Airport Master Plans vs. Airport Layout Plans

From time to time the subject of airport master plans (AMP) crops up.  It is important that people understand that AMPs are local planning tools and are not required by the FAA. (The 'master plan' can go by any name, e.g., airport development plan, but it essentially contains a forecast of future operations and documentation of facilities needed to meet the projected need.)

By contrast, airport layout plans (ALP) are required by the FAA and are specifically required before the FAA will grant the airport money from Airport Improvement Program (AIP) funds.  (Airports are almost entirely dependent on AIP money and passenger facility charges (PFCs) to pay for capital improvements.  AIP money can be used to pay for as much as 90 percent of a project.)

Airport master plans are long-term plans, usually 12-15 years.  Airport layout plans are shorter-term plans; the FAA prefers that ALPs be updated at the very least every five years (and in practice, I understand, ALPs are updated on average every three years).

Why is this important?

Environmental impact reports are routinely prepared for airport master plans, and are often challenged in court.  BUT the AMP and ALP are different documents.   Unless revision of the ALP is included as part of the revision of the AMP, the public fury over environmental analysis of the AMP (the protracted public controversy and eventual legal challenge) may be wasted energy.  An airport can choose to build projects that are not included in the AMP, as long as the proposed projects are included in the airport layout plan.  One consequence of this is that an airport could proceed with construction of a project even while it is under a court order not to implement its AMP (the airport would probably risk citation for contempt of court, but in my view the airport would win in the end).  I know of one airport in California that is presently moving ahead with construction of several new projects despite the fact that its AMP and environmental impact report have yet to be adopted or certified by the city-owner.

The FAA requires analysis of the environmental impacts of each project for which AIP funds are sought.  That step appears to be slipping past airport watchdogs, no doubt because the analysis results in a "finding of no significant impacts" or the project to be built is "categorically excluded" from the requirement of environmental analysis.  (Categorical exclusions are available to all federal agencies; they are projects that, in the agency's view (got that?), can never result in significant environmental impacts.)   In either case a full environmental impact report is not required and thus the public at large has no opportunity to criticize the proposed project.

Airport watchdogs should ask to inspect an airport's layout plan.  They should also ask airport management for a list of applications for AIP funds from, say, the past five years.  Having identified such applications, one can then request the environmental documentation that accompanied a particular AIP application.  It is important to request this information and documentation from the airport, not the FAA.  The airport is responsible for preparing the application, and thus the application is a public document subject to state law governing availability of records.  If you ask the FAA for the records, you will wait for an eternity and probably end up having to go through the formality of the FAA's FOIA (Freedom of Information Act) procedures, which are frustrating and daunting (you have to request a record from a central office that handles such requests -- it's very much like passing through the eye of a needle).

The FAA document governing the process of applying for AIP grants is the "AIP Handbook," FAA Order 5100.38A (amended Dec. 20, 1999).  The handbook is available on the web at http://www.faa.gov/arp/500home.htm.  See paragraph 302 regarding requirements for environmental analysis.

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