2018 ACA Presentation Lake Tahoe, CA AIP Program Update September 2018 Presented By: Laurie Suttmeier Assistant Manager, SFO-ADO Al Richardson Assistant Manager, LAX ADO Gail Campos Environmental Protection Specialist, LAX-ADO

Presentation Overview FY18 Challenges Grant Performance Requirements FY19 AIP Program Target Areas Proposed Project Schedule Strategies for an Earlier Grant Keys To A Successful Project

FY18 Challenges Closeouts: Inactive grants: Ongoing battle Need to close-out ALL 2014 and older Grants Need to maintain activity on open grants Inactive grants: Ongoing battle Office Audit: All required Quarterly and Annual SF270/271’s and 425 needed to be submitted. Bid and Award Grants Earlier in FY

Grant Performance 5-45 Airport Improvement Program Handbook. 49 USC § 47106(a)(4) requires that a project be completed without unreasonable delay. Frequency of Sponsor’s Payment Requests. Under 49 CFR § 18.41(d)(3) (2 CFR § 200.327, Financial Reporting), sponsors must submit payment requests at least every twelve months starting from the date of the grant acceptance. The White House Office of Management & Budget (OMB) established outlay rates or “liquidation goals” for the Airport Improvement program (AIP) funds.

Grant Performance Grant Performance Indicators: Status of Existing Open grants ALL grants that are 4 years old or older should be in the process of being closed Close-out all grants that have 10% or less of funds remaining Submit regular, periodic reimbursement requests Submit close-out reports promptly Sponsor Risk Rating: Direct bearing on project and grant payment oversight

Grant Performance Impact on You, the Sponsor(s) Operate in compliance with Federal regulations and Policy Reduces the amount of annual financial reporting Reduces the amount of paperwork and oversight required as a result of the Sponsor Risk Assessment Policy Minimizes and/or eliminates the need for the FAA to monitor and report on your particular grant(s).

FY2019 AIP Program Target Areas All 2015 Grants Must Be Closed. Inactive Grants Requirements: Grant reimbursement requests are being monitored for requests that exceed 6 mos or more. Attach Documentation for Reimbursement Requests Document Reviews (SOW, P&S, Design, LCCA, Building design, Project Justification) there are new internal requirements for monitoring of grant activity The ADO has to provide justification quarterly as to why the grants remain inactive. The Risk Management portfolio for your airport includes a review of the timeliness of your reimbursement requests.

Inactive Grants 14 ($5M Unspent) 27 ($23M Unspent) Arizona 2 State > 9 Months > 12 Months Arizona 2 California 19 15 Nevada Hawaii 1 Pacific Islands 6 Total: 14 ($5M Unspent) 27 ($23M Unspent)

4-Year & Older grants 37 $26M Arizona 5 $0.3M California 22 $17.6M State # of Grants Balance Arizona 5 $0.3M California 22 $17.6M Nevada 1 $4.1M Hawaii 3 $0.1M Pacific Islands 6 $3.9M Total: 37 $26M

Target Balance Vs. Actual Regional Balance (Target for FY19) Grant Year FY17 FY16 FY15 FY14 Average FY14 - FY17 Target (40%) (19%) (9%) (4%) Arizona 26% 21% 5% 2% Ahead by $8M California 50% 19% 7% 1% Behind by $20M Nevada 30% 17% 11% Ahead by $7M Hawaii 60% 55% 28% Pacific Islands 74% 51% Behind by $22M AWP 47% 24% 10% Behind by $47M Within 5% of Goal Beyond 5% of Goal Meet Goal

FY2019 AIP Program Target Areas Program Efficiency Manage Project Schedules FAA PM should agree with project Schedule Schedule timeframes should be adjusted if/when milestones are missed. Earlier Review and Report-out on Project and/or Document Submittals there are new internal requirements for monitoring of grant activity The ADO has to provide justification quarterly as to why the grants remain inactive. The Risk Management portfolio for your airport includes a review of the timeliness of your reimbursement requests.

Target Schedule For Grant Award Sep 30th: Confer with ADO on next FY project(s) Fall: Design project, submit Env & project justification Dec 31: Draft Application due to FAA Jan: Submit engineers design report & CSPP Jan 31st: Submit Safety Phasing Plans into airspace Feb 28th: Submit CIP for FY20, FY21 & FY22 Mar 31st: Submit P&S (or 60 days before bidding) April: Bid Project May 1st : Transfer or carry-over NPE’s/Be ready for Grant

Project Schedule Existing Schedule Year 1 Year 2 Sched JAN FEB MAR APR   JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC Existing Schedule Year 1 Submit CIP for next FY CIP Mtgs  Sub-mit NEPA Docs Draft App Due Env. Det. Due SOW & Air-space CSPP Submit P&S Deadline Declare C.O. Bid Project Open Bids Submit Apps Transfer/ C.O. Receive Grant Year 2 Engs Design Report

Keys To A Successful Project Utilize Word Tracking functions in revising your documents – saves time on FAA reviews of resubmittals For more complex projects, consider implementing periodic telecons with FAA Develop a project schedule early; maintain/update as often as necessary Please! Spend the time to proof-read your documents

Environmental Considerations

Presentation Overview The Importance of Proper Planning Purpose and Need and the Proposed Action Common Trouble Spots

Appropriate Planning is Critical for the Environmental Process Master Plan ALP Feasibility Studies Noise Studies Environmental Determination CatEx EA EIS Project Implementation Construction

Can’t I just get the EA over first? Planning and environmental tasks are related and similar (See Chapter 5 in in FAA Order 5050.4B. It is important for planners and environmental specialists to begin collaboration earlier than has been the case in the past. An action on the categorically excluded list is not automatically a categorical exclusion, the FAA has to review whether any potential extraordinary circumstances exist. A project with impacts may not require and EA or EIS because they do not individually or cumulatively have a significant effect on the environment.

Why Consider Environmental Factors During Planning? Helps airport sponsors make informed decisions. To avoid a previously unforeseen problem. Environmental issues may cause you to adjust your proposed project. Ensures efficient, timely, and effective NEPA review. Determining what level of environmental documentation is required Considerations of Extraordinary Circumstances It assists you to put a shovel in the ground faster.

Project Development & NEPA Process Pre-NEPA activities: Planning studies (e.g. master plan, feasibility), $, Fed action? To determine the level of NEPA review, FAA needs sufficient project information/data Engineering Design and NEPA Sufficient design to support NEPA activities (Preliminary engineering ~ 25% design limitation) Final design activities, property acquisition… project construction shall not proceed until CATEX, FONSI, or ROD have been issued (40 CFR 1506.1).

Proper planning includes FAA review/approval of: Aviation Activity Forecast and Critical Aircraft Obstruction Mitigation Plans Site selection studies Review the adequacy of the planning alternative analysis ALP set and associated airspace case study Planning study and associated capital improvement program Proper planning includes FAA review/approval of: Aviation Activity Forecast and Critical Aircraft. Obstruction Mitigation Plans. Site selection studies. Review the adequacy of the planning alternative analysis. Airport Layout Plan (ALP) Drawing Set and associated airspace case study. Planning study and associated capital improvement program. Airport Master Plan Study should identify and justify the airport facility’s True Needs for the planning horizon.

Planning and NEPA Purpose and Need “Purpose & Need” = what is the problem and how do we fix it Airport planning study provides the justification and basis of a proposed action Consideration of environmental factors as a task Airport planning process Related baseline environmental consideration How does planning set the groundwork for NEPA? One of the first things that NEPA looks at is a clear Purpose and Need, which is a NEPA term that refers to a section of an environmental document the describes the purpose of, and need for, the proposed action. An airport planning study provides the justification and basis for a project’s Purpose & Need in subsequent environmental evaluation and NEPA analysis of Alternatives. Consideration of environmental factors as a Task within the airport planning study is appropriate for the planning large complex projects, as well as smaller scope planning projects. The Airport Sponsor should always complete the airport planning process and any related baseline environmental consideration prior to commencing preparation of an EA or EIS.

Define the Proposed Action / Project Description Clearly describe the details of the proposed project: what are you building, repairing, etc.; what are connected actions; what equipment is needed; where is the staging area; what is the timeline Maps/drawings/photos to show the project footprint and surroundings are important This allows us to determine the extent of potential impacts

Planning Environmental Baseline Preliminary identification of potential, or known, environmental features Air quality impacts Noise impacts Wetlands Flood Zones Historic or Cultural features DOT Section 4(f) features Biological Resources Water resources Compatible land use Surface traffic issues Not part of NEPA Planning Environmental Baseline - As a Task, the Airport Master Planning study can include a preliminary identification of potential, or known, environmental features. This Environmental Baseline can include preliminary identification of potential or known environmental features can include: Major airport drainage ditches Wetlands Flood Zones Historic or Cultural features DOT Section 4(f) features Flora/Fauna This Environmental Baseline is not intended to be part of the NEPA process. It is to ensure that supportable and consistent planning data is provided. It can be used to avoid any sensitive or protected resources during your planning efforts.

Common Trouble Spots Using a CEQA document for NEPA Purpose and Need Project Description Alternatives Federal Resources Compliance with Special Purpose Laws While most issues may be addressed in a similar manner under both NEPA and CEQA documentation, there are differences that must be noted:  A primary difference is the way significance is determined and discussed in environmental documents Under NEPA, significance is used to determine whether an EIS, or some lower level of documentation, will be required Don’t use a CEQA document and label it “NEPA” FAA recommends separate documents NEPA - “less than significance” is not used. Alternative impacts are compared to the “no action” alternative to determine impacts. NEPA requires an EIS when the proposed project “as a whole” has the potential to “significantly affect the quality of the human environment”   Some impacts determined to be significant under CEQA guidelines may not be of sufficient magnitude to be determined significant under NEPA

Common Trouble Spots Cumulative Effects Responses to Public Comments Response to Resource Agency Concerns Accounting for New Information Insufficient Administrative Record Relying on FAA to edit the document

Who can help me with this? Airport Staff members An airport consultant with experience in both planning and federal environmental documentation The FAA Airports District or Regional Office Environmental Protection Specialists

Thank You! Gail Campos Al Richardson Laurie J. Suttmeier Environmental Protection Specialist, LAX-ADO, El Segundo, CA (424) 405-7269 | gail.compos@faa.gov Al Richardson Assistant Manager LAX-ADO, El Segundo, CA (424) 405-7267 | Al.Richardson@faa.gov Laurie J. Suttmeier Assistant Manager SFO-ADO, Brisbane CA (650) 827-7602 | laurie.suttmeier@faa.gov