Understanding NEPA and Environmental Planning

NEPA requires federal agencies to consider the environmental effects of proposed actions and their reasonable alternatives prior to authorization or approval of a proposed action. The regulations and procedures used to conduct environmental reviews pursuant to NEPA vary by agency. The FAA has issued two orders to provide guidance to airport operators when implementing NEPA:

• FAA Order 5050.4B, NEPA Implementing Instructions for Airport Actions (April 2006); and
• FAA Order 1050.1F, Environmental Impacts: Policies and Procedures (July 2015). Order 1050.1F includes an Environmental Desk Reference, which was also updated in July 2015, and includes important background regarding the evaluation of individual environmental resources and summaries of applicable regulations.

FAA revises and reissues these orders periodically in response to changes in regulations and available technology.

Extent of Environmental Analysis

If a proposed airport improvement or development requires a federal action by the FAA or another federal agency, it must adhere to NEPA. At airports, a federal action that requires NEPA approval includes projects that include federal funds or a decision by FAA to include a proposed project on the Airport Layout Plan. Both FAA Orders identify the broad categories of environmental resources that must be considered when performing an environmental analysis pursuant to NEPA, but FAA acknowledges that the resources may vary according to the type of project proposed and its location. The environmental resources that must be considered during an environmental evaluation pursuant to NEPA include:

Since not every airport is the same or has the same environmental resources, the resources addressed in an environmental analysis can vary. If a resource is not present, it is not addressed in the analysis. For example, your airport might not be located in an area near coastal resources, but it might include important geological resources.

The FAA acknowledges that not all actions are likely to cause the same types or extent of environmental impacts, and it has identified three types or levels of analysis.

• CATEX – A CATEX applies to categories of actions that the FAA has determined, based on previous experience, do not have significant individual or cumulative impact on the quality of the human environment except in extraordinary circumstances. A CATEX is not an exemption or waiver of NEPA review; it is a level of NEPA review and documentation that must be prepared for the project file to identify why no additional environmental review is necessary. Chapter 5, Categorical Exclusions, of FAA Order 1050.1F Environmental Impacts: Policies and Procedures paragraph 5-6, provides a list of topics that normally do not individually or cumulatively have a significant effect on the human environment and that may be categorically excluded in the absence of extraordinary circumstances.
• EA – An EA is prepared by an airport sponsor to determine whether a proposed action will cause a significant effect on the human environment. A significant effect would exceed regulatory thresholds/limits. An EA describes a proposed project and its alternatives, summarizes the environmental analysis and conclusions, and is circulated to the public. The public may comment on an EA. Based on the EA analysis, FAA will either approve the proposed action by issuing a FONSI or require further analysis. If further analysis is required, the FAA will work with the airport operator to prepare an EIS. Chapter 6 of FAA Order 1050.1F Environmental Impacts: Policies and Procedures titled Environmental Assessments and Findings of No Significant Impact provides guidance on EA preparation.
• EIS – Under NEPA, the FAA must prepare an EIS for proposed actions that can cause a significant effect on the human environment by exceeding regulatory thresholds/limits and for which mitigation is not available to reduce those impacts below regulatory thresholds. An EIS describes a proposed project and its alternatives, summarizes the environmental analysis and conclusions, and is circulated to the public. The public may comment on an EIS. If FAA approves the proposed action upon completion of the EIS, it will issue a ROD. Chapter 7 of FAA Order 1050.1F, titled Environmental Impact Statements and Records of Decision, provides guidance for working with FAA to prepare an EIS.