Best Practices for Environmental Impact Statement (EIS) Management
July 2001 (Updated January 2002)
EIS Teams and Teamwork
The FAA will establish an EIS team for each new EIS for a major runway project at a large hub primary airport. EIS teams may be established for other proposed projects at the discretion of FAA and airport proprietor. Adding more FAA members, airport members, and consultants to teams will strengthen EIS teams. Good teamwork by FAA, airport proprietors, and consultants is extremely important for any EIS, regardless of whether a formal EIS team is established. A strongly committed and skilled FAA, airport proprietor, and consultant team backed up with their respective management's support and adequate resources, will streamline the EIS process and avoid unnecessary delays.
- The FAA can prepare a more timely, high quality EIS by assigning more expert staff resources to it and using an EIS team approach. EIS teams are the most effective and productive when they are led by a skilled and knowledgeable FAA project manager, adequately staffed with field and headquarters Airports Program environmental specialists and environmental attorneys (supported as needed by an airport planner and other FAA specialists, such as an air traffic specialist), and provided with adequate resources (including travel funding and administrative support) and with strong FAA management support. FAA management must strive to provide personnel, travel, and administrative resources sufficient to support an EIS team.
- It is as important for airport proprietors to field an experienced EIS team as it is for FAA, regardless of whether a formal EIS team is established or the more traditional EIS approach is used. The FAA may not delegate core Federal environmental responsibilities to other parties. However, airport proprietors provide most of the backbone airport planning information for the EIS, provide data on existing conditions on the airport and in the airport vicinity, interact with the local community on the proposed project and ongoing EIS, fund the EIS consultant's work, and are responsible for compliance with other Federal environmental requirements beyond the purview of FAA (e.g., Corps of Engineers 404 permits) and with applicable State and local environmental requirements and permits.
- The airport proprietor's assignment of an environmentally-skilled project manager to work cooperatively with the FAA EIS project manager produces benefits in terms of adding skilled staff resources to the EIS; anticipating the need for and timing of specific airport input and providing it expeditiously; handling other Federal, State, and local environmental requirements and coordination simultaneously with FAA's EIS (see more under Interagency Coordination); and providing a good communication channel between FAA and airport director on the EIS work including progress, problems, and additional resource needs (including the need to fund additional consultant work). When a formal EIS team is formed, the airport project manager is a member.
- When projects have a high level of complexity or probable litigation, or both, the airport proprietor's assignment to the EIS of in-house or independent counsel with NEPA expertise is useful. The airport's counsel can productively confer with FAA counsel on legal issues during the EIS, including the approach to specific environmental laws and requirements as they relate to the specific project, and on any subsequent litigation.
- The EIS consultant does the bulk of the technical work and extensive coordination. The project manager for the consulting firm must closely interact with the FAA EIS project manager, as well as with the airport proprietor's project manager, and will be a member of any formal EIS team.