Presented to: 2010 Airports Conference By: Sue McDonald With slides by Tom Klin, CH2M HILL Date: March 3, 2010 Federal Aviation Administration Cumulative

Presented to: 2010 Airports Conference

By: Sue McDonald

With slides by Tom Klin, CH2M HILL

Date: March 3, 2010

Federal AviationAdministrationCumulative Impacts

2Federal AviationAdministration

Cumulative Impacts

What is a cumulative impact ?

CEQ Regulations at 40 CFR 1508.7 define cumulative as:

“ . . .the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions . . .”


Cumulative Impacts

Why look beyond your project?

To determine if your proposed action will

result in a significant impact when

coupled with other past, current or future

projects.


Cumulative Impacts

Requirements

CEQ regulations require:

• Consideration of cumulative, connected, similar and independent actions

• Focus on past, present, future actions• Federal and non-Federal actions• Focus on each affected resource individually• Address additive, countervailing and synergistic

effects• Look beyond the life of the action


Cumulative Impacts

Key concepts• Connected actions – “ . . .closely related actions that : (a) automatically

trigger other actions which may require environmental impact statements; (b) cannot or will not proceed unless other actions are taken previously or simultaneously; or (c) are interdependent parts of a larger action and depend on the larger action for their justification.” (1050.1E, paragraph 500c)

• Past actions – Often limited by availability of usable data, best mined through successful agency scoping

• Present actions – Include FAA, other Federal, and non-Federal (including non-government) actions within the geographic area and timeframe. Non-Federal actions sometimes hampered by confidentiality.

• Reasonably foreseeable actions – “. . .developed with enough specificity to provide meaningful information . . .” and that would affect the resources affected by the FAA action and occur in the same timeframe (5050.4B, paragraph 9q)


Cumulative Impacts

PHL Regional Study Area


Cumulative Impacts

Airport development actionsGeographic area established by resource category on

a project-by-project basis

Geographic Boundaries to Consider

Air Quality Metropolitan area, air-shed, global atmosphereWater Quality Stream, watershed, river basin, estuary, aquifer Fish Stream, river basin, estuary, spawning area, migration

routeWildlife Breeding grounds, migration route, wintering areas, range Plants Watershed, forest, range, ecosystemLand Use Community, metropolitan area, county, state, regionHistoric Neighborhood, community, city, state, tribal territory,

district_____________________________________________________________________(Considering Cumulative Effects under the National Environmental Policy Act – CEQ)


Cumulative Impacts

Studies Beyond Regional Area


Cumulative Impacts

Airport development actionsTime frames established by resource category on a project-byproject basis• How far back?

– In theory, duration of impacts should guide this decision– In practice, lack of data often limits this analysis, often resulting in a

qualitative analysis– Data sources include previous NEPA documents, permit applications,

and comprehensive scoping with agencies, other stakeholders and public

• What is reasonably foreseeable?– On-going construction (duh)– Subject of current (or recent) NEPA process or other regulatory action

by a federal, state, local or Tribal agency– Federal or non-Federal action that has been designed and/or funded – Would occur within the time frame of the proposed action– Would affect at least on environmental resource that the proposed

action would affect


Cumulative Impacts

Airport development actionsWhat types of Federal and non-Federal actions need to beconsidered in cumulative analysis?

• Public infrastructure – transportation and other govt. facilities, runway strengthening to accommodate A380, DOD facilities

• Private infrastructure – commercial/office/retail/residential development, suburban expansion, private recreational facilities

• Changes in Federal operations or operations requiring Federal approval – introduction of new jet service, transit expansion (rail spur to airport), military operations

• Other agency actions- forest management, etc.


Cumulative Impacts

Consultation

Scoping can be the most valuable source of information about past, current and reasonably foreseeable actions.

Consult with: – Federal, state and local cooperating and other agencies– Tribal resources– MPO– Academic and institutional sources– NGOs– Individuals


Cumulative Impacts

Determining effects• FAA Orders and guidance does not establish significance

thresholds for cumulative impacts • Thresholds for cumulative significance are based on

thresholds for individual environmental resource category significance thresholds, but refined to reflect project-specific context

• Some principles & approaches for determining cumulative significance thresholds:– Document baseline- what would happen to the resource without the

action?

– Will the action degrade the ability of the resource to sustain itself?

– Develop a ‘big picture’ perspective to identify cause/effect relationships between the proposed action, other past/current/reasonably foreseeable actions and resources (matrix)


Cumulative Impacts

Determining effects• Baseline set in geographic and temporal context for

resources commonly affected by the proposed action (and/or its alternatives) and other past, current and reasonably foreseeable projects

• Quantitative or qualitative analysis? Depends on availability and accuracy of data

• Cumulative effect on sustainability or resources, ecosystems, or human communities

• Mitigation for cumulative effects – Focus on measures to reduce cumulative impacts to affected resources

• Consult with resource agencies and others early and often


Cumulative Impacts

Affects of Airspace Redesign on CEP


Cumulative Impacts

CEQ, EPA and FAA Guidance

• CEQ – Considering Cumulative Effects under the National Environmental Policy Act (January 1997), 40 CFR 1508.7

• EPA – Consideration of Cumulative Impacts in EPA Review of NEPA Documents (May 1999), EPA 315-R-99-002

• FAA – 1050.1E & 5050.4B, Desktop Reference