 
they could also be affected by emissions from airport sources. See 
[hyperlink, http://www.gao.gov/products/GAO-08-706T]. 

[72] Effluent Limitation Guidelines and New Source Performance 
Standards for the Airport Deicing Category, 74 Fed. Reg. 44676 
(proposed August 2009). 

[73] 74 Fed. Reg. 56260 (October 2009). 

[74] GAO, Highways and Environment: Transportation Agencies Are Acting 
to Involve Others in Planning and Environmental Decisions, [hyperlink, 
http://www.gao.gov/products/GAO-08-512R] (Washington, D.C.: Apr. 25, 
2008); GAO, Surface Transportation: Many Factors Affect Investment 
Decisions, [hyperlink, http://www.gao.gov/products/GAO-04-744] 
(Washington, D.C.: June 30, 2004); GAO, Highway Infrastructure: 
Stakeholders' Views on Time to Conduct Environmental Reviews of 
Highway Projects, [hyperlink, http://www.gao.gov/products/GAO-03-534] 
(Washington, D.C.: May 23, 2003); and GAO, Highway Infrastructure: 
Perceptions of Stakeholders on approaches to Reduce Highway Project 
Completion Time, [hyperlink, http://www.gao.gov/products/GAO-03-398] 
(Washington, D.C.: Apr. 9, 2003). 

[75] GAO, Highways and Environment: Transportation Agencies Are Acting 
to Involve Others in Planning and Environmental Decisions, [hyperlink, 
http://www.gao.gov/products/GAO-08-512R] (Washington, D.C.: Apr. 25, 
2008). Because the requirements were relatively new at the time of our 
report, stakeholders identified potential, rather than actual, 
benefits. 

[76] FAA recommends airports consider environmental factors early in 
airport planning, but notes that if an EIS is prepared long after an 
airport master plan, the planning data and environmental inventories 
prepared as part of the master planning may be outdated. FAA, Best 
Practices for Environmental Impact Statement (EIS) Management 
(Washington, D.C.: January 2002). 

[77] Transportation Research Board of the National Research Council, 
Airport Cooperative Research Program Synthesis 17: Approaches to 
Integrating Airport Development and Federal Environmental Review 
Processes, (Washington, D.C.: 2009). The report findings were based on 
17 case studies, where airports used various practices to integrate 
airport development and the NEPA review processes. 

[78] Stakeholders can include contractors, tenants, metropolitan 
planning organizations (MPO), state environmental agencies, 
communities, and passengers. 

[79] Pub. L. No. 108-176, §§ 302, 304, 308, 117 Stat. 2490, 2533-2540, 
codified at 49 U.S.C. § 47171 et seq. Under the act, a "congested 
airport" is an airport that accounted for at least 1 percent of all 
delayed aircraft operations in the United States in the most recent 
year for which such data is available and an airport listed in table 1 
of the FAA Airport Capacity Benchmark Report 2001. An "airport 
capacity enhancement project" is a project for construction or 
extension of a runway, including any land acquisition, taxiway, or 
safety area associated with the runway or runway extension; and such 
other airport development projects as the Secretary of Transportation 
may designate as facilitating a reduction in air traffic congestion 
and delays. Pub. L. No. 108-176, § 304, 117 Stat. 2490, 2538, codified 
at 49 U.S.C. § 47175. Environmental streamlining can also be used for 
aviation safety and aviation security projects, but according to FAA 
officials, has yet to be used for these types of projects because the 
regular environmental review process seems to be working well. 

[80] According to these officials, other factors that may delay the 
environmental review process include the extent of public comments 
received, local politics, and limited resources of other federal and 
state environmental agencies that FAA coordinates with during the EIS 
process. 

[81] See EPA Position Statement on Environmental Management Systems 
(EMS), Dec. 13, 2005 and FAA Order 5050.4B on the value of EMS. The 
International Civil Aviation Organization's (ICAO) Committee on 
Aviation Environmental Protection (CAEP) is preparing a report on the 
use of EMS and will recommend how the committee could promote the use 
of EMS within the aviation system. That report will be based on the 
results of a questionnaire on EMS use, which was distributed to member 
states and other organizations. 

[82] See FAA, Environmental Management Systems (EMS) and NEPA Adaptive 
Management (May 2004). FAA's guidance focuses on how an EMS can 
improve the NEPA process by supporting an adaptive management approach 
for projects that face uncertain or unforeseen conditions during 
implementation. We have previously reported on the benefits of using 
an adaptive management approach. GAO, FAA Airspace Redesign: An 
Analysis of the New York/New Jersey/Philadelphia Project, [hyperlink, 
http://www.gao.gov/products/GAO-08-786] (Washington, D.C.: July 31, 
2008). 

[83] DOE and EPA, Environmental Management Systems Primer for Federal 
Facilities (1998). According to the Primer, the systematic nature of 
the EMS allows for a more inclusive and proactive view of 
environmental protection. In turn, demonstrating improved 
environmental performance and making the environmental management 
structure and procedure more visible can lead to improved relations 
with regulators, stakeholders, and the public. 

[84] See CEQ, Aligning National Environmental Policy Act Processes 
With Environmental Management Systems, A Guide for NEPA and EMS 
Practitioners (April 2007). 

[85] We have previously identified seven core principles for effective 
stakeholder participation based on our review of participation 
literature and policies from leading federal agencies in stakeholder 
participation, including the three discussed in this report which are 
applicable to airports. See Fisheries Management: Core Principles and 
a Strategic Approach Would Enhance Stakeholder Participation in 
Developing Quota-Based Programs, [hyperlink, 
http://www.gao.gov/products/GAO-06-289] (Washington, D.C.: February 
2006). ACRP's Community Toolkit also identifies strategies for 
effective community engagement programs, many of which substantively 
mirror the effective stakeholder participation practices we identified. 

[86] GAO, Aviation and the Environment: Impact of Aviation Noise on 
Communities Presents Challenges for Airport Operations and Future 
Growth of the National Airspace System, [hyperlink, 
http://www.gao.gov/products/GAO-08-216T] (Washington, D.C.: October 
2007). 

[87] Ibid. According to the ACRP Community Toolkit, two-way airport- 
community communications is critical for effective community outreach. 

[88] Our survey asked about community roundtable and advisory 
committee meetings that are regularly-scheduled and ongoing. These 
meetings may include, but are not limited to meetings and workshops 
that take place during the environmental review process. 

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink, http://www.gao.gov] 
and select "E-mail Updates." 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO’s Web site, 
[hyperlink, http://www.gao.gov/ordering.htm]. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional 
information. 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: fraudnet@gao.gov: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, dawnr@gao.gov: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: