Department of Transportation

Allow FAA Airports to centrally fund/select/manage Env. Doc. Preparation for AIP Development

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Background:

Currently the FAA Airport line of business (LOB), issues Airport Improvement Program (AIP) Grants to eligible airport sponsors. AIP grants are issued to fulfill all eligible project requirements from planning to construction. The FAA as the sponsoring (funding) federal agency is required to ensure that the airport sponsor fulfills FAA’s requirements for compliance with the National Environmental Policy Act (NEPA) and other relevant special purpose environmental laws applicable to federal agencies. Currently eligible airport sponsors submit grant applications for funds to prepare NEPA and NEPA supporting documentation in support of their proposed AIP development projects.

 

Suggested Improvement:

The FAA, specifically the Airports LOB, would benefit from having the NEPA processes more directly managed/controlled & funded by the FAA, rather than delegating these responsibilities to the airport sponsors. I believe this is especially true in the case of small & general aviation airports where there is no environmental staff. The benefits of the direct involvement of an environmental professional in the selection of contractors performing environmental services (Environmental Assessments (EAs), natural/cultural/archaeological resource surveys, etc.) vice someone with little or no environmental experience or background are significant.

 

Method of Implementation:

If we could directly/centrally manage a portion of Airport Improvement Program (AIP) $ for environmental services using an indefinite delivery order/indefinite quantity (IDIQ) type of contract, we would realize efficiencies & cost savings in many ways: 1) economies of scale- better pricing b/c of the volume of work; 2) a less time consuming and more efficient/centralized contract procurement process; 3) less time expended by FAA environmental specialists spent in lengthy & time consuming review/comment periods between FAA environmental specialists & preparers of environmental documents, often essentially "training" the consultants/contractors how to prepare documents to meet our requirements. By working with a pool of a relatively limited # of contractors, selected IAW all applicable federal requirements, the contractors would learn our "secret handshake." In this way it would be an iterative process improvement & the length of time to get environmental documents prepared & finalized would be streamlined & better support our AIP program. I have only been with the FAA Airports Line of Business for 3 years & have brought this idea forward. It is my understanding that AIP funds must be issued to airports in grants & that we are unable to centrally manage a portion of those funds as I have suggested to implement my suggestion.

 

Considerations/Trade-offs:

There would be some cost trade-offs for implementing this suggestion. The FAA Airports LOB, likely the Airports District Offices would definitely have to hire more environmental staff to manage our environmental program as I have suggested. With that said, I believe a cost benefit analysis would support it. Prior to joining my wonderful FAA team, I worked for the DoD & we found that centralized contracting and the use of IDIQ to be a tremendous cost & time savings.

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Idea No. 10645