Best Practices for Environmental Impact Statement (EIS) Management
July 2001 (Updated January 2002)
Combining Federal and State Environmental Processes
Some States are very active in the environmental review and permitting of airport development projects; other States are not. Some States have a NEPA-like review, mirroring but not exactly the same as the Federal process. Some have no NEPA-like reviews, but do have State requirements and/or permits covering certain types of impacts (e.g., air quality, water quality, coastal resources, State-listed endangered and threatened species). State environmental reviews can add complexity and time to the overall environmental review process. It is FAA policy and practice to combine Federal and State environmental reviews to the extent possible in an EIS, or at least to have the reviews running concurrently rather than sequentially.
- The airport proprietor is responsible for complying with State environmental requirements. At the beginning of the environmental process, the FAA EIS project manager and the airport proprietor's project manager should confer on the extent to which Federal and State environmental requirements can be addressed in one combined environmental document and how the respective analyses will be performed.
- A combined Federal/State environmental document is more complex and time-consuming than a Federal or State document alone, and environmental review schedules need to be adjusted accordingly. However, it is usually more efficient to have a combined document, and it certainly saves time to avoid sequential Federal and State processes.
- If Federal and State processes are sufficiently different in requirements and timing, it may be more effective and efficient not to combine documents, but to run the two processes on somewhat parallel tracks within concurrent time frames to the extent possible.
- If Federal and State processes are not combined, care must be exercised to use common data bases for both processes and to avoid end-to-end sequential processes that extend the overall environmental time line for the project.