a

GAO

United States General Accounting Office

Report to the Subcommittee on Aviation, 

House Committee on Transportation and 

Infrastructure

January 2003 AVIATION 

INFRASTRUCTURE

Challenges Related to 

Building Runways and 

Actions to Address 

Them

GAO-03-164
The amount of time airports spend planning and building their runways can 

vary because of numerous factors. In light of this variation, for the 32 

runway projects we analyzed, we used median rather than average time. The 

median time was about 10 years for runways that had been completed and 

was estimated to be about 14 years for those not completed. Most airports 

and stakeholders we visited and surveyed said they faced a variety of 

challenges that had delayed their runway projects. While the level of 

challenges that airports faced varied in part depending on the proximity of 

the airport to a major city and the amount of community opposition to the 

runway, some common themes emerged, including challenges related to the 

following: 

• Reaching stakeholder agreement on purpose and need for the runway; 

• Completing the environmental review process; 

• Reaching agreement on noise mitigation and other issues; and 

• Designing and constructing the runway. 

Although there may be no single solution to the challenges involved in 

developing runways, the federal government and airport authorities have 

undertaken a number of initiatives in this area. Recently, the President 

issued an Executive Order that is directed at streamlining the environmental 

review of transportation infrastructure projects, including runways. In 

addition, two federal legislative initiatives designed to streamline the runway 

process were considered in the 107th Congress. In addition, FAA has 

undertaken a number of initiatives directed at streamlining parts of the 

process. Airports have also undertaken initiatives in this area, including 

involving stakeholders such as community groups early in the process, and 

reaching early agreement on how best to mitigate noise and other runway 

impacts. These initiatives may be a step in the right direction, but it is too 

early to assess their impact on the runway process. 

Amount of Time Airports Spent or Estimated Spending to Complete Runways Varied 

AVIATION INFRASTRUCTURE 

Challenges Related to Building Runways 

and Actions to Address Them 

www.gao.gov/cgi-bin/getrpt?GAO-03-164 

To view the full report, including the scope 

and methodology, click on the link above. 

For more information, contact Gerald 

Dillingham, Ph.D., at (202) 512-3650 or via 

E-mail at dillinghamg@gao.gov. 

Highlights of GAO-03-164, a report to the 

Aviation Subcommittee, House Committee 

on Transportation and Infrastructure 

January 2003 

Aviation experts believe that 

building runways is one key way to 

address airport capacity issues and 

prevent delays that can affect the 

entire U.S. economy, but runway 

projects are often controversial and 

time-consuming. GAO was asked to 

examine how much time airports 

spend completing runways, what 

challenges airports and other 

stakeholders experience during 

this process, and what airports and 

other stakeholders have done to 

address challenges related to 

runway projects. 

GAO analyzed the results of 

surveys from 30 airports on 32 

runway projects and visited 5 

airports in order to interview 

numerous runway project 

stakeholders. 

The Department of Transportation 

agreed with GAO’s characterization 

of the challenges associated with 

building runways and some of the 

initiatives taken to address these 

challenges. They did express some 

concerns related to GAO’s analysis 

of the time airports spent or 

estimated spending in developing 

runways, and suggested that GAO 

acknowledge additional FAA 

efforts to improve the runway 

process. We believe that our 

approach was a reasonable 

assessment of the amount of time 

taken to build runways; however, 

we clarified our discussion about 

the length of time. We also added 

information regarding initiatives 

undertaken by FAA. 
Page i GAO-03-164 Aviation Infrastructure

Contents

Letter 1

Results in Brief 2

Background 4

Some Airports Have Spent Many Years Building Runways and Have 

Faced a Variety of Challenges 10

A Number of Initiatives Are Underway to Address Challenges 

Related to Building Runways 16

Agency Comments 22

Appendixes

Appendix I: Scope and Methodology 24

Appendix II: Airport Site Visits 26

General Edward Lawrence Logan International Airport – East 

Boston, MA 27

Current Status of the Runway Project 30

Stakeholders Cite Community Opposition as a Major Challenge and 

Say Efforts to Address This Issue Were Unsuccessful 30

Stakeholders Say Meeting Extensive Environmental Requirements 

Has Been Challenging Because of Community Opposition 31

Litigation Added Time to Process 34

Appendix III: Dallas-Fort Worth International Airport – DFW, TX 36

Current Status of the Two Runway Projects 38

Airport Officials Described Extensive Environmental Review 

Process as Challenging 38

The Dallas-Fort Worth International Airport Used Some Unique 

Approaches to Mitigate Runway Impacts 38

Stakeholder Experiences, from Start to Finish, Were Many and 

Varied 39

Litigation Delayed Process 40

Appendix IV: Memphis International Airport 43

Status of the Runway project 45

Airport Officials Stated That They Faced Challenges Reaching 

Consensus among Stakeholders on Project Funding Issues and 

Decisionmaking 45

Extensive Requirements Raised Challenges Regarding Wetlands 

Mitigation and Land Acquisition during Construction of 

Runway 46

Site-Specific Challenges Involved Relocating Other

Infrastructure 47
Contents

Page ii GAO-03-164 Aviation Infrastructure

Appendix V: Minneapolis-St. Paul International Airport 49

Current Status of the Runway Project 51

Stakeholders Agree That Comprehensive Mitigation Plans Are 

Essential but Difficult to Develop 51

Stakeholders Believe That Mitigation Funding Should Be More 

Flexible to Include More Communities 52

A Nationwide Low Frequency Noise Policy Is Not in Place 52

Some Communities Question Justification of State Zoning Laws 53

Appendix VI: Seattle-Tacoma International Airport 56

Status of the Runway project 58

Simplifying Purpose and Need May Help Reduce the Circuitous 

Nature of the Review Process 58

A Compatible Land Use Program May Help to Reduce 

Opposition 59

New Mitigation Approaches and Increased Community Interaction 

Could Help Foster Community Support 60

Extensive Regulatory and Legal Requirements Posed Resource 

Challenges 62

Site-Specific Issues Involve Safety and Environmental 

Challenges 63

Appendix VII: Lester B. Pearson International Airport, Toronto, Canada 65

Status of Runway Projects 67

Airport Development Process in Canada Differs from U.S. 

Process 67

Canadian Airports Face Many of the Same Challenges as U.S. 

Airports 68

Appendix VIII: Survey of Airports 70

Appendix IX: Survey of Airports with Recent or Planned Runway 

Projects 72

Tables Table 1: Summary of Provisions in H.R. 4481 and S. 633, and the 

Challenges Each Seeks to Address 18

Table 2: Airports Selected for Site Visit and their Runway 

Projects 27

Table 3: History of the Boston Logan Runway Project 35

Table 4: History of Dallas–Fort Worth Runway Project 41

Table 5: History of Memphis Runway Project 48

Table 6: History of Minneapolis-St. Paul International Airport 

Runway Project 54

Table 7: History of Sea-Tac Runway Project 64
Contents

Page iii GAO-03-164 Aviation Infrastructure

Table 8: Airports Surveyed 71

Figures Figure 1: Runway Development Process 8

Figure 2: Amount of Time Airports Have Spent or Planned to Spend 

on Runway Projects Varied 11

Figure 3: Median Time Spent on Runway Projects Overall and on 

Each Phase 12

Figure 4: Airport Diagram—Boston’s Logan International 

Airport 29

Figure 5: Airport Diagram—Dallas-Fort Worth International 

Airport 37

Figure 6: Airport Diagram—Memphis International Airport 44

Figure 7: Airport Diagram—Sea-Tac International Airport 57

Figure 8: Airport Diagram—Lester B. Pearson International 

Airport 66
Page 1 GAO-03-164 Aviation Infrastructure

United States General Accounting Office

Washington, D.C. 20548

A

January 30, 2003 Letr

The Honorable John L. Mica

Chairman

The Honorable William O. Lipinski

Ranking Democratic Member

Subcommittee on Aviation 

Committee on Transportation and Infrastructure

House of Representatives

Although the events of September 11, 2001, diverted the aviation industry’s 

attention from airport flight capacity to security issues, aviation experts 

believe that addressing capacity issues must be brought back to the 

forefront to prevent costly flight delays and their negative effect on the U.S. 

economy. According to a recent report on the impact on civil aviation,1

 the 

flight congestion and delay problems that were experienced in 2000 had a 

significant effect on the entire U.S. economy and were felt not only in the 

commercial aviation industry but also in the tourism and related supplier 

industries. The report found that in 2000, commercial aviation delays 

resulted in over $9 billion in negative economic effects on the entire U.S. 

economy and cost commercial airlines over $3 billion. In addition, the 

report stated that if there were no new investments in airport construction 

(including new runways) or in the air traffic system beyond 2000, delays 

could potentially cost the U.S. economy $13.5 billion in 2007 and $17.2 

billion in 2012.

Building runways can involve years of planning, an extensive 

environmental review phase, and the design and construction of the actual 

runway. Airport authorities who want to build a runway must also 

coordinate with numerous stakeholders, including airlines, federal and 

state officials, and community groups. In addition, they may face legal 

challenges from opponents of the runway that can take years to resolve. 

Nonetheless, according to FAA, despite these challenges, building new 

runways is widely regarded as the most effective way to increase capacity 

1

The National Economic Impact of Civil Aviation, DRI-WEFA, Inc., July 2002.
Page 2 GAO-03-164 Aviation Infrastructure

in the national airspace system and is critical to the entire U.S. economy.2

This report provides information on the process for building runways, 

taking into consideration the needs of the system and the concerns of the 

various stakeholders. Specifically, as agreed with your offices, we address 

the following questions:

1. How much time do airports spend building their runway projects, and 

what challenges do airports and other stakeholders experience during 

this process?

2. What have airports and other stakeholders done or proposed to do to 

address the challenges they experienced in building runways?

To determine the amount of time that airports spent to complete runway 

projects, along with challenges that airports and other stakeholders faced 

during this process and initiatives to address these challenges, we surveyed 

30 airports that had built or planned to build a total of 32 runways between 

1991 and 2010. Based on survey responses, we selected 5 airports that were 

diverse in size, location, and challenges at which we conducted in-depth 

site visits in order to understand the perspectives of numerous 

stakeholders. At these locations, we interviewed airport, airline, federal 

and state, and community officials about their experiences. We also visited 

the Lester B. Pearson International Airport in Toronto, Canada, to gain a 

perspective on the Canadian runway development process. A more detailed 

explanation of the scope and methodology can be found in appendix I.

Results in Brief The amount of time that airports spend planning and building their 

runways can vary because of a number of factors. For example, although it 

is relatively straightforward to determine the beginning and ending of the 

environmental and the design and construction phases of the runway 

development process, there is no consensus among stakeholders about 

what constitutes the beginning of the planning phase of the process. 

Consequently, the length of time and the number of activities considered by 

some airports to be part of the planning phase vary. In light of these 

circumstances, we decided to use a median time rather than the average 

time because it would minimize the impact of outlying airports that may 

have taken a very long or very short time. For the airports we surveyed, the 

2

Some in the aviation industry believe that demand management and peak pricing are also 

feasible alternatives to reducing congestion and delays.
Page 3 GAO-03-164 Aviation Infrastructure

median time spent from planning to completion of their runway projects 

was about 10 years, and the median time that airports estimated they would 

spend on projects not yet completed was about 14 years. Several of the 

airports with unfinished runway projects stated that significant challenges 

had delayed their projects’ completion. Although the level of challenges 

faced by airports varied depending on such factors as proximity of the 

airport to a major city, amount of community opposition to the runway, and 

specific environmental issues, some common themes emerged. For 

example, several airports described challenges related to reaching 

stakeholder agreement on the purpose and need for the new runway. 

Another theme was the challenge of completing required environmental 

reviews; specifically, airports described challenges related to complying 

with extensive and duplicative federal and state requirements and 

obtaining the necessary permits. Some airports also described challenges 

related to reaching agreement on how to mitigate the impact of noise and 

other issues. Several airports commented that they faced challenges during 

the design and construction of their runways such as dealing with weather 

and site preparation issues. 

Although there may be no single solution that addresses all the issues 

involved in planning and building runways, the federal government and 

airport authorities have undertaken a number of initiatives in this area. 

Most recently, the President issued an Executive Order that is directed at 

streamlining the environmental review of transportation infrastructure 

projects by requiring federal agencies that conduct environmental reviews 

to develop procedures that will allow the reviews to be completed in a 

timely and responsible manner. In addition, to address challenges 

associated with the many regulatory requirements of the runway 

development process, two legislative initiatives designed to streamline the 

runway development process have been under consideration at the federal 

level. FAA has also undertaken several initiatives directed at increasing 

communication and coordination, and at streamlining the planning and 

environmental review of runway projects. FAA officials expect these 

initiatives to produce measurable improvements in the runway 

development process. Although some airports stated that the federal 

initiatives held promise for helping airports to resolve challenges more 

quickly, it is too early to assess their impact on the runway development 

process. Airports have also undertaken initiatives to address challenges 

related to building runways, including getting local stakeholders such as 

community groups involved at the very beginning of the process and 

reaching early agreement on how to mitigate the impacts of the runway. 

Airports described these initiatives as helpful to facilitating the completion 
Page 4 GAO-03-164 Aviation Infrastructure

of their runway projects, and their efforts may be useful for other airports 

involved in runway projects to consider, but the variety of situations that 

airports described and the different levels of challenges they faced make it 

difficult to generalize from one airport’s experience to another.

We provided the Department of Transportation with a draft of this report 

for their review and comment. FAA officials agreed with our 

characterization of the challenges associated with building runways and 

our identification of some of the initiatives to address these challenges. 

However, they did express some concerns related to our analysis of the 

time that airports spent developing their runways, and suggested that GAO 

include more acknowledgment of FAA’s efforts to improve the process. In 

response to FAA’s comments, we believe our approach was a reasonable 

assessment of the amount of time it takes airports to build runways; 

however, we clarified our discussion about the length of time. We also 

added information regarding several initiatives that FAA has undertaken to 

streamline the runway development process, and we made technical 

changes where appropriate. 

Background The decision to build runways has traditionally elicited strong and often 

emotional reactions among stakeholders, both negative and positive. 

Generally, these reactions are directed at the decision to build a runway—

usually in response to the perceived environmental or economic impacts 

that the proposed project will have on the surrounding communities. Often, 

opponents to a runway project base their opposition on the belief that the 

negative impact of the runway on their quality of life will outweigh the 

projected benefits of the project. At other times, opponents contend that 

alternatives such as high-speed rail, regional airports, or demand 

management are better alternatives to resolving delay issues than building 

new runways. In contrast, proponents of new runway projects generally 

contend that building new runways can increase the level of service and 

reduce delay at the airport, can result in a positive economic impact to the 

region served by the airport, and in some cases can reduce noise pollution 

by distributing flights over a larger geographical area.

Airports that plan to build runways must comply with what can become a 

complex process involving three general phases that often overlap: 

planning, environmental review, and design and construction. In addition, 

airports can be involved in legal actions that can occur in any or all of the 

three phases.
Page 5 GAO-03-164 Aviation Infrastructure

The first phase in the runway development process is planning. According 

to FAA guidance, airports should begin planning for a new runway when 

the airport has reached 60 to 75 percent of total annual flight capacity. 

During the planning phase, airport authorities and local officials begin by 

identifying the type of development needed at a specific airport and the 

proposed project’s estimated cost and benefits, in both political and 

economic terms. Some of the planning tasks include establishing the 

purpose and need for the runway (for example, assessing the capability of 

current facilities, reviewing and refining aviation demand forecasts, and 

evaluating options to accommodate forecast demands), coordinating land 

use issues with community planning boards, and preparing capacity 

enhancement plans, master plans, airspace reviews, cost benefit analyses, 

and airport layout plans.3

 Further, most airports consider numerous 

alternatives for increasing capacity or reducing delay before deciding on a 

project to pursue. During this phase, airports will begin addressing how to 

fund the proposed project.

The environmental review phase, which often overlaps with planning, is the 

second phase in the runway development process. This phase typically 

begins with a determination by FAA of the extent to which a proposed 

project will affect the quality of the environment.4

 To make this 

determination, FAA examines the proposed project and its possible 

environmental impacts on air and water quality, on noise, and on historical 

lands. FAA will make one of three determinations. If the agency determines 

that the scope of the project is such that it will not directly affect the 

environment, it will issue a categorical exclusion.5

 If FAA determines that a 

project will have a measurable effect on the environment, but that its 

impact will not exceed guidelines established in the agency’s 

Environmental Handbook, it will issue a Finding of No Significant Impact 

(FONSI). After issuance of a FONSI, runway projects can begin applying 

for necessary permits, such as those that may be required under the Clean 

3

Airports and other stakeholders develop these plans to help them identify potential ways to 

increase airfield capacity at major airports and to coordinate major infrastructure projects 

at the airports.

4

Some states have environmental review requirements in addition to federal requirements.

5

Under the National Environmental Policy Act of 1969, a categorical exclusion exempts the 

project from the requirements of the federal environmental review process. However, 

according to FAA, categorical exclusions are not an option for a new runway or major 

runway extension. A categorical exclusion does not necessarily relieve the project from 

state and local environmental review requirements.
Page 6 GAO-03-164 Aviation Infrastructure

Air Act or the Clean Water Act. Where potentially significant impacts are 

obvious, FAA will proceed directly to the preparation of an environmental 

impact statement (EIS) rather than start with the airport sponsors’ 

environmental assessment.6

If FAA determines that a proposed project will have significant 

environmental effects, it will issue a notice of intent to prepare an EIS. An 

EIS includes an analysis of the potential environmental effects of a 

proposed project and how to mitigate significant impacts. Council on 

Environmental Quality (CEQ) regulations do not require that all impacts be 

mitigated; agencies are required to disclose impacts that will not be 

mitigated, and the reason. After the draft EIS is completed, FAA provides it 

to the Environmental Protection Agency (EPA), which publishes a notice of 

its availability in the Federal Register, where it is made available for review 

and comment to federal, state, and local agencies and the public for at least 

45 days. Public hearings, if necessary, usually occur during the review and 

comment period. At the end of the public comment period, FAA responds 

to comments received on the draft and prepares the final EIS. Once FAA 

approves the final EIS, the document is printed, distributed, and once again 

filed with EPA. EPA subsequently publishes notice of the availability of the 

final EIS in the Federal Register. According to CEQ regulations, FAA can 

not issue a Record of Decision (ROD) for at least 30 days after the 

publication of the final EIS. Once the final EIS has been issued, it takes FAA 

an average of about 3 months to issue a ROD. The ROD, which is the final 

step of the environmental review process, summarizes the administrative 

record of the agency’s proposals, alternatives, analysis, findings/ 

determinations, decisions, actions, and mitigation measures that were 

made a condition of approval of the EIS. If, however, FAA finds that the 

revised draft differs significantly from the initial draft, the agency may 

issue a supplemental draft EIS and release this document for further review 

and comment. In addition, other factors that may lead to a supplemental 

EIS include a change in the proposed action, a change in the agency’s 

6

An EIS is a document required of federal agencies by the National Environmental Policy 

Act of 1969 and its implementing regulations as formulated by the Council on 

Environmental Quality for major projects or legislative proposals that significantly affect 

the environment. It describes the environmental effects of the undertaking and lists 

alternative actions. In principle, it is a basis for deciding whether to approve the project. 

FAA is responsible for preparing an EIS for a major airport project or selecting a contractor 

(that is, consultant) to assist FAA in preparing the EIS. Typically, FAA coordinates with the 

airport authority when it selects an EIS consultant. 
Page 7 GAO-03-164 Aviation Infrastructure

decision, or new reasonable alternatives not previously evaluated. A 

supplemental draft EIS can occur anywhere in the environmental process. 

In addition to the requirements above, airport sponsors may be required to 

obtain environmental permits/approvals from other state, local, and federal 

agencies before they can begin construction of the proposed project. These 

permits/approvals cover various federal and state requirements related to 

wetlands, water and air quality, coastal zone management, and endangered 

species, among others. These requirements arise from various regulations, 

including the federal Clean Water Act and Clean Air Act. For example, the 

Army Corp of Engineers requires permits when proposed projects have an 

impact on wetlands under the Clean Water Act. State and local agencies 

may also be responsible for requiring permits dealing with air and water 

quality. Similar to the National Environmental Policy Act (NEPA) process, 

the permitting process may include a public review and comment period. 

Project opponents may initiate litigation once the final EIS has been 

approved and the FAA has issued a favorable ROD. However, a lawsuit can 

be filed at any time during the planning, environmental, and design and 

construction phases. 

Following the completion of the permit process, project sponsors generally 

begin the final phase of the runway development process—the design and 

construction phase. This phase includes a myriad of tasks, such as project 

engineering, financing, contracting, land acquisition, site preparation, and 

actual project construction. This phase also includes construction tasks 

related to mitigating noise, wetland, and other environmental impacts. 

According to FAA, it is common for airport sponsors to begin runway 

design while the environmental process is underway in the interest of 

saving time by undertaking these actions concurrently. Once construction 

of the runway has been completed, FAA certifies the runway for operation 

and commissions it for service. Figure 1 illustrates the main steps involved 

in the runway development process.
Page 8 GAO-03-164 Aviation Infrastructure

Figure 1: Runway Development Process
Page 9 GAO-03-164 Aviation Infrastructure

Note: GAO analysis of FAA and other documents.
Page 10 GAO-03-164 Aviation Infrastructure

Some Airports Have 

Spent Many Years 

Building Runways and 

Have Faced a Variety of 

Challenges 

The amount of time that airports spend planning and building their 

runways can vary because of a number of factors. For example, although it 

is relatively straightforward to determine the beginning and ending of the 

environmental and the design and construction phases of the process, 

there is no consensus about what constitutes the beginning of the planning 

phase. Consequently, the length of time and the number of activities 

considered by some airports to be part of the planning phase vary. Airports 

also described a variety of challenges that they said delayed their projects. 

Many of these challenges related to reaching stakeholder agreement, 

completing the environmental review phase, mitigating the impact of noise, 

or designing and constructing the actual runway. 

Completed Runways Took a 

Median of 10 Years to Build, 

and Unfinished Runways 

May Take Even Longer

As shown in figure 2, airports we surveyed reported spending a wide range 

of time in completing runway projects. In general, airports reported 

spending less time on completed projects than they estimate they will 

spend on those projects not yet completed; for example, airports reported 

that about half of the completed runways took 10 years or less but 

estimated that almost all the projects that were not yet completed (16 out 

of 17) would take 10 years or more. According to the airports with 

uncompleted projects, a number of factors contributed to the time spent, 

such as community opposition and difficulties in dealing with 

environmental requirements. 
Page 11 GAO-03-164 Aviation Infrastructure

Figure 2: Amount of Time Airports Have Spent or Planned to Spend on Runway 

Projects Varied

Note: GAO analysis of airport survey data.

Figure 3 shows that the median time spent on completed runway projects 

was about 10 years, while the median time airports estimated they would 

spend on runway projects not yet completed was about 14 years. Similarly, 

the median time spent on the planning and environmental phases for 

airports that had completed these phases was significantly shorter than the 

median time airports estimated would be spent on those phases for 

projects that they had not yet completed. This may have been because the 

three projects in the planning phase and the five projects in the 

environmental phase were experiencing challenges that the airports 

believed would delay the completion of the respective phases. Moreover, 

the median time spent on the environmental phase of projects that had 

completed their environmental requirements under a FONSI was about 2.7 

years, while the median time spent on the environmental phase of projects 

that had completed their environmental requirements with an EIS was 

about 3.7 years. This difference is likely attributable to the greater number 

of requirements that accompany an EIS as compared with a FONSI. 
Page 12 GAO-03-164 Aviation Infrastructure

Figure 3: Median Time Spent on Runway Projects Overall and on Each Phase Varied 

Note 1: GAO analysis of airport survey data.

Note 2: Airports used different milestones to indicate the start and end dates for each phase. Given 

this difference, we used median time rather than average time.

Note 3: Although we received 32 responses regarding the amount of time taken or estimated to 

complete the overall process, the number of responses regarding the amount of time taken or 

estimated to complete each phase varied.

In May 2001, the Department of Transportation issued a report to the 

Congress on an environmental review of airport improvement projects that 

reported results similar to our analysis.7

 As a part of its analysis, FAA 

measured the average time that elapsed between the start of planning and 

the start of construction for 10 airports that received approval for a new 

runway between 1996 and 2000. FAA found that the average time from

7

Report to the U. S. Congress on Environmental Review of Airport Improvement Projects, 

U.S. Department of Transportation, May 2001.
Page 13 GAO-03-164 Aviation Infrastructure

thestart of planning until the start of construction was about 10 years.8 The 

report also stated that the average time to complete an EIS for a new 

runway was 3.25 years from the beginning of the EIS process to the 

issuance of the Record of Decision—or about one-third of the 10-year time. 

According to FAA, there can be a considerable lag from the inception of the 

runway process until the runway is completed and in operation. FAA added 

that these delays occur as part of the process that airports sometimes go 

through in seeking to achieve consensus and the political will to move 

forward while contending with local public and political opposition to 

runway development. According to FAA, numerous examples can be found 

where runway development has been delayed 5, 10, or more years while 

plans are revised, discarded, or shelved until political and/or economic 

factors can be satisfied. FAA stated that these actions make it difficult to 

determine how long it takes to build a runway. 

Several Themes Emerged 

among the Challenges That 

Airports Described

Most airports that we surveyed and visited described significant factors 

that delayed their runway projects. In many cases, the challenges they 

described were interrelated. For example, several airports said they faced 

significant community opposition, which affected their ability to reach 

stakeholder agreement and to complete the environmental review phase. 

Although many of the airports we surveyed experienced similar types of 

challenges, some airports, such as those in Boston, Atlanta, and Seattle, 

faced a heightened level of challenges because of their locations in urban 

areas with a large number of residences very close by. Some of the specific 

challenges identified by airports and other stakeholders we visited include 

the following:

Reaching stakeholder agreement. Reaching consensus on the purpose 

and need for a runway was described by several airports as being 

particularly challenging. In order to reach this consensus, airports 

generally must meet numerous times with stakeholders who may have 

differing opinions about the runway project or uses of land surrounding the 

airport. For example, airport officials in Los Angeles and Boston described 

challenges related to working with community interest groups and local 

metropolitan planning organizations that opposed the runway projects and 

advocated using means other than building a new runway to address 

8

FAA officials said that if they added 3 to 5 years for design and construction, then FAA’s 

determination of average time to complete a runway would become about the same as that 

reported by GAO for projects not yet completed. 
Page 14 GAO-03-164 Aviation Infrastructure

capacity issues, such as developing regional airports, building new airports, 

or pursuing alternative transportation modes like high-speed rail. 

Some airports described challenges related to reaching agreement with 

stakeholders other than community groups. For example, stakeholders in 

Seattle said that reaching agreement was challenging on issues such as 

where the runway should be located or the coordination of sometimes 

inconsistent land use plans among various planning groups. Officials at 

Boston’s Logan Airport said they could not reach agreement with FAA, a 

key stakeholder on all runway projects, regarding what was needed to 

satisfy the environmental review process. Specifically, Logan Airport 

officials disagreed with FAA’s decision to extend its environmental process 

by requiring a supplemental EIS because they believed that environmental 

issues had been settled during the initial analysis. They believed that FAA’s 

decision to require the supplemental draft stemmed from significant public 

and political pressure from those opposed to the project.

Completing the environmental review phase. Of the 30 airports we 

surveyed, 13 stated that one of their most significant challenges in planning 

and building their runways was complying with environmental 

requirements. Under the current process, airports must comply with over 

40 federal laws, executive orders, and regulations that often overlap with 

the environmental requirements mandated by some states. For example, 

federal law requires the governor of each state to certify that federally 

funded runways conform to local air quality standards, a requirement 

known as the Governor’s certification. In addition, the Clean Air Act 

requires FAA to determine whether emissions from each airport project 

conform to its state’s plan for implementing national air quality standards. 

According to officials from the American Association of Airport Executives 

and Airports Council International, many state air quality plans contain 

unrealistically low airport emissions budgets, and few realistically 

anticipate reasonable airport growth. They believe that coordinating 

airport development activity with the state air quality plans causes a major 

source of delay and risk to airport projects. The officials also noted that the 

Governor’s Certificate requirement duplicates requirements found in the 

Clean Air Act and Clean Water Act.

Moreover, several airports, including those in Boston, Atlanta, Houston, 

and Minneapolis-St. Paul, commented that obtaining the permits necessary 

to complete the environmental review was a challenge that delayed their 

projects, because permitting agencies often took much longer than 

expected. Boston Logan officials stated that they experienced delays 
Page 15 GAO-03-164 Aviation Infrastructure

because the permitting agencies did not agree on the order in which the 

permits should be issued. For example, the coastal zone management 

agency was unwilling to issue its permit until FAA issued the ROD; 

however, FAA was unwilling to issue the ROD until the coastal permit was 

issued. According to FAA officials, the agency was able to obtain a 

satisfactory assurance from the state permitting agency that allowed FAA 

to move forward with the issuance of the ROD. As a result, according to 

FAA officials, they were able to avoid a significant delay. 

Mitigating the impact of noise and other issues. As we reported in 

October 2000,9

 mitigating the potential impact of aircraft noise on the 

surrounding community continues to be a significant challenge for airports 

that are building new runways. One of the reasons is that community 

concerns with aircraft noise are generally already high around many 

airports, and adding new runways adds to the already heightened concern. 

Another reason, according to some stakeholders, why mitigating noise is 

particularly challenging for several of the airports is because they do not 

participate in FAA’s voluntary Part 150 Noise Compatibility Program, which 

provides funding to airports to help mitigate the impact of noise on the 

communities. Several other airports also told us that their noise problems 

are the result of incompatible land uses (existing or planned) around the 

airports. 

In addition to mitigating the impact of noise on the surrounding 

community, officials at Sea-Tac Airport said that they were equally 

challenged to mitigate the impact of the project on wetlands, particularly 

because two key stakeholders had conflicting views on how this should be 

done. According to Sea-Tac officials, the state of Washington has a strong 

preference that mitigation measures for wetland and stream impacts be 

located in the same water basin where the impacts occur. However, 

because of concerns about attracting wildlife, and the danger to aircraft of 

bird strikes, FAA strongly advises that airports avoid locating wetlands 

within 10,000 feet of runways.

Design and construction of the runway. Several airports commented 

that they also faced some challenges during the design and construction 

phase of their runways. For example, Dallas-Fort Worth officials stated that 

adverse weather conditions created construction problems for them, as the 

9

U.S. General Accounting Office, Aviation Infrastructure: Challenges Associated with 

Building and Maintaining Runways, GAO-01-90T (Washington, D.C., Oct. 5, 2000).
Page 16 GAO-03-164 Aviation Infrastructure

region’s high temperatures made it difficult to ensure that concrete poured 

for the runway would cure properly. Airport officials at Sea-Tac also 

described challenges related to the design and construction phase. For 

example, before Sea-Tac can build its runway it has to import 17 million 

cubic yards of dirt to the airport to extend a plateau for a foundation. Thus, 

the airport authority has to find suitable, nonpolluted fill dirt to use for the 

foundation. Once the dirt is located, it must be transported to the airport 

over an indirect route using trucks that the airport is required to clean 

before they leave the airport. Finally, the airport authority is to use 

extensive mitigation measures to ensure that moving the dirt will not 

adversely affect the surrounding communities and wetlands.

Appendixes II through VI provide a detailed description of how various 

challenges have affected runway projects at the Boston, Dallas, Memphis, 

Minneapolis-St. Paul, and Seattle airports, according to airport authorities 

and other stakeholders.

A Number of Initiatives 

Are Underway to 

Address Challenges 

Related to Building 

Runways

While there may be no single solution to all the challenges associated with 

planning and building runways, the federal government and airports have 

undertaken a number of initiatives to address the challenges related to 

such issues as duplicative environmental requirements, stakeholder 

differences, and noise mitigation. Primarily, these initiatives focused on 

streamlining the environmental review process and improving cooperation, 

communication, and coordination among major stakeholders.

Federal Initiatives Focus on 

Streamlining the 

Environmental Review 

Process to Reduce 

Duplication

One initiative designed to address a significant issue identified by airports 

and other stakeholders—the extensive and often duplicative environmental 

review requirements—is Executive Order 13274, entitled Environmental 

Stewardship and Transportation Infrastructure Project Reviews, which was 

signed by the President on September 18, 2002.10 The order directs agencies 

that conduct required environmental reviews with respect to 

transportation infrastructure projects, including runways, to formulate and 

implement administrative, policy, and procedural mechanisms that enable 

the agencies to ensure completion of such reviews in a timely and 

10The order does not supersede the requirements of the National Environmental Policy Act 

or other environmental laws. 
Page 17 GAO-03-164 Aviation Infrastructure

environmentally responsible manner. The order also states that the 

Secretary of Transportation shall

• designate a list of high-priority transportation infrastructure projects to 

receive expedited agency reviews;11

• chair an inter-agency task force to monitor and expedite environmental 

reviews of high-priority transportation infrastructure projects, and 

identify and promote policies that can effectively streamline the 

environmental review process; and 

• prepare an annual report to the President describing the results of the 

expedited reviews, and provide recommendations. 

Executive departments and agencies shall take appropriate actions, to the 

extent consistent with applicable law and available resources, to promote 

environmental stewardship in the nation’s transportation system and to 

expedite environmental reviews of high-priority transportation 

infrastructure projects. The Secretary has stated that the Department of 

Transportation will work with federal and state agencies to reduce 

duplicative and overlapping requirements and promote effective strategies 

for enhancing the timeliness of the decisionmaking process.

Proposed legislation was introduced in the 107th Congress to address 

several of the concerns raised by a number of airports and other 

stakeholders we surveyed and visited—H. R. 4481, the Airport Streamlining 

Approval Process Act of 2002, and S. 633, the Aviation Delay Prevention 

Act. H.R. 4481, the House bill, focused on capacity-enhancement projects 

and was generally directed at streamlining the runway development 

process, while the Senate bill was directed at reducing aviation delays. 

Table 1 summarizes some of the key provisions in H.R. 4481 and S. 633 that 

sought to address the challenges the airports identified.

11On October 31, 2002, the Secretary of Transportation selected seven high-priority 

transportation projects. One airport project was selected—a runway construction project at 

the Philadelphia International Airport. The Secretary is currently considering additional 

transportation projects, including airport projects, to add to the initial list. 
Page 18 GAO-03-164 Aviation Infrastructure

Table 1: Summary of Provisions in H.R. 4481 and S. 633, and the Challenges Each Seeks to Address

Source: U.S. General Accounting Office.

In responding to our survey, seven airports stated that eliminating the 

governor’s certificate requirement would reduce duplicative environmental 

requirements. In an August 2000 report to the Congress on aviation and the 

environment, we suggested that Congress may wish to consider eliminating 

the state air quality certification requirements in airport legislation 

becauseit is duplicative of protections offered under the Clean Air Act.12

FAA officials stated that they agreed with our suggestion and believed that 

a parallel situation exists with respect to state water quality certification, 

H.R. 4481, Airport Streamlining Approval 

Process Act of 2002 S. 633, Aviation Delay Prevention Act Challenge addressed

Directs FAA to take action to encourage the 

construction of airport capacity-enhancement 

projects at congested airports.

Requires DOT to designate certain airport projects 

as national capacity projects. The airports where 

these national capacity projects are designated 

would be required to complete the planning and 

environmental review process within 5 years, or else 

lose access to certain federal funds.

Reaching stakeholder 

agreement.

Authorizes DOT to develop interagency cooperative 

agreements with other federal and state 

stakeholders in the environmental review process.

Requires DOT to implement an expedited 

coordinated environmental review process for 

national capacity projects that provides for better 

coordination among federal, regional, state, and 

local agencies.

Completing the 

environmental review 

phase. 

Allows airports to reimburse FAA for the additional 

staff necessary to review and approve project 

construction requests.

Authorizes DOT to develop a 5-year pilot program 

funded by airport sponsors to hire additional FAA 

environmental specialists and attorneys.

Completing the 

environmental review 

phase. 

Makes DOT the lead agency for all capacityenhancement project environmental reviews, with 

responsibility for setting time frames for all relevant 

agency reviews. All federal agency reviews would be 

required to occur concurrently.

Requires DOT to implement an expedited 

environmental review process that provides a “date 

certain” process deadline for environmental reviews.

Completing the 

environmental review 

phase.

Allows DOT to define the purpose and need for any 

airport capacity-enhancement project for any federal 

or state review that requires the establishment of a 

purpose and need.

Not addressed. Reaching stakeholder 

agreement. 

Eliminates the required Governor's certification, 

which states that an airport will meet state and local 

environmental standards.

Eliminates the required Governor's certification, 

which states that an airport will meet state and local 

environmental standards.

Completing the 

environmental review 

phase. 

12U.S. General Accounting Office, Aviation and the Environment: Airport 

Operations and Future Growth Present Environmental Challenges, GAO/RCED00-153 (Washington, D.C.: Aug. 30, 2000). 
Page 19 GAO-03-164 Aviation Infrastructure

which is largely duplicative of protections under the Clean Water Act. Both 

the House and the Senate bills would have eliminated the Governor’s 

Certificate requirement.

FAA Initiatives Focus on 

Streamlining the Planning 

and Environmental Review 

Processes

FAA has identified and undertaken several initiatives directed at 

streamlining the planning and environmental review processes and 

improving cooperation, communication, and coordination among major 

stakeholders. Some of the initiatives have been implemented, and others 

are currently underway. FAA officials believe that the initiatives, if 

successful, will provide measurable improvements in the amount of time 

and resources spent in the planning and environmental review phases of 

the process. 

FAA has undertaken several initiatives to improve the planning and 

environmental processes that the agency believes will help ensure that 

runway projects are completed in a timely manner. With respect to 

planning, FAA prepared an internal Memorandum of Agreement in 

September 2002 to standardize the procedures for establishing 

multidisciplinary teams to participate in major airport planning studies. 

The agency has plans to update its guidance on airport master plans and to 

upgrade an airspace and ground capacity simulation model in fiscal year 

2003, and to update its guidance on airport terminal planning and design by 

the end of fiscal year 2004. With respect to streamlining the environmental 

review process, FAA began implementing several initiatives in January 

2001 that are designed to produce measurable improvements. FAA began 

establishing multidisciplinary EIS teams for new EISs at large hub primary 

airports, reallocating staff resources and seeking airport reimbursable 

agreements to support environmental work, and increasing the use of 

consultants to assist FAA with coordination and administration of EISs.

To increase coordination and assign accountability for runway 

development tasks to key stakeholders, FAA began another initiative in 

August 2001 as a part of its Operational Evolution Plan—a 10-year plan to 

expand and modernize the nation’s airport system. FAA developed detailed 

plans called Runway Template Action Plans to provide a standard set of 

tasks that must be considered when developing new runways. FAA has 

completed Runway Template Action Plans for 12 airports that are expected 

to complete new runways by 2008. According to FAA officials, the agency 

has met the deadlines for its commitments at all of the airports, and no 

runway completion date has changed as a result of FAA actions since the 

program began.
Page 20 GAO-03-164 Aviation Infrastructure

While the Executive Order and the proposed legislation were designed to 

address challenges some of the airports experienced, it is too early to 

assess their impact; the Executive Order was only recently signed, and the 

legislation did not pass in the 107th session of Congress. Nonetheless, 

several stakeholders, including airports we surveyed and visited, supported 

efforts consistent with these initiatives. Further, FAA officials believe that 

the initiatives FAA has taken and proposed will yield measurable 

improvements in the runway development process—particularly with 

respect to the planning and environmental review phases of the process. 

Airports Have Undertaken 

Some Initiatives to Address 

Challenges

Airports we visited and surveyed described a number of actions they have 

taken to address the challenges they faced in building their runways. These 

actions included proactive approaches to working with stakeholders to 

plan for and mitigate various impacts of the runway projects on 

neighboring communities. For example, the Louisville airport used an 

unusual approach to deal with the needs of neighboring homeowners who 

would be required to move in order to be outside the noise parameter levels 

posed by the new runway. After reaching agreement on the market value 

that the airport would pay for each home, the airport offered these 

residents a choice: residents either could move to a new home of equal 

value in a new community development being built by the airport, or they 

could participate in the traditional relocation program, where the airport 

purchases the home and the family relocates to a home and location of its 

choosing. Airport officials stated that this approach worked well for both 

the airport and the displaced residents. According to airport officials, the 

residents benefited because those who wished to stay together as a 

community (which was the preference of many) were able to do so, and the 

airport saved approximately $17,000 per home on those homes built in the 

new community development.

A Washington State Department of Transportation official stated that 

minimizing controversy over the uses of land needed for expanding runway 

capacity could be important in avoiding lengthy project delays. The 

department developed an Airport Land Use Compatibility Program, 

implementing a 1996 amendment of the Washington State Growth 

Management Act—the state’s land-use planning law. The law requires cities 

and counties to identify, site, and protect essential public facilities 

(including airports) from incompatible land use, such as encroaching 

development. In other words, when developing local land-use plans, cities 

and counties must ensure that their plans do not adversely affect these 

facilities. As part of the land-use compatibility program, certain state 
Page 21 GAO-03-164 Aviation Infrastructure

transportation officials provide consultations, including mediation, 

between airport sponsors and community representatives (often municipal 

or county planning staff) to balance the state’s dual interest of promoting 

aviation and ensuring the health, safety, and welfare of its residents. The 

approach to facilitating airports’ future expansion includes several steps, 

including the development of planning-based solutions and the integration 

of those solutions into a legally enforceable document, such as a 

comprehensive development plan—rather than the Airport Master Plan, 

which is not binding on land-use authority—in order to increase the 

probability that the solutions will succeed.

In Minneapolis, the airport attempted to build consensus throughout the 

project by considering mitigation agreements that were more liberal than 

those required by FAA. For example, the airport has been pursuing a liberal 

noise-mitigation strategy in order to better address community concerns 

about noise impacts. The airport chose to keep residential blocks together 

for noise-mitigation measures, whether or not the entire block fell within 

the same noise contour. In other words, if one residence in a block lay 

within the 65-decibel Day Night Average Sound Level (DNL) noise contour, 

every residence on the block received similar mediation measures.13

Another challenge for which the airport had to develop a solution was 

mitigating the noise impacts on a National Wildlife Refuge located within 

the flight path of the new runway. The refuge contains an educational 

center and is a popular location for bird watching. The refuge contended 

that the usefulness of the center and bird watching activities would be 

severely impacted by noise from the runway. The airport and the refuge 

were ultimately able to negotiate an agreement whereby the airport 

authority would pay the organization $26 million for the right to conduct 

flight operations over the refuge.

In Dallas-Fort Worth, the airport chose to implement a four-stage approach 

to mitigating the noise impacts of the runway project: 1) direct land 

acquisition for properties located in the runway protection zone, 2) direct 

land acquisition of certain properties for noise mitigation, 3) sound 

proofing structures for noise mitigation, and 4) acquisition of aviation 

easements. Airport officials noted that the first three stages of the 

mitigation plan are standard among most runway projects and, in the case 

of acquiring properties in the runway protection zone, required of all 

13The Day Night Average Sound Level is a measurement of the average noise impacts of the 

airport on the surrounding community. 
Page 22 GAO-03-164 Aviation Infrastructure

airports. However, with respect to aviation easements, the airport 

undertook an approach that it considered to be extraordinary at the time. 

The airport offered residents 25 percent of the fair market value of their 

property to acquire easements for noise impacts. The easements are 

attached to the property deed, affecting the current property owner and all 

future owners of that property.

Overall, the airports that described these initiatives believed they had a 

positive impact on their runway projects. Other airports described similar 

initiatives that they believed were helpful in facilitating the completion of 

the various phases of their projects. It may be helpful for other airports to 

consider these initiatives when faced with similar challenges; however, the 

wide variety of situations faced by airports and the differing levels of 

community opposition or environmental issues each airport faces make it 

difficult to determine whether an effort undertaken successfully by one 

airport will have the same positive results at another airport. 

Agency Comments We provided the Secretary of Transportation with a copy of a draft of this 

report. FAA officials agreed with our characterization of the challenges 

associated with building runways and our identification of some of the 

initiatives to address these challenges. However, they did express some 

concerns related to our analysis of the amount of time airports spent or 

estimated spending in developing their runways, as compared with the 

results of FAA’s 2001 study. They also suggested that GAO include more 

acknowledgment of their efforts in trying to improve the runway 

development process. Regarding FAA’s concerns, we believe our approach 

was a reasonable assessment of the amount of time it takes airports to 

build runways. However, we clarified our discussion on the length of time 

by focusing on the median time rather than the average time because this 

approach minimizes the impact of outlying airports that may have taken a 

very long or a very short time to build their runways. We also compared our 

analysis of the time taken by airports to build runways with FAA’s study. 

See appendix I for a more detailed discussion of the comparative analysis. 

Finally, we included information regarding several initiatives that FAA has 

undertaken to streamline and improve the planning and environmental 

processes. We also made technical changes throughout the report as 

appropriate.

We performed our work from April 2001 through December 2002 in 

accordance with generally accepted government auditing standards.
Page 23 GAO-03-164 Aviation Infrastructure

As agreed with your office, unless you release its contents earlier, we plan 

no further distribution of this report until 10 days after the date of its 

issuance. At that time, we will send copies of this report to congressional 

committees with responsibilities for the activities discussed in this report; 

to the Secretary of Transportation; and to the Administrator of the Federal 

Aviation Administration. We will make copies available to others upon 

request. This report is also available at no charge on GAO’s Web site at 

http://www.gao.gov.

If you or your staff have any questions regarding the contents of this report, 

please call me or Tammy Conquest at (202) 512-2834. Other key 

contributors to this report were Ruthann Balciunas, William Chatlos, David 

Hooper, Gary Lawson, David Lehrer, and Alwynne Wilbur.

Gerald L. Dillingham, Ph.D

Director, Physical Infrastructure Issues
Page 24 GAO-03-164 Aviation Infrastructure

Appendix I

Scope and Methodology AAppenednxidexiIs

Our primary methods for addressing our two research questions—first, 

how much time do airports spend building their runway projects and what 

challenges do airports and other stakeholders experience during this 

process, and second, what have airports and other stakeholders done or 

proposed to do to address the challenges they experienced in building 

runways—-were to conduct a nationwide survey of airports that built new 

runways between 1991 and 2000 or planned to build new runways by 2010, 

and to perform site visits at five airports. The survey population included 

30 airports, 16 of which had built their airports between 1991 and 2000, and 

14 of which had planned to build new runways by 2010. The survey, 

conducted in February 2002, provided data on the amount of time that 30 

airports spent in planning and building 32 runway projects; on key factors 

that accelerated or delayed the projects; and on initiatives that airports 

have taken to address the challenges they faced during the process.14

Based on our analysis of the survey responses, we judgmentally selected 

five airports at which to conduct site visits, to develop a more in-depth 

understanding of the experiences and challenges they faced. We 

subsequently visited Boston Logan, Dallas-Fort Worth, Memphis Shelby 

County, Minneapolis-St. Paul, and Seattle-Tacoma Airports, where we 

interviewed the airport authority, FAA, hub airlines, state agencies, 

metropolitan planning organizations, and local community and 

environmental groups about their experiences with the runway projects. In 

addition, we also interviewed officials from Lester B. Pearson International 

Airport in Toronto, Canada, and Transport Canada to gain an understanding 

of the Canadian runway development process.

We also compared our analysis with FAA’s May 2001 report. While the 

results of the two studies are similar, there are some methodological 

differences between the two studies. First, our measurement begins at the 

start of planning and ends with the completion of the runway. In contrast, 

FAA’s measurement begins with planning but ends with the beginning of 

the design and construction phase. Second, GAO’s analysis is based on the 

median time, which minimizes the impact of runways that take a very long 

or a very short time to complete; FAA’s estimate, however, is based on the 

average time, which does not account for the impact of outliers. Based on 

our survey responses, when considering the average time, we found that 

airports that had completed their projects took 12.25 years and airports 

14Information on the time airports spent in various parts of the process is based, in part, on 

estimates provided by some airports that have not yet completed their projects. 
Appendix I

Scope and Methodology

Page 25 GAO-03-164 Aviation Infrastructure

that had not yet completed their projects estimated that their projects 

would take about 16 years. Third, our survey allowed the airports to 

determine the beginning and end of each of the process phases, whereas 

FAA selected specific events for analysis. For example, FAA’s analysis 

based the end of the environmental review phase on the issuance of the 

ROD. Certain airports responding to GAO’s survey included federal and 

state permits as part of the environmental process. FAA’s May 2001 report 

found that federal and state permits can take 6 to 12 months or more to 

complete after the ROD. Finally, each of the two analyses examined a 

different universe of airports. FAA analyzed data on 10 airports that had 

projects approved between 1996 and 2000. GAO analyzed data on over 30 

runway projects that were completed, or expected to be completed, 

between 1991 and 2010. GAO’s analysis included 6 of the 10 airports that 

FAA analyzed.

We also interviewed officials from FAA, Airports Council International, the 

Airline Transport Association, and the National Association of State 

Aviation Officials to obtain information on the process for building 

runways and to identify what actions have been taken to address 

challenges related to planning and building runways. 

We conducted our work from April 2001 through December 2002 in 

accordance with generally accepted government auditing standards.
Page 26 GAO-03-164 Aviation Infrastructure

Appendix II

Airport Site Visits ApendxiI

To gain additional perspective on the runway development process, we 

visited five airports that had significant positive or negative experiences in 

going through the runway development process; some of the airports 

identified initiatives to overcome these challenges.15 We also included 

airports that were in various stages of completing their runway projects, 

and in various parts of the country. We asked the airports to share their 

experiences in the process of building new runways, as well as those 

events that either significantly delayed or accelerated the completion of the 

runway projects. We identified several key factors—the amount of time 

that transpired, how this time compared with the airports’ expectations of 

the process timeline, how key stakeholders’ timeliness compared with the 

airports’ expectations, and the significant events that either delayed or 

accelerated the completion of the runways. In addition, we considered the 

airports’ responses to other questions, as warranted. We also visited the 

Lester B. Pearson International Airport in Toronto, Canada, to gain an 

understanding of the Canadian runway development process and of the 

airport’s experiences in building runways. The overarching factor leading 

to selection was the airports’ experiences that appeared appropriate for 

other airports to draw upon. These experiences, both positive and negative, 

are intended to yield lessons that other airports can emulate or avoid. Table 

2 shows the airports we selected and the phase of each project as of 

December 2002.

15See appendix I for the methodology we used to select the airports we visited.
Appendix II

Airport Site Visits

Page 27 GAO-03-164 Aviation Infrastructure

Table 2: Airports Selected for Site Visit and their Runway Projects

Source: U. S. General Accounting Office.

a

Runway development phases often overlap. The phase shown is the phase with the predominant 

activity as of December 2002. 

b

The airport suspended development of this runway to explore implications of recent economic and 

industry events.

Appendixes II through VII contain a summary of the results of our visit to 

each airport, including background information and status of the runway 

project. The summaries also highlight significant events and experiences 

for each specific location, based on our discussions with the airport 

authorities and key stakeholders. While each of the airports we visited 

experienced challenges within several broad themes noted earlier 

(resolving stakeholder differences, completing extensive environmental 

requirements, and addressing issues related to runway design and 

construction), those broad themes were not necessarily the most important 

at that specific site. Consequently, we highlight different experiences at 

each site. For example, the Boston airport’s legal challenges were much 

more extensive than were those at the Minneapolis-St. Paul airport. We 

discuss Boston’s legal challenges at length, while we mention those at 

Minneapolis-St. Paul as they applied to other experiences.

General Edward 

Lawrence Logan 

International Airport – 

East Boston, MA

Boston’s Logan International Airport is operated by the Massachusetts Port 

Authority (Massport). According to FAA, airport, state, and airline officials, 

Logan plays a critical role in the New England economy, and it serves as the 

region’s long-haul and international gateway airport. According to 

Massport officials, in 2000, the airport handled 27.4 million passengers and 

Airport Location Size Phasea

Gen. Edward Lawrence Logan 

International

East Boston, MA Large Environmental

Dallas-Fort Worth International DFW, TX Large Completed

Dallas-Fort Worth International DFW, TX Large Suspendedb

Memphis International Memphis, TN Medium Completed

Minneapolis-St. Paul International Minneapolis, MN Large Construction 

Seattle-Tacoma International Seattle, WA Large Environmental

Lester B. Pearson International Toronto, Ontario Large Completed

Lester B. Pearson International Toronto, Ontario Large Completed

Lester B. Pearson International Toronto, Ontario Large Planning
Appendix II

Airport Site Visits

Page 28 GAO-03-164 Aviation Infrastructure

contributed about $6.6 billion to the regional economy, supporting about 

100,000 jobs. It was North America’s nineteenth-busiest in terms of 

passenger traffic. Logan is consistently ranked as one of the nation’s most 

delayed airports. In 2000, Logan was the sixth-most delayed airport overall 

and second-most delayed for arrivals. Logan is served by all the major U.S. 

carriers. The top carriers are U.S. Airways, American, and Delta, with 

roughly equal shares of passenger traffic. The airport is primarily an origin 

and destination point, with about 90 percent of the passengers beginning or 

ending their trips at Logan. 

In good weather, Logan generally operates on a north-south, three-runway 

configuration with a capacity of about 120 flight operations per hour. 

However, during adverse weather conditions (such as northwest or 

southeast winds in excess of 10 knots per hour, which occur about onethird of the year), the airport can be reduced to as few as 60 to 90 

operations per hour on an east-west, one- or two-runway operation. 

Massport believes that its proposed 5,000-foot, unidirectional runway will 

avoid the significant reduction in efficiency during adverse weather 

conditions and help mitigate weather-related delays.16 Massport views the 

runway as a capacity-neutral airfield enhancement, which means that the 

proposed runway will decrease delays without increasing the airport’s top 

capacity of about 120 flights per hour. The Massachusetts Executive Office 

of Environmental Affairs administers the Massachusetts Environmental 

Policy Act, the state’s environmental protection act. In its Final 

Environmental Impact Report certificate, the Secretary, Massachusetts 

Executive Office of Environmental Affairs, stated that the central 

environmental question is not whether the project is accommodating or 

generating demand per se, but rather whether Massport is operating the 

airport in a manner that avoids, minimizes, or mitigates environmental 

impacts in light of its obligations under MEPA. An official from the 

environmental office stated that the project might increase airfield 

capacity, but that an airport capacity determination was beyond the scope 

of its review. Figure 4 shows the existing Logan runway configuration, 

including the proposed runway project.

16All flights using this runway would arrive from the southeast or depart from the northwest, 

over Boston Harbor.
Appendix II

Airport Site Visits

Page 29 GAO-03-164 Aviation Infrastructure

Figure 4: Airport Diagram—Boston’s Logan International Airport

We selected Logan Airport as a site-visit location, in part, because its 

runway project has been in the planning phase since 1969.17 Further, a state 

court injunction against building new runways at the airport has been in 

place since the mid-1970s (FAA approved an EIS for a runway in the same 

general location on the airfield in the late 1960s). Further, because of the 

injunction, Massport decided not to actively pursue the project until the 

project was reinstituted in 1995, based on an FAA Capacity Enhancement 

17Logan Airport was not the only airport that spent a long time in the planning phase. Of the 

30 airports we surveyed, two others—Phoenix and Indianapolis—also reported spending a 

long time (about 20 years or more) in the planning phase. 
Appendix II

Airport Site Visits

Page 30 GAO-03-164 Aviation Infrastructure

Study. Logan is an example of an airport that has spent a long time in the 

process, and it has gone through several iterations of the EIS review 

process. 

We interviewed officials at Massport, who were the main sponsors of the 

new, sixth runway at Logan. We also interviewed officials at FAA’s New 

England Region, American Eagle Airlines, Massachusetts Executive Office 

of Environmental Affairs, and the Massachusetts High Technology Council. 

We also gathered information from Communities Against Runway 

Expansion, the primary community interest group.18

Current Status of the 

Runway Project

FAA issued its ROD indicating that the project had satisfied all federal 

environmental requirements on August 2, 2002. However, the airport can 

not yet begin constructing the runway because of an existing state court 

injunction. Moreover, opposition groups appealed the ROD in August 2002 

in the U.S. Court of Appeals in Washington, D.C., arguing, among other 

things, that FAA did not adequately analyze the noise and air quality 

impacts on neighboring communities. 

Stakeholders Cite 

Community Opposition 

as a Major Challenge 

and Say Efforts to 

Address This Issue 

Were Unsuccessful

Massport and other stakeholders we interviewed (American Eagle Airlines, 

Massachusetts Executive Office of Environmental Affairs, FAA, and the 

High Technology Council) said that the lack of agreement among 

stakeholders—particularly with regard to responding to the strong ongoing 

community opposition to the runway project—has presented a major 

challenge. Communities Against Runway Expansion and other local 

community groups surrounding the airport opposed the project because of 

a number of issues, including the impact of the runway on noise, emissions, 

economic growth, and endangered species. Opponents to the project also 

question the intended use of the runway (for example, delay reduction 

versus capacity enhancement). According to FAA, Massachusetts 

Executive Office of Environmental Affairs, American Eagle Airlines, the 

High Technology Council, and Massport officials themselves, the public 

appears to distrust Massport. These stakeholders added that much of the 

opposition stems from the fact that the airport is located in downtown 

Boston rather than from plans for a new runway, and that community 

18The Communities Against Runway Expansion Vice President is also the Chair of the 

Community Advisory Council, a group representing various communities around Logan.
Appendix II

Airport Site Visits

Page 31 GAO-03-164 Aviation Infrastructure

groups opposed to the project are not likely to change their position. 

According to an American Eagle Airlines official, FAA should help 

community groups understand the economic benefits of the project on 

their communities.

Massport said it has attempted to address this challenge through extensive 

public participation and review efforts, but that these have not been 

successful. FAA, Massachusetts Executive Office of Environmental Affairs, 

and the airlines have agreed that Massport involved the public throughout 

most of the lengthy process, and that the public was able to express its 

concerns to Massport through the public meetings and the required public 

comment periods on FAA’s decisions. According to Massport, in response 

to public pressure, FAA created a special review panel and required 

Massport to undertake a supplemental Draft EIS as a means to further 

expand public participation. As part of the public outreach process, 

Massport provided $350,000 for technical assistance to the Community 

Advisory Council. Communities Against Runway Expansion, on the other 

hand, stated that Massport’s efforts toward communication were for 

appearance only—that the airport authority spoke to them but did not 

listen to their concerns. All agreed that extensive communication did not 

lead to cooperation and consensus.

Stakeholders Say 

Meeting Extensive 

Environmental 

Requirements Has 

Been Challenging 

Because of Community 

Opposition 

Massport and FAA prepared a joint Draft Environmental Impact Report and 

Draft EIS to meet state and federal requirements. According to Massport, 

this joint effort is a common approach for streamlining the environmental 

review process. The joint state and federal permit process lasted over 7 

years. Stakeholders said this is partly attributable to community opposition 

and to the effect of this opposition on the process.

In 1995, in what it described as an effort to conduct the environmental 

analysis with input from all concerned parties, Massport established the 

Airside Review Committee, which included representatives from the 24 

communities surrounding the airport and from 11 business and industry 

organizations. However, according to both FAA and Massport, this effort 

was suspended for about 18 months between 1996 and 1998, when the 

entire runway project stalled because of a change in Massport leadership 

and priorities. In 1998, according to Massport officials, the airport 

attempted to pick up the environmental review process where it had been 

suspended. Community groups complained that they had not been part of 

the recent process and appealed to FAA that the Draft EIS was no longer 
Appendix II

Airport Site Visits

Page 32 GAO-03-164 Aviation Infrastructure

accurate, complete, or up-to-date. Massport believes it did try numerous 

times to meet with the Airside Review Committee, but to no avail.

The state approved the Draft Environmental Impact Review in May 1999 

and the final Environmental Impact Review in June 2001. However, FAA 

requested a Supplemental Draft EIS rather than approving the Draft EIS. 

FAA officials stated that the agency did so because it needed to address 

several issues, including changing technology and the high level of 

concerns expressed by project opponents in public comments to the Draft 

EIS. Massport, the Massachusetts High Technology Council, and American 

Eagle Airlines all believe that FAA’s decision was unreasonable. Massport 

officials contended that the project had already undergone 5 years of public 

process, that continuation was unlikely to help achieve local consensus, 

and that they believed it had not. FAA officials, however, believe that it did 

result in a better, more informative EIS document.

Individuals, communities, action groups, and business groups submitted 

comments during public information meetings and hearings and in 

response to the Draft EIS and Final EIR documents that were extensive. 

For example, about 800 people attended the two April 2001 public hearings 

for the Supplemental Draft EIS document and about 850 comment letters 

were received during the 75-day comment period.

The Supplemental Draft EIS took about 1 year to complete, and it delayed 

the filing of the Final EIS by about 1.5 years, according to Massport. During 

this time, in another attempt to develop agreement among stakeholders, 

FAA chaired a city and commonwealth Task Force to request further 

comments to the Draft EIS for incorporation into the Supplemental Draft 

EIS. Although this group met, analyzed, and discussed many runway issues, 

not all stakeholders were pleased with its outcome. For example, 

Communities Against Runway Expansion stated that the products of the 

panel’s work, the Supplemental Draft EIS and the Final Environmental 

Impact Review, were inaccurate and inconclusive, and they justified the 

runway without proposing a viable alternative.

In late June 2002, FAA issued the Final EIS for public comment, as required 

by the NEPA process. FAA received approximately 100 comment letters 

raising 42 main issues, ranging from general opposition to a concern about 

the adequacy of technical analyses. FAA said that it responded to the 

comments as required and issued its final approval, the ROD, in August 

2002. In both the Final EIS and the ROD, FAA included a restriction (which 

Massport officials said was unprecedented) that the proposed runway be 
Appendix II

Airport Site Visits

Page 33 GAO-03-164 Aviation Infrastructure

used only when winds create conditions in which the usefulness of other 

current runways is limited.19 FAA considers this wind restriction a 

mitigation measure, as it would ensure that the runway was not used to 

increase capacity during good weather. Many stakeholders—including 

proponents and opponents—view this restriction as a compromise 

designed to achieve consensus, but others, such as community groups, 

maintain that the wind restriction does not go far enough to mitigate the 

environmental effects of this project. Communities Against Runway 

Expansion continued to contest FAA’s approval in the press and in federal 

court and, through an urgent message on its Web page, urged others to 

respond to the Final EIS. Moreover, Massport and Massachusetts Executive 

Office of Environmental Affairs officials said that, by issuing the ROD with 

wind restrictions, FAA could reactivate the state environmental review 

process because the approved project differs significantly from what 

Massachusetts Executive Office of Environmental Affairs approved in 

2001. Subsequently, the Executive Office of Environmental Affairs chose 

not to reexamine the environmental document because it did not believe 

that the wind restriction significantly changed the environmental impacts 

of the runway.

FAA, Massport, and American Eagle Airlines said that, during the length of 

time spent attempting to get all of the environmental approvals needed, 

some assumptions made early on in the process have been called into 

question. For example, concerns have been raised that traffic forecasts 

may not materialize, that the increasing use of Regional Jets may change 

the equipment mix more than planned, and that the 5,000 foot runway may 

not be long enough to be as useful as hoped. They believe that these issues 

played a part in triggering FAA’s Supplemental Draft EIS process. However, 

a Massachusetts Executive Office of Environmental Affairs official stated 

that it is not possible to “freeze” the process to figure out all the answers 

before making a decision. According to many stakeholders, the 

environmental review process is a continuous cycle in which comments 

require additional study, which leads to revisions, which lead to more 

comments, which lead to additional study. They contend that the circuitous 

nature of the process is the primary source of delay. The Massachusetts 

environmental permit process has important time triggers that allow for the 

19The ROD limits the use of the proposed 14/32 runway to those times when wind conditions 

equal or exceed 10 knots, either northwest or southeast. FAA Air Traffic Control is 

responsible for runway assignments and will base its use of 14/32 on forecasted wind 

conditions. The Record of Decision also includes a 2-hour window to adjust to changing 

conditions.
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Airport Site Visits

Page 34 GAO-03-164 Aviation Infrastructure

process to come to an end. Massport believes that if similar triggers were in 

place at the federal level, many of the delays encountered during the EIS 

process could have been avoided. 

Litigation Added Time 

to Process

Massport first suggested, and actually began construction on, a new 3,830 

foot runway in the same general location on the airfield almost 30 years ago 

(May 1974). Massport took the position that the 1974 runway project did 

not require a state environmental review because 1) both the Massport 

Board and the Commonwealth Office of Transportation and Construction 

determined it had no environmental impact and 2) the project commenced 

before July 1, 1973, the effective date of the Massachusetts Environmental 

Policy Act. The City of Boston and the Massachusetts Secretary of 

Environmental Affairs both disagreed and sued Massport. The Suffolk 

Superior Court enjoined Massport from proceeding with the 1974 Runways 

Project, pending the preparation, filing, and review of a final EIR as 

directed by the Secretary of Environmental Affairs. 

On June 15, 2001, the Secretary of Environmental Affairs determined that 

Massport’s Final EIR submitted in March 2001 adequately and properly 

complied with the Massachusetts Executive Office of Environmental 

Affairs. Massport went to court to get the injunction lifted. The court began 

considering this injunction in late January 2003. Groups opposing the 

project declared victory because the motion to lift the injunction went to 

trial. A second lawsuit, regarding runway development in Plymouth County, 

located southeast of the airport, resulted in a summary judgment in favor of 

Massport. This matter is now under appeal. Plymouth County includes the 

cities of Hull, Hingham, and Cohasset, all in the flight path of the over-thewater operations. These local municipalities alleged that the state 

environmental permit was invalid because Massport misled the 

Massachusetts Executive Office of Environmental Affairs about the 

project’s impact by providing incomplete and inaccurate technical data. 

Table 3 summarizes the history of the Boston Logan runway project. 
Appendix II

Airport Site Visits

Page 35 GAO-03-164 Aviation Infrastructure

Table 3: History of the Boston Logan Runway Project

Source: U.S. General Accounting Office.

Date Event

Late 1960s FAA approves new runway. 

August 1974 State court injunction against building new runways at airport.

June 1976 State court injunction against building new runways at airport 

amended.

November 1995 Massachusetts Secretary of Environmental Affairs defines Draft 

EIR scope. 

November 1995 Massport establishes Airside Review Committee.

January 1996 FAA defines Draft EIS scope. 

February 1999 Massport files Draft EIS/Draft EIR with state and FAA.

April 1999 FAA and Massport hold public meetings on Draft EIS/Draft EIR.

May 1999 State approves Draft EIR.

January 2000 FAA orders supplemental Draft EIS.

March 2001 Massport submits supplemental Draft EIS/Final EIR to state and 

FAA.

April 2001 FAA and Massport hold public hearings on supplemental Draft 

EIS/Final EIR.

June 2001 State approves Final EIR.

June 2002 FAA publishes Final EIS for public comment.

August 2002 FAA issues ROD.

August 2002 FAA approves Airport Layout Plan.

August 2002 Community groups appeal ROD in U.S. Court of Appeals.

September 2002 Massachusetts MEPA decides not to reopen state process.

October 2002 Community challenge of state environmental approval trial 

dismissed.

January 2003 Massport challenge of injunction trial date (Suffolk Superior 

Court).

Spring 2006 Projected completion date.
Page 36 GAO-03-164 Aviation Infrastructure

Appendix III

Dallas-Fort Worth International Airport – 

DFW, TX ApendxiI

In 2001, the Dallas-Fort Worth International Airport was the fourth-busiest 

North American airport in terms of passengers. Both American Airlines and 

Delta Airlines run hub operations at the airport, with about 70 percent and 

19 percent of the airport’s annual operations, respectively. According to the 

airport’s Chief Executive Officer, the airport provides $12 billion in annual 

economic activity for North Texas. 

The Dallas-Fort Worth Airport Board (the Board) governs the airport. The 

Board is composed of 12 members, 11 of whom are appointed by the 

councils of the airport’s owner cities in accordance with each city’s 

ownership interest in the airport; 7 represent the city of Dallas, and 4 

represent the city of Fort Worth. The 12th member is a nonvoting member 

representing the neighboring host cities of Coppell, Euless, Grapevine, and 

Irving on a rotating annual basis (the member is from a particular city every 

fourth year). The Board may enter into contracts without approval of the 

City Councils, but its annual operating budget requires City Council 

approval of the owner cities. 

The airport lies within the city limits of the four host cities. It obtained the 

freedom to pursue independent development through state legislation 

known as the Texas Municipal Airports Act. It covers over 29 square miles, 

and its real property consists of over 18,000 acres. The current 

configuration is seven runways—five north-south parallel, two diagonal. 

Four of these runways are over 11,000 feet in length. This configuration 

allows the airport to land four planes simultaneously. In good weather, the 

airport generally operates with a capacity of about 260 to 270 operations 

per hour. Airport revenue is shared with the surrounding cities based upon 

the location of the enterprise. For example, the rental car franchises are 

located in Euless, so that city receives a portion of the car rental tax 

revenues.

The seventh runway was designed to reduce delays as well as to increase 

overall aircraft operations capacity. Airport officials developed the 1991 

DFW Airport Development Plan, which included two new runways in 

response to market demand, to maintain the highest level of service for 

their customers. Figure 5 shows the existing Dallas-Fort Worth 

International Airport configuration, including the proposed eighth runway 

and several proposed extensions.
Appendix III

Dallas-Fort Worth International Airport – 

DFW, TX

Page 37 GAO-03-164 Aviation Infrastructure

Figure 5: Airport Diagram—Dallas-Fort Worth International Airport

We selected the Dallas-Fort Worth International Airport for a site visit 

because the airport, which was completed in February 1974, is one of the 

most recently constructed airports in the United States (only Denver is a 

more recently constructed large hub airport). The airport completed its 

seventh runway in 1996, and had planned to complete an additional eighth 

runway before more sophisticated demand-delay studies were completed. 

Furthermore, the airport reported in our survey that many elements of the 

runway development process took less time than expected. 

We interviewed officials at the following: Dallas-Fort Worth International 

Airport, the sponsor of the new runway projects; the four host cities 

surrounding the airport—Coppell, Euless, Grapevine, and Irving; FAA 

Southwest Regional Office and Airports District Office; North Central 

Texas Council of Governments; and the Texas Commission on 

Environmental Quality. We attempted to contact American Airlines, but 

airline officials said that too much time had passed since the early phases 

of the project for its response to be meaningful.
Appendix III

Dallas-Fort Worth International Airport – 

DFW, TX

Page 38 GAO-03-164 Aviation Infrastructure

Current Status of the 

Two Runway Projects

The seventh runway was commissioned in October 1996. All activities for 

the proposed eighth runway have been temporarily suspended while 

airport officials explore the implications that recent economic and industry 

events will have for runway need. 

Airport Officials 

Described Extensive 

Environmental Review 

Process as Challenging

According to the airport Chief Executive Officer, the environmental review 

process for the seventh runway required the airport to coordinate the 

activities of 19 federal agencies and 15 state agencies, and this process was 

further complicated by the lack of prime contacts and personnel changes at 

reviewing agencies. Public controversy and public demands for 

information exceeded the airport’s expectations and necessitated a highly 

detailed environmental review. According to airport officials, this review 

included an analysis of 12 project alternatives, although many were not 

equally viable or would not survive the review process. According to these 

officials, the airport will probably include two alternatives in future 

reviews—build/no build—and then add specific alternatives for study if 

reviewers request that additional alternatives be examined. Officials felt 

that preparing an analysis of alternatives in this way will likely be less 

costly and time-consuming than would preparing alternatives that, in their 

opinion, clearly have no relevance.

The Dallas-Fort Worth 

International Airport 

Used Some Unique 

Approaches to Mitigate 

Runway Impacts

The Dallas-Fort Worth International Airport chose to implement a fourstage approach to mitigating the off-airport noise impacts of the runway 

project: 1) direct land acquisition for properties located in the runway 

safety area; 2) direct land acquisition of certain properties for noise 

mitigation; 3) sound-proofing structures for noise mitigation; and 4) 

acquisition of aviation easements.20 The airport offered 25 percent of the 

fair market value of the property to acquire aviation easements. According 

to airport officials, the easements were written so that residents who 

accepted them still have legal standing to take the airport to court over 

noise impacts. Airport officials estimated that final mitigation costs would 

be about $176 million. The last of the real estate settlements were paid out 

in 2002. The final cost of the mitigation program exceeded the runway cost 

by a wide margin.

20Aviation Easements (also referred to as Avigation Easements) are rights given to the 

airport to fly aircraft over property; they indicate that property owners acknowledge and 

accept the noise impacts of the aircraft.
Appendix III

Dallas-Fort Worth International Airport – 

DFW, TX

Page 39 GAO-03-164 Aviation Infrastructure

The airport created an independent agency, the Action Desk, before 

beginning the mitigation plan implementation. The Action Desk was the 

main point of contact for property owners to provide and obtain 

information and to file concerns and complaints. This office developed a 

database of property-owner information and disseminated a newsletter. 

According to airport officials, this approach was highly effective in 

providing property-specific information to property owners that countered 

misinformation about the project and allayed fears. The airport also hired a 

consultant to manage the mitigation process, and it established an appeals 

process by which property owners could contest the acquisition process. 

The appeals council was composed of airline employees, local residents, a 

local clergy member, and airport board members. The airport Chief 

Executive Officer had final approval of any appeals.

Stakeholder 

Experiences, from 

Start to Finish, Were 

Many and Varied

The Dallas-Fort Worth International Airport still maintains its Capacity 

Enhancement Team, first established in the 1970s, composed of officials 

from FAA, the airport, and the airlines. The airport refers to the team as a 

“three-legged stool.” Each of the groups is equally important to supporting 

this stool. If one of the “legs” doesn’t provide support, the stool falls over. 

Airport officials, FAA, and even local governments made reference to this 

team during our visit. The team’s responsibility is to recommend how the 

airport should address increases in airfield efficiency, safety, and capacity. 

According to airport officials, one of the biggest factors contributing to the 

successful completion of the seventh runway project was the staff 

dedicated to the project from FAA, the Department of Justice, and various 

consultant teams. These stakeholders were assigned to the project. The 

dedicated team provided the airport with single points of contact and 

reduced the potential for misinterpretation or ambiguity, as well as 

continually reeducated the participants. This experience was in contrast to 

the difficulties the airport experienced in coordinating the input from over 

30 agencies in the environmental review process. Airport officials wished 

that they had kept the Environmental Protection Agency involved 

throughout the process, rather than only at the beginning and at the end. 

They also suggested that FAA limit the time frame for agency comments, 

and thereby eliminate lengthy comment periods. The Environmental 

Protection Agency took 260 days to review the EIS, which is considerably 

longer than the 60 to 90 days that the airport expected. 

FAA officials thought that holding many more public information meetings 

than required also contributed to the success of the project, especially 
Appendix III

Dallas-Fort Worth International Airport – 

DFW, TX

Page 40 GAO-03-164 Aviation Infrastructure

during the environmental review process. This way, FAA and others 

answered questions or comments and addressed concerns before the 

official comment period began. FAA also repeated the airport’s suggestion 

that FAA should adhere to the comment deadlines.

The four communities surrounding the airport had both positive and 

negative experiences while working with the airport. Three cities 

challenged the ROD on the basis that its noise analysis and mitigation plan 

were insufficient. (The ROD was upheld 23 months later.) Grapevine felt 

that the airport broke long-standing promises. According to Grapevine 

representatives, the plan that the airport originally presented would have 

placed the area subsequently developed by Grapevine outside projected 

flight patterns. Currently, if the airport continues with its plan for the eighth 

runway, flights will go directly over the city of Grapevine. Irving realized 

that asking for no airport expansion was probably unreasonable, and “you 

really have to cut the best deal you can.” The best possible runway 

development process should make the city whole. Euless will be more 

affected by the eighth runway. While Euless initially joined forces with two 

cities to contest the ROD, it withdrew its challenge. The Euless City 

Manager stated that he appreciated the positive economic impact of the 

airport on the North Central Texas economy and believed the airport needs 

additional capacity to support that economic impact. If the eighth runway 

does become a reality, the City Manager expects the same mitigation plan 

that Irving received for the seventh runway, which he considered fair. The 

fourth community, Coppell, did not challenge the ROD. According to the 

Coppell City Manager, Coppell realized that it had to do its part to approve 

the runway somehow, because the airport is seen as vital to the economies 

of Coppell as well as to the region. The manager felt that airport staff were 

professional, knowledgeable, and helpful and never held things out to be 

different from reality. For example, the airport put together a task force to 

work with the communities affected by overflights.

Litigation Delayed 

Process

The surrounding communities of Irving, Grapevine, Euless, and Coppell 

challenged the airport, asserting that the cities had the rights to control 

zoning on the airport property that fell within their municipal boundaries. 

The municipalities wanted to zone the land for “government use.” Such 

zoning would require that the airport obtain the approval of the city boards 

prior to doing any construction on airport property. The airport objected, 

and took the cities to court. The cities won the case, and also won the 

subsequent appeal. The Texas State Legislature ultimately passed the Texas 

Municipal Airports Act, which stated that the airport sponsors and not the 
Appendix III

Dallas-Fort Worth International Airport – 

DFW, TX

Page 41 GAO-03-164 Aviation Infrastructure

municipalities control zoning on airport property. According to the Chief 

Executive Officer, while the act can apply to any Texas municipal airport, 

the wording of the act leaves little doubt that it applies specifically to the 

Dallas-Fort Worth International Airport. The Chief Executive Officer also 

felt that the support of the local business community was crucial in the 

development and implementation of the project. For example, the business 

community provided support to the airport in the state legislature. This 

case resulted in nearly 7 years of litigation in state courts and ended when 

the Texas Supreme Court denied hearing the complaint.

In addition to the zoning suit, the surrounding municipalities filed suit 

contending that the FAA ROD was based on an inadequate environmental 

impact study. According to the airport’s General Counsel, the cities 

surrounding the airport alleged that FAA and airport officials did not 

properly follow the environmental review process, primarily because the 

airport did not use a proper methodology in determining single-event noise 

impacts. The U.S. Court of Appeals of the District of Columbia upheld the 

ROD after 23 months of argument, and the U.S. Supreme Court denied 

hearing the case. The runway construction was delayed 23 months pending 

the resolution of the case.
Appendix III

Dallas-Fort Worth International Airport – 

DFW, TX

Page 42 GAO-03-164 Aviation Infrastructure

Table 4: History of Dallas–Fort Worth Runway Project

Source: U.S. General Accounting Office.

Date Event

February 1974 Airport opens. 

September 1986 FAA Task Force forms to explore means of expanding air space 

capacity.

January 1987 FAA Task Force initiates Metroplex Air Traffic System Plan Studies.

September 1987 DFW begins runway planning. 

February 1989 DFW begins EIS Scoping.

April 1990 Neighboring cities challenge DFW on zoning issues.

August 1990 FAA releases Draft EIS.

March 1991 DFW completes runway planning, publishes Airport Development 

Plan.

December 1991 FAA issues Final EIS.

April 1992 FAA issues ROD.

April 1992 Three cities challenge ROD.

1993 DFW seeks legislative solution to zoning issues from the 73rd Texas 

Legislature.

May 1993 Texas Municipal Airports Act, reaffirming DFW as exempt from local 

zoning ordinances, takes effect.

March 1994 U.S. Court of Appeals for D.C. Circuit upholds ROD.

April 1996 Texas Supreme Court denies hearing appeal on zoning case from 

Fort Worth Court of Appeals. 

October 1996 DFW completes construction of 7th runway.

February 1998 Texas Supreme Court denies appeal on zoning case from Dallas 

Court of Appeals.

May 1998 DFW publishes 1997 Airport Development Plan Update.

October 2001 DFW suspends activities for 8th runway, while DFW Capacity Design 

Team explores implications of recent economic and industry events 

for runway need.

Spring 2002 DFW pays final real estate settlements. 
Page 43 GAO-03-164 Aviation Infrastructure

Appendix IV

Memphis International Airport ApendxiIV

The Memphis International Airport is a medium-size hub airport that has 

significant levels of both commercial passenger traffic and cargo traffic. 

According to FAA data, this airport was among the 31 busiest U.S. airports 

in 2001. Memphis is one of three major hubs operated by Northwest 

Airlines. Federal Express is based in Memphis, and along with other cargo 

airlines operating there, Memphis has served as the busiest cargo airport in 

the world for the past several years. Additionally, Memphis has claimed the 

distinction of being the number one hub airport in the United States for ontime flights. The Memphis-Shelby County Airport Authority operates the 

Memphis and two general aviation airports. The authority is managed by a 

seven-member county board composed of commissioners who must be 

qualified community leaders in the fields of aviation, engineering, or 

finance. Of the airlines operating at Memphis, three account for about 60 

percent of the operations. Northwest and Federal Express each accounts 

for slightly more than 20 percent of the operations, while Northwest 

Airlink—a commuter airline—accounts for slightly less than 20 percent.

Memphis currently has four runways, three of which are parallel and run 

north and south, including the new runway on the east side of the airport, 

developed between 1984 and 1997, which was the focus of our study. The 

fourth runway runs east and west and is located north of the other 

runways. The addition in 1997 of the new 9,000 foot runway (18L/36R) 

raised the airport’s maximum capacity in good weather from 131 to 145 

operations per hour (about 11 percent) and in bad weather from 84 to 99 

operations per hour (about 18 percent). However, the runway was 

constructed mainly to counteract the capacity reduction incurred by the 

reconstruction and extension of an existing runway, and to help the 

combination of commercial and cargo air service work at the airport. 

Figure 6 shows the existing Memphis airport configuration. 
Appendix IV

Memphis International Airport

Page 44 GAO-03-164 Aviation Infrastructure

Figure 6: Airport Diagram — Memphis International Airport 

Note: According to Memphis airport officials, the center runway has been completed, and changes to 

the remaining runways are no longer planned.
Appendix IV

Memphis International Airport

Page 45 GAO-03-164 Aviation Infrastructure

We selected the Memphis Airport for study because it had quite recently 

experienced all phases of the runway development process—planning, 

environmental, and design and construction. In addition, unlike most other 

airports in our study, it had a significant proportion of its operations 

devoted to cargo, and it was the only medium-size hub airport we visited.

We interviewed airport officials from the Memphis-Shelby County Airport 

Authority who were the sponsors of the runway project. We also 

interviewed officials at FAA Memphis Airport District Office; Federal 

Express Airlines, which accounted for about 20 percent of the airport’s 

operation but about 50 percent of its landed weight; Northwest Airlines, 

Memphis’s leading commercial airline; neighboring business community 

and residential representatives; Tennessee Department of Transportation, 

Aeronautics Division and Highway Division; and Tennessee Department of 

Environment and Conservation.

Status of the Runway 

Project

FAA commissioned the runway in 1997.

Airport Officials Stated 

That They Faced 

Challenges Reaching 

Consensus among 

Stakeholders on 

Project Funding Issues 

and Decisionmaking

A Memphis Shelby County Airport Authority official stated that the airport 

faced challenges reaching agreement among airlines regarding project 

funding during the development of their runway project. Specifically, 

during the planning phase, a funding disagreement arose between the two 

airlines that were the biggest airport users—one a passenger airline and 

one a cargo airline. The passenger airline objected to the airport’s initial 

proposal to fund a major portion of the project using passenger facility 

charges, which are collected only by commercial passenger airlines and not 

by cargo airlines, as it believed that this approach would disproportionately 

benefit the cargo airlines. Ultimately, the airport authority was able to 

negotiate an agreement with the airlines in which project funding was 

based on landing fees, which are proportionate to the gross landed weight 

at the airport and therefore apply to both passenger and cargo aircraft.

The disagreement among airlines regarding project funding highlighted a 

broader issue regarding the establishment of the overall decisionmaking 

process at the airport, according to an airport official. The Memphis airport 

uses a Majority-in-Interest Agreement that stipulates how the airlines (and 

other airport tenants) are involved in the airport’s decisionmaking process. 
Appendix IV

Memphis International Airport

Page 46 GAO-03-164 Aviation Infrastructure

As some airline fees are based on landed weight, some airports’ agreements 

base each airline’s vote on its proportion of landed weight, giving more 

power to those airlines with the greatest landed weight and highest fees. 

However, the Memphis airport chose to structure its voting process to 

prevent any one airline from dominating the decisionmaking process. 

According to its Majority-in-Interest Agreement, a vote to approve or reject 

a proposal, such as any that addressed the runway completed in 1997, must 

have represented more than 51 percent of signatory airlines’ landed weight 

and more than 51 percent of the number of signatory airlines serving the 

airport. This approach allowed all airlines to participate in runway project 

decisions affecting them. Additionally, after 1996, the airport started using 

an “inverted” Majority-in-Interest Agreement, whereby the airport may 

proceed with projects unless an airline requests a formal vote and the 

majority of airlines vote to disapprove the project. This approach—

supported by the two hub airlines at the airport—gives the airport more 

flexibility in project development than would an approach requiring 

airlines to affirmatively approve every significant project step.

Extensive 

Requirements Raised 

Challenges Regarding 

Wetlands Mitigation 

and Land Acquisition 

during Construction of 

Runway 

Airport officials said that extensive environmental and land acquisition 

requirements presented challenges during the construction of the runway 

project. The airport was required to mitigate a wetland area called 

Hurricane Creek and a series of small, adjacent marshy areas on its 

property that needed to be relocated because of impacts associated with 

the construction of the runway and adjacent developable land.21 Airport 

officials said wetlands attract birds that must be “harvested” through 

periodic hunting because of the danger that birds represent to jet airplanes, 

and that airport workers do not like being exposed to the poisonous snakes 

in the creek as they work to maintain the relocated wetlands. According to 

airport officials, it was necessary to relocate a portion of the existing creek 

to construct the new runway, and to straighten the remainder of the creek 

to maximize the use of remaining developable airport property. The airport 

proposed a concrete-lined channel for the relocated creek based on a City 

of Memphis standard. However, state governmental authorities required 

the airport to obtain an aquatic alteration permit from the state and 

requested that it relocate the creek in its natural state so that animals such 

as frogs and poisonous snakes in the creek bed would still have their 

21According to FAA officials, the EIS addressed all major development in the Memphis 

Airport Master Plan, including the new runway. FAA officials contend that if the EIS had 

included only the new runway, no appreciable wetland impacts would have occurred.
Appendix IV

Memphis International Airport

Page 47 GAO-03-164 Aviation Infrastructure

habitat. According to an official from the Tennessee Department of 

Environment and Conservation, this type of requirement is fairly typical for 

airports that are expanding into areas containing water. Another state 

environmental official said that the airport’s concrete lined-channel 

approach had no habitat for living species and would be a direct conduit 

for pollutants. Ultimately, large wire baskets filled with medium-sized 

rocks were used along the new stream alignment, and four artificially 

constructed habitat structures were added in the channel bottom to 

support fish that had been in the stream before it was altered.

Airport officials stated that acquiring land for the runway project took 

longer than they expected because of litigation and requirements 

associated with acquiring the land. According to airport officials, for the 

new runway, the airport acquired a road and adjacent property next to the 

airport that previously contained gas stations and industrial property. Some 

of the acquired properties contained underground tanks that had 

previously leaked chemicals into the ground. The state environmental 

agency required the airport to clean up the polluted properties prior to 

constructing the project, although the airport did not cause the residue 

problems. 

Site-Specific 

Challenges Involved 

Relocating Other 

Infrastructure

During the construction phase, the Memphis airport faced a challenge in 

attempting to relocate a road that lay adjacent to the airport and in the path 

of the new runway. According to airport officials, the City of Memphis 

preferred that the airport be responsible for relocating the road to ensure 

that the work was done in a timely manner. After the new runway project 

was completed in 1997, the airport had a subsequent project to reconstruct 

and extend an existing runway by 2,700 feet to permit use by larger planes 

used for international flights. An airport boundary road had to be lowered 

to allow for the proper clearance of the flight path for the extended runway 

over the boundary road. According to airport officials, the City of Memphis 

owned the road and had widened it about 15 years earlier; the road could 

have been lowered for an additional $250,000. However, the city refused to 

fund the additional project cost at that time. When the airport asked for 

funding from the Federal Highway Administration to assist in lowering the 

highway, the agency determined that no funds were available to meet the 

airport’s required time schedule, and it could not fulfill the request. 

Ultimately, the airport accomplished the project with FAA and bond funds. 

On another roadway project through the center of the airfield, the airport 

worked with the Tennessee Department of Transportation to widen and 
Appendix IV

Memphis International Airport

Page 48 GAO-03-164 Aviation Infrastructure

lower a portion of an existing road passing under an existing taxiway, the 

original center runway, and two additional taxiways. The state 

transportation agency chose to be responsible for the design and 

construction of a new roadway to match the city’s current road plan. The 

airport notified the city that the taxiway and runway would be closed to air 

traffic because of airport reconstruction, and it offered the opportunity to 

accomplish the needed street improvements at the least cost. The airport 

funded and constructed two taxiway crossings over the existing road in the 

same general time period, and it contributed funds toward the cost of a 

replacement tunnel and a portion of the lowered and widened roadway 

needed to accommodate the eastern taxiway. According to airport officials, 

the airport was responsible for these improvements at a cost of $17 million. 

They said that the airport complied with state requests at a cost and time 

greater than was planned for by the airport because of the state 

transportation agency’s jurisdiction and power over factors that can slow 

down or stop an airport’s project.

Table 5: History of Memphis Runway Project

Source: U.S. General Accounting Office.

Date Event

June 1984 Airport initiates Master Plan for new runway.

March 1987 Airport initiated Environmental Assessment and noise study.

June 1989 Airport’s noise study report issued. Litigation began.

June 1991 First Majority in Interest Agreement between airport and airlines to 

build a new runway is reached.

December 1991 Airport completes Environmental Assessment.

December 1991 FAA begins EIS process.

April 1992 Airport initiates first of eight runway design projects.

May 1992 FAA publishes Draft EIS.

November 1992 FAA issues Supplemental Draft EIS to address EPA noise 

comments.

April 1993 FAA issues Final EIS.

May 1993 FAA issues ROD.

July 1996 Airlines’ disagreement about prorated funding for runway project 

resolved.

September 1997 Airport opens runway.

October 2000 Litigation ended.
Page 49 GAO-03-164 Aviation Infrastructure

Appendix V

Minneapolis-St. Paul International Airport ApendxiV

The Minneapolis-St. Paul International Airport (Minneapolis-St. Paul) 

ranked as North America’s tenth-busiest airport in terms of passenger 

traffic during 2001. The Metropolitan Airports Commission (Commission) 

broke ground in May 1999 for the new north-south runway. This runway, 

the airport’s fourth, is expected to add about 25 percent additional capacity. 

According to the Commission Chairman at the groundbreaking, the new 

runway is vital to the economic growth of Minnesota and the region.

The Commission owns and operates the Minneapolis-St. Paul International 

Airport and six reliever airports. The Commission reports directly to the 

Minnesota legislature and governor. Northwest Airlines, the major hub 

carrier serving Minneapolis, accounts for nearly 80 percent of annual 

operations. Several other airlines account for the remaining traffic. 

Northwest is headquartered in the neighboring community of Eagan, Minn.

The configuration is two parallel northwest-southeast runways, one 

crosswind runway, and the new north-south runway. In good weather, the 

airport operates with a capacity of 115 to 120 operations per hour. The 

runway was originally scheduled for completion in December 2003, but the 

terrorist events of September 11, 2001, forced the airport to delay 

completion until November 2004—an 11 month delay. Airport officials cited 

reduced cash flow as the primary reason for this delay. They also said that 

the new runway would accommodate future demand, increase runway 

capacity, relieve congestion, and reduce delays. Figure 7 shows the existing 

airport configuration, including the new runway.
Appendix V

Minneapolis-St. Paul International Airport

Page 50 GAO-03-164 Aviation Infrastructure

Figure 7: Airport Diagram—Minneapolis-St. Paul International Airport

We selected Minneapolis-St. Paul International Airport as a site-visit 

location because it is one of the nation’s busiest airports with an active 

runway project; its project was in the construction phase; it had detailed 

and comprehensive planning and environmental phases; and its Executive 

Director has been a prominent speaker regarding airport issues. 

We interviewed Commission officials who were the main sponsors of a new 

fourth runway at the airport. We also interviewed officials at FAA’s 

Minneapolis Airport District Office; Northwest Airlines, which had a 

majority of the air operations at the airport; Minnesota Department of 

Transportation Office of Aeronautics, which is responsible for promoting 

safety zones around the airport; and the Metropolitan Council, which had a 
Appendix V

Minneapolis-St. Paul International Airport

Page 51 GAO-03-164 Aviation Infrastructure

key role in the planning process. Additionally, we interviewed 

representatives of the cities of Eagan, Richfield, and Bloomington, which 

surround the airport and are impacted by the runway project. 

Current Status of the 

Runway Project

The Minneapolis-St. Paul International Airport is in the construction phase 

for its fourth runway (Runway 17/35). 

Stakeholders Agree 

That Comprehensive 

Mitigation Plans Are 

Essential but Difficult 

to Develop

According to both FAA District Office and airport officials, the Commission 

worked hard at building consensus throughout the project and entered into 

numerous mitigation agreements to resolve issues. The prevailing 

philosophy was to do whatever was necessary to make the project 

successful. Commission officials, communities, airlines, and other 

stakeholders worked together to achieve this. For example, when 

developing noise contour maps, the Commission chose to include an entire 

city block if the noise contour intersected any part of the block. If one 

residence received sound insulation measures because it lay within the Day 

Night Noise Level (DNL) 65 contour, every house on the block received 

identical remediation measures. According to Minneapolis–St. Paul airport 

officials, the effort represented good comprehensive community 

involvement. The Commission spent considerable resources trying to keep 

all stakeholders satisfied. According to airport officials, the Commission 

and FAA also tried to avoid having the project go into litigation, viewed as 

an unproductive use of time and resources and the worst scenario in the 

process. In the long run, the FAA District Office, the state Department of 

Transportation, and Commission officials agreed that consensus building, 

while taking longer than expected in the project’s early stages, saved time 

in the long run.

However, often what was good for one community was bad for another 

community. At least one community accused the Commission of buying 

communities off, neighborhood by neighborhood. For example, 

Minneapolis was “made happy” by eliminating the north parallel runway 

from consideration. A National Wildlife Refuge located near the airport was 

“made whole” through the payment of over $26 million;22 however, the 

22According to an airport official, the amount was determined by an independent 

professional appraiser and includes costs to relocate significant educational activities. 
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Minneapolis-St. Paul International Airport

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noise will continue over the refuge. According to FAA officials, this cost 

was required to mitigate the impact on refuge property protected under 49 

U.S.C. 303(c), formerly known as section 4(F) of the DOT Act. The 

opposition viewed the process as achieving “traveling” consensus—just 

moving the problem around. Opposition groups described the process as 

one seeking cooperation for appearances only—a “divide and conquer” 

approach. 

Stakeholders Believe 

That Mitigation 

Funding Should Be 

More Flexible to 

Include More 

Communities

Stakeholders impacted by the runway said that they would be more 

supportive of the project if the airport authority would increase the level of 

noise mitigation on the surrounding community. The FAA concluded, as 

indicated in its Minneapolis-St. Paul ROD, that federal-funds eligibility for 

future residential sound insulation measures is generally limited to the DNL 

65+ contour. However, it said that FAA might extend federal-funds 

eligibility for the residential insulation program to include the area out to 

the DNL 60 contour if there are applicable local standards. For the 

Minneapolis airport, FAA plans to evaluate this extension through a future 

Commission-initiated Federal Aviation Regulations Part 150 Noise 

Compatibility Plan. The Commission submitted an updated noise 

compatibility plan to FAA in November 2001 and withdrew it in May 2002, 

prior to an FAA decision. Mitigation efforts continue in the DNL 65+ 

contour area; time frames released to the public called for the extended 

(DNL 60-64) program to be completed in phases between 2005 and 2012. A 

major factor in Northwest Airlines’ objection to paying for the additional 

mitigation measures was that the future had changed significantly enough 

since September 11, 2001, to reevaluate these additional measures.23

A Nationwide Low 

Frequency Noise 

Policy Is Not in Place

The impact of low frequency noise on the surrounding community is an 

issue for the Minneapolis-St. Paul airport, which is close to neighborhoods, 

according to the Federal Interagency Committee on Aviation Noise

23MAC intends to update the noise contours to reflect a 2002 base year and the 2007 forecast, 

incorporating the 2007 fleet mix plans. As a result, noise contours could shrink because of 

quieter aircraft. MAC adopted a noise-mitigation plan for single-family homes in the DNL 

60–64 contours in April 2002. Implementation of this plan is contingent upon resubmission 

of the Part 150 Update and its FAA approval. 
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Minneapolis-St. Paul International Airport

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(FICAN).24 According to the City of Richfield official, the Commission 

received $10 million in FAA Airport Improvement Program funds for noise 

mitigation activities for the west side of the new runway (the City of 

Richfield lies west of the new runway), pending FAA’s review of the noise 

impacts of the project. The $10 million was earmarked in the 2001 

Department of Transportation Appropriations Act conference report.25

In December 1998, the City of Richfield and the Commission agreed to 

undertake a detailed study of existing and potential impacts of low 

frequency aircraft noise in communities around the airport. In order to 

develop a consistent low frequency noise policy, FAA turned to FICAN for 

input on the review of this study and technical aspects of the issue—

particularly for an assessment of the problem and metrics to evaluate it. 

Low frequency noise was discussed at the committee meeting held in June 

2001. Commission and Richfield experts attended. The Committee released 

its findings in August 2002 and basically said that additional data are 

needed to determine whether any relationship exists between low 

frequency noise and human annoyance.26 According to FAA officials, FAA is 

reluctant to fund low frequency noise mitigation until the alleged adverse 

impacts are conclusively validated and national standards established.

Some Communities 

Question Justification 

of State Zoning Laws

According to the Minnesota Department of Transportation, FAA, the 

Commission, and community officials, Minnesota has state safety zones 

that go beyond the federal Runway Protection Zone limits.27 Within these 

safety zones, certain types of development are prohibited. The 

establishment of safety zones involves issues of safety, land use, and 

encroachment that can impact not only the development of an airport 

24Low frequency noise is aircraft-generated noise that is likely to induce audible rattles in 

residences, most likely below 100 hertz.

25House Conference Report 106-940, October 5, 2000.

26Federal Interagency Committee on Aviation Noise on the Findings of the Minneapolis-St. 

Paul International Airport Low Frequency Expert Panel, August 2002.

27FAA requirements cover both the primary runway surface and runway protection zone 

limits. The length and width of the zones depend upon the aircraft operating on the 

particular runway and the visibility minimums. Minnesota state requirements include 1) 

Zone A—begins 200 feet from the runway end and extends for a distance two-thirds the 

runway length; 2) Zone B—begins at the end of Zone A and extends for a distance of onethird the runway length; and 3) Zone C—the required horizontal clearance. 
Appendix V

Minneapolis-St. Paul International Airport

Page 54 GAO-03-164 Aviation Infrastructure

runway but also the development of land surrounding the airport. Some 

communities around the airport question whether the safety zones are 

beneficial for them. Although not all stakeholders oppose Minnesota’s 

strict zoning, The Commission authorized and funded a consultant study to 

research the need for the state safety zones as well as the approaches that 

the other 49 states have taken. The consultant’s April 2002 report, sent to 

the Joint Zoning Board, found no justification for the strict zoning.

The application of a grandfather clause in the use of state-created safety 

zones presents an additional challenge to the communities surrounding the 

airport. Under the terms of the grandfather clause, if a residential area 

existed in the state zones in 1978 or earlier, it was allowed to remain in 

place and not be removed by the airport. However, business expansion in 

the general area around the airport is subjected to state safety zone 

restrictions. Communities are unhappy because it makes no sense to the 

community leaders to leave residences closer to the runway itself but not 

permit businesses to expand in an area further away from the airport. 

Businesses feel that, although their property was not acquired, the impact 

is the same, since expansion is forbidden.

Table 6: History of Minneapolis-St. Paul International Airport Runway Project

Date Event

October 1988 Metropolitan Airports Commission (Commission) and Metropolitan 

Council issue Airport Adequacy Study.

May 1989 Minnesota legislature establishes Dual Track Airport Planning 

Process.

April 1992 Scoping meetings held. FAA, in cooperation with Commission, 

publishes Notice of Intent to prepare EIS. FAA and Commission 

issue First Phase Scoping Report.

March 1993 FAA and MAC publish responses to First Phase Scoping Report.

December 1993 Airport Capacity Team completes Capacity Enhancement Plan. 

December 1994 State Department of Transportation completes Terminal Airspace 

Study for relocated airport.

May 1995 FAA issues Second Phase Scoping report, holds public meetings.

July 1995 FAA issues EIS Scoping Decision.

December 1995 FAA and Commission publish Draft EIS.

March 1996 Commission and Metropolitan Council issue Dual Track Planning 

Study.

April 1996 Minnesota legislature decides to expand existing airport.

August 1996 FAA issues Airport Capacity Enhancement Terminal Airspace Study.
Appendix V

Minneapolis-St. Paul International Airport

Page 55 GAO-03-164 Aviation Infrastructure

Source: U.S. General Accounting Office.

Date Event

May 1998 FAA issues Final EIS.

September 1998 FAA issues ROD.

December 1998 Richfield individual files suit against Commission and state 

Environmental Quality Board.

May 1999 Commission commences runway construction.

June 2000 State Court of Appeals upholds Summary judgment regarding 

Richfield individual’s lawsuit.

October 2000 $10 million earmarked for noise mitigation activities for the west side 

of the new runway.

June 2001 Federal Interagency Committee on Aviation Noise begins discussing 

low frequency noise standards.

November 2001 Commission submits Part 150 Noise Compatibility Plan.

March 2002 FAA clarifies airport zoning standards.

April 2002 Study authorized by Commission results in consultant report that 

finds no need for state safety zones.

May 2002 Commission withdraws Part 150 Noise Compatibility Plan.

November 2004 Planned runway completion.

(Continued From Previous Page)
Page 56 GAO-03-164 Aviation Infrastructure

Appendix VI

Seattle-Tacoma International Airport ApendxiVI

The Seattle-Tacoma International Airport (Sea-Tac) is the primary air 

transportation hub of Washington State and the northwestern United 

States. It is the 17th-busiest passenger airport, the 20th-busiest cargo 

airport, and among the 31 busiest hub airports in the United States. Located 

12 miles south of downtown Seattle and 20 miles north of Tacoma, it is the 

primary provider of international and domestic air carrier service in the 

region surrounding the Seattle/Tacoma area. Its primary service market is 

the Puget Sound region, composed of four counties and approximately 3.5 

million people. About three-fourths of the air travelers using Sea-Tac 

Airport are origin and destination passengers who begin or end their trip at 

the airport. The remaining flights are connecting flights. The airport is a 

significant employer in the region, with 20,000 airport employees. 

Sea-Tac currently has two parallel runways. Our primary focus was on a 

runway development project for a new third parallel runway first 

considered in Sea-Tac’s plans in 1989, and which the Port of Seattle 

approved in 1992. The project has proceeded through several steps of the 

environmental review process, and it is currently scheduled for completion 

in 2006. Sea-Tac’s sole purpose for adding this 8,500 foot parallel runway, 

which would be separated by 2,500 feet from the furthest parallel runway, 

is to address constraints attributable to Seattle’s poor weather, and 

although the new runway would increase capacity, airport officials do not 

consider the runway project to be a capacity-enhancing project. During 

periods of reduced weather conditions, which occur about 44 percent of 

the time, Sea-Tac can use only one of the two existing runways for arrivals 

because of the narrow spacing between them, thereby causing delays. The 

number of flights that can be accommodated drops from about 60 arrivals 

per hour in good weather to 48 or fewer in poor weather. The new runway, 

which is planned to have much greater separation from other runways, 

would allow independent landings on two runways at the same time, which 

reduces delays. Figure 8 shows the existing Sea-Tac airport configuration, 

including the proposed runway.
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Seattle-Tacoma International Airport

Page 57 GAO-03-164 Aviation Infrastructure

Figure 7: Airport Diagram—Sea-Tac International Airport 

We selected Sea-Tac Airport for study because it was an airport with a 

significant amount of both passenger and cargo operations and it had 
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Seattle-Tacoma International Airport

Page 58 GAO-03-164 Aviation Infrastructure

experienced significant planning and environmental issues during the 

development of its runway project. Additionally, in constructing the 

planned runway, Sea-Tac is expanding the plateau where the airport is 

located—undertaking one of the most significant landfill and embankment 

projects in the United States (about 17 million cubic yards). According to 

Sea-Tac officials, this earth-moving project is producing several 

accompanying environmental considerations. 

We interviewed officials from Sea-Tac, who were the sponsors of the 

runway project. We also interviewed officials at the FAA Seattle Airports 

District Office; Alaska Airlines; Puget Sound Regional Council; Airport 

Community Coalition; Regional Commission on Airport Affairs; 

Washington State Department of Transportation Aviation Division; 

Washington State Department of Ecology; the U.S. Army Corps of 

Engineers; and the U.S. Environmental Protection Agency. 

Status of the Runway 

Project

As indicated above, the runway project for the new third parallel runway at 

Sea-Tac has completed environmental review and has received state and 

Corps wetland fill permits. However, according to Sea-Tac officials, both 

permits are currently in litigation and under appeal. Sea-Tac has begun 

constructing the foundation that will be required to support the third 

runway.

Simplifying Purpose 

and Need May Help 

Reduce the Circuitous 

Nature of the Review 

Process

Sea-Tac officials stated that continual review of the purpose of and need for 

their runway project, as well as alternatives to it, presented a significant 

challenge to moving forward in the process. They stated that reducing the 

number of reviews could reduce the amount of potential delay in the 

process. The purpose and need was established and reviewed by the 

airport, FAA, consultants, and the local Metropolitan Planning Organization 

during the planning and environmental process; it was then re-reviewed by 

the Corps of Engineers (Corps) during the permitting process under 

Section 404 of the Clean Water Act.28 FAA officials questioned the 

usefulness of the Corps’ review of the project’s purpose and need, stating 

that the extra review created frustrations for other stakeholders and added 

time to the process when the purpose and need had already been 

28According to Sea-Tac and FAA, the Corps was involved as a cooperating agency during 

Master Plan updates and participated in an early EIS draft. 
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Seattle-Tacoma International Airport

Page 59 GAO-03-164 Aviation Infrastructure

established. Additionally, FAA officials said that aviation expertise is 

needed to analyze the alternatives, and the Corps has no such expertise. 

According to Corps officials, the Corps is required to ensure that 

alternatives have been adequately considered.29 Corps officials said that 

their review of the alternatives was justified because it had been a 

considerable time since the EIS had been developed, and it wanted to 

determine if the events of September 11, 2001, had changed the relative 

benefits of the alternatives. Officials from the Puget Sound Regional 

Council, the metropolitan planning organization in the Seattle area, 

suggested that the Corps could have been included more in the early 

consideration of alternatives, but acknowledged that the Corps’ limited 

resources made early participation difficult. FAA officials, however, believe 

that the Corps did participate in the development of alternatives in its role 

as a cooperating agency during the development of the EIS. 

Sea-Tac Airport, while not specifically citing purpose and need, said that a 

clear federal policy of encouraging runway development and moving 

projects through the regulatory process would help ensure that adequate 

airport capacity is in place to reduce growing air traffic delays. It suggested 

that such a commitment could be similar to the one the federal government 

took in developing the interstate highway system and national railroads. A 

task force could be created to identify runway projects that are critical to 

the national air transportation system. Such an approach could help 

expedite implementation of decisions already made at the local level. 

Additionally, they suggested that Congress could adopt a policy of directing 

all organizations to achieve a balance between environmental, economic, 

and social goals, coupled with statutory deadlines for decisionmaking. 

They contend that such an approach, now used by other countries, would 

help agencies make difficult decisions and get needed runways built.

A Compatible Land Use 

Program May Help to 

Reduce Opposition 

A Washington State Department of Transportation official stated that 

minimizing controversy over the uses of land needed for expanding runway 

capacity could be important in avoiding lengthy project delays. The 

department developed an Airport Land Use Compatibility Program, 

implementing a 1996 amendment of the Washington State Growth 

Management Act—the state’s land use planning law. The law requires cities 

and counties to identify, site, and protect essential public facilities 

2933 CFR part 323.
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Seattle-Tacoma International Airport

Page 60 GAO-03-164 Aviation Infrastructure

(including airports) from incompatible land use, such as encroaching 

development. In other words, when developing local land use plans, cities 

and counties must ensure that their plans do not adversely affect these 

facilities.

As part of the land use compatibility program, certain state transportation 

officials provide consultations, including mediation, between airport 

sponsors and community representatives (often municipal or county 

planning staff) to balance the state’s dual interest of promoting aviation and 

ensuring the health, safety, and welfare of its residents. The approach to 

facilitating airports’ future expansion includes several steps, including the 

development of planning-based solutions and the integration of those 

solutions into a legally enforceable document such as a comprehensive 

development plan (rather than the Airport Master Plan, which is not 

binding on a land use authority).

New Mitigation 

Approaches and 

Increased Community 

Interaction Could Help 

Foster Community 

Support

In Seattle, the Airport Communities Coalition, representing several 

communities near Sea-Tac Airport but not the city of SeaTac, said that 

expanding the scope of mitigation beyond direct environmental 

applications would go far in building community support for runway 

projects. They said that the airport’s use of heavy trucks over local roads to 

haul dirt for its landfill project for the runway caused significant 

deterioration of the community’s roads, for which it has not been 

reimbursed.30 Similarly, when the airport acquires residence and business 

locations in order to mitigate noise or wetland impacts, these buyouts 

deplete the tax base in the community where the properties are based, 

resulting in negative economic impacts for which the community is not 

reimbursed. Therefore, the community has no reason to support the 

runway project. However, they said that the community would have 

reasons to support the project if some funding were provided to mitigate 

the economic damage to the community. An organization official said that 

the Department of Defense reimburses communities for economic loss 

when it acquires property within the community to build military bases. 

Officials at the Regional Commission on Airport Affairs, a citizens’ group in 

the greater Seattle metropolitan area, stated that that the airport could do 

more to mitigate economic impacts. However, they also said that 

30An airport official stated that most of the impacts have been to roads in the city of SeaTac, 

and that mitigation costs pertaining to the impacts have been addressed. 
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Seattle-Tacoma International Airport

Page 61 GAO-03-164 Aviation Infrastructure

expanding the scope of mitigation would not diminish their opposition to 

the runway project. 

According to the Airport Communities Coalition, communities seek to 

contribute meaningful input into the airport expansion process; however, 

when they are not allowed to do so, they are forced to file lawsuits against 

airports and other stakeholders over decisions that have been made. 

Officials at both the Coalition and the Regional Commission believed that 

the planning process used by the airport and the Puget Sound Regional 

Council needed to include meaningful input from the communities near the 

airport. An official at the Regional Commission stated that there should be 

a citizen’s advisory committee with genuine input into the airport’s 

expansion projects early in the planning process. The official suggested 

that the federal government should provide the incentive for the 

establishment of such a committee by providing federal funds only when 

such a committee was established. In the official’s view, the success of such 

an approach would be contingent on the airport’s taking the committee’s 

views into account and substantively addressing them. These community 

organizations have filed several lawsuits against the airport, the Puget 

Sound Regional Council, and FAA, based on objections to their approach 

for addressing environmental issues. An Airport Communities Coalition 

official said that the community filed lawsuits in part, to get the airport to 

listen to the needs of the community and to negotiate solutions. The official 

noted that communities near other airports had successfully used such an 

approach. Sea-Tac and FAA officials stated that there was extensive 

community involvement beyond that required by law.

An official at the Airport Communities Coalition said that the public 

hearing process on environmental matters gives stakeholders the ability to 

voice concerns but, because of the limited time allocated to each person, 

does not give those convening the hearing an ability to understand the 

concerns or allow citizens to have an impact on the project. The thrust of 

FAA’s 2001 best practices guide seems to agree with the coalition official; 

the guide states that periodic informal workshops during the planning and 

environmental processes tend to provide better forums for community 

consultation than do formal public hearings. Understandable information 

on the project and its environmental impacts should be made available at 

the workshop, and knowledgeable stakeholders such as the airport, FAA, 

and EIS consultants should be present to answer questions. In the guide, 

FAA notes that strong local opposition tends to slow down the 

environmental process and that a citizens’ advisory committee in some 

locations has been useful in improving working relationships and 
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Seattle-Tacoma International Airport

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communication between the airport and the community. FAA said that such 

a committee may be established on either a permanent basis or for the 

duration of a specific project’s planning and environmental review. FAA 

added that factors that help build local consensus and address opposition 

include, among others: 1) open and frank dialogue on the aviation need and 

the airport proprietor’s initial planning, including possible alternatives; 2) 

an effective forum for constructive exchanges on expected benefits, 

impacts, alternatives, and mitigation prospects; and 3) serious 

consideration of community concerns and views, including project 

adjustments that have merit and are possible, as well as responses to 

community proposals that cannot be accommodated, and the reasons why. 

A SeaTac official emphasized that the airport did include public outreach 

beyond that required by environmental regulations. For example, such 

efforts included public information sessions and community open houses, 

among others. 

Extensive Regulatory 

and Legal 

Requirements Posed 

Resource Challenges 

Stakeholders may have limited staff and resources to address the extensive 

regulatory and legal requirements of the process, leading to delays. For 

example, officials from FAA’s Seattle office said that when an endangered 

species of fish was identified at Sea-Tac Airport, 20 months elapsed before 

officials from the federal Fish and Wildlife Service and the state 

Department of Marine Fisheries approved actions to address the conditions 

of endangered species. Both agencies had limited staff to review and 

analyze the discovery and the approach for addressing it. FAA officials said 

that they understood that the Corps had only six staff members to review 

about 1,000 water quality permits, and according to state aviation 

department officials, the Corps had a significant backlog in processing 

permit applications.

Additionally, an official from the state Department of Ecology said that the 

Sea-Tac runway project had been a significant drain on resources at the 

agency. The agency has had difficulty finding sufficient resources to 

complete environmental reviews and must redirect personnel from other 

functions. The official said that, because of the shortage of state funds, 

applicants wanting reviews to proceed quickly will have to bear the burden 

of funding water quality reviews. Sea-Tac officials noted that additional 

staff resources are needed in regulatory agencies in order to process 

environmental permits in a timely manner and, aside from adding federal 

funding, funding could be provided by project proponents. The airport 

acknowledged that agencies were reluctant to accept funding because of a 

concern with potential conflicts of interest. The airport suggested that 
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Seattle-Tacoma International Airport

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Congress could make guidelines under which the agencies could remain 

impartial. The purpose of allowing such funding would not be to curry 

favor but to work efficiently with the federal government to get runways 

built. They asserted that these staff would work exclusively under FAA’s 

supervision and would be under no obligation to the airport. They 

contended that this proposal would provide a mechanism for airports to 

bear the financial cost of accelerated project reviews.

Site-Specific Issues 

Involve Safety and 

Environmental 

Challenges

A major site-specific challenge involves the construction of a large plateau 

to enable the airport to construct the new runway. According to Sea-Tac 

officials, in order to bring the new runway site up to the elevation of its 

other two runways, a 17–million cubic yard landfill and embankment is 

being built. The embankment will require three retaining walls to reduce 

impacts on a nearby creek and wetlands and to accommodate safety areas 

at the ends of the runway. The walls are mechanically stabilized, using 

concrete panels and layers of galvanized reinforced strips that bind to and 

reinforce the embankment material in a coherent way. According to the 

Port, this type of wall is highly earthquake resistant, and it has been used 

successfully elsewhere in the United States. In April 2002, Sea-Tac Airport 

officials said that the communities surrounding the airport were concerned 

that the wall will collapse or will be unable to withstand an earthquake. 

However, according to airport officials, the airport used the services of 

consulting engineers, geotechnical consultants, and earthquake engineers 

from companies and the University of Washington, and sought advice from 

a technical review board in developing the wall design to ensure that it is 

safe. The airport has also held public hearings in an attempt to enlighten 

the public about the durability and safety of the wall project.
Appendix VI

Seattle-Tacoma International Airport

Page 64 GAO-03-164 Aviation Infrastructure

Table 7: History of Sea-Tac Runway Project

Source: U.S. General Accounting Office.

Date Event

June 1992 Puget Sound Regional Council completes 2.5 year study of air 

capacity needs that included possible third runway at SeaTac.

April 1993 Metropolitan Planning Organization approves Regional Airport 

System Plan.

November 1993 Initial design contracts awarded.

October 1994 Metropolitan Planning Organization concludes no sites suitable for 

new airport.

February 1996 Final EIS completed.

July 1996 Metropolitan Planning Organization amends metropolitan 

transportation plan to include new runway.

August 1996 Airport authority adopts revised Master Plan that includes new 

runway.

December 1996 Supplemental EIS begun.

May 1997 Final Supplemental EIS issued.

July 1997 ROD issued.

August 1997 ROD challenged.

December 1997 Airport submits permit applications to state and Corps of Engineers.

March 1998 Construction begins on the first phase of the landfill project.

September 1998 New wetlands discovered in project area.

January 1999 Circuit court affirms ROD.

September 1999 Airport submits revised permit applications.

November 1999 Public comment hearings held on permit applications.

September 2000 Airport withdraws permit application before expiration deadline to 

address remaining issues and provide agency additional time to 

process application.

October 2000 Airport resubmits permit applications.

January 2001 Public comment hearings held on permit applications.

August 2001 State issues water quality certification.

December 2001 State water quality certification suspended pending community 

appeal to Pollution Control Hearings Board.

July 2002 FAA approves Part 150 noise study.

August 2002 Pollution Control Hearings Board upholds water quality certification, 

subject to additional conditions.

September 2002 Airport appeals Pollution Control Hearings Board’s conditional 

approval of water quality certification.

December 2002 Corps issues wetland permits; permits challenged. 

2006 Planned completion of runway construction.
Page 65 GAO-03-164 Aviation Infrastructure

Appendix VII

Lester B. Pearson International Airport, 

Toronto, Canada ApendxiVI

The Lester B. Pearson International Airport (Pearson) is the primary 

commercial airport serving the Toronto area. The Greater Toronto Airports 

Authority manages the day-to-day operations of the Pearson airport, as well 

as managing its capital infrastructure projects. The Greater Toronto 

Airports Authority was established in March 1993 as a community 

initiative, was reconstituted in accordance with Canadian Airport Authority 

guidelines, and was recognized by the Minister of Transport in November 

1994 as the airport authority responsible for Pearson airport. The airport 

authority is a private, not-for-profit corporation. Its 15-member Board of 

Directors is composed of nominees from the City of Toronto, the Province 

of Ontario, the Government of Canada, and four regional municipalities. 

The airport authority assumed control of the management, operation, and 

maintenance of Pearson on December 2, 1996.

Pearson Airport is the busiest airport in Canada and the 16th-busiest in 

North America, having served 28 million passengers in 2001. With regard to 

international passengers, Pearson was ranked as the 2nd-busiest in North 

America and 17th-busiest in the world in 2001. To handle the projected 

demand for air travel through the airport, the airport authority developed a 

$4.4 billion (Canadian) development plan for the improvement of the 

airport’s infrastructure—the Airport Development Program (ADP), which 

includes new runway projects, among other infrastructure projects. Figure 

9 shows the existing Pearson airport configuration.
Appendix VII

Lester B. Pearson International Airport, 

Toronto, Canada

Page 66 GAO-03-164 Aviation Infrastructure

Figure 8: Airport Diagram—Lester B. Pearson International Airport 

We chose Pearson Airport as a site visit to learn about the runway 

development process used in Canada, and because the airport had three 

runway projects that met the criteria we used to select airports in the 

United States—one runway completed in 1997, one completed in October 

2002, and one planned for future implementation.31 The three additional 

runways were approved for development as warranted by demand in 1993 

by Transport Canada after a lengthy Environmental Assessment Review 

process in 1990–1992. 

31When we visited the airport, the runway project completed in October 2002 was still under 

construction.
Appendix VII

Lester B. Pearson International Airport, 

Toronto, Canada

Page 67 GAO-03-164 Aviation Infrastructure

Status of Runway 

Projects

As noted above, Pearson Airport completed the construction of a new 

runway in 1997, completed the construction of a second new runway in 

2002, and has a third runway in the planning stages, to be constructed when 

capacity demands warrant another runway.

Airport Development 

Process in Canada 

Differs from U.S. 

Process

The airport development process in Canada differs from the U.S. process in 

several distinct ways. Pearson Airport was one of the first airports in 

Canada to attempt to build additional runways since the airports were first 

constructed to serve the Canadian military during World War II. As a result, 

there was no established runway development process in place—Transport 

Canada officials had to learn about the process as they progressed through 

it. In the broadest sense, there are three pieces of legislation that affect the 

process—the Aeronautics Act, the Fisheries Act, and the Environmental 

Act.

The environmental phase differs greatly from that employed in the United 

States. Prior to the development of the EIS, the airport authority begins the 

process with scoping. The scoping process is a public process. According 

to airport officials, every project goes through environmental screening 

(equivalent to an Environmental Assessment) as a part of the planning 

process. When the Pearson project went through the screening process, the 

airport authority was responsible for conducting environmental screening. 

However, current legislation requires that the screening results be available 

to the public.

The Minister of Transport and the Minister of the Environment 

cooperatively choose an Environmental Review Panel consisting of 

government officials and knowledgeable local residents (that is, 

academics.) The panel begins by developing a list of issues that it believes 

the EIS must identify. The issues and, therefore, the requirements of the 

EIS will vary from airport to airport. Airport officials referred to the 

process as “organic”—changing from airport to airport, project to project. 

The airport authority is responsible for preparing the EIS documents, and it 

submits them to the panel for review. The panel reviews the environmental 

impact documents and convenes hearings to hear testimony in order to 

formulate its opinions regarding the environmental impacts of the project 

and accompanying mitigation measures. The hearings are judicial in nature, 

and attendees have never resorted to shouting or histrionics. According to 

airport officials, the hearings were well balanced between opponents and 

proponents of the projects. With respect to the EIS, the focus of the 
Appendix VII

Lester B. Pearson International Airport, 

Toronto, Canada

Page 68 GAO-03-164 Aviation Infrastructure

environmental hearings was medium-term capacity enhancement 

projects—the three runways at Pearson. The issues that the panel 

considered depended greatly on their perception of the issues raised during 

the hearings. The members of the panel did not work on the EIS full-time, 

and did not have the requisite expertise to conduct their reviews—the 

panel either hires knowledgeable consultants or develops the necessary 

knowledge. This process takes a long time.

Once the EIS is completed, the panel reviews the document, develops a 

series of recommendations, and submits them to the Minister of 

Environment. The Minister of Environment then makes a final 

determination and submits recommendations to the Minister of Transport. 

The Minister of Transport has sole discretion as to whether to implement 

the recommendations of the Minister of Environment. The Minister of 

Transport makes the final determination, and it is incumbent upon the 

airport authority to respond to the final recommendations.

The design and construction process in Canada does not differ 

substantially from that in the United States. The airport must prepare 

preliminary engineering and final design, and then construct the runway 

infrastructure. Finally, in summary, airport officials believed that the 

process went very well and did not believe that they would proceed 

dramatically differently if they were to go through the process again. 

However, both airport and Transport Canada officials noted that the 

recently passed Canadian Environmental Assessment Act will result in 

changes to the existing process.

Canadian Airports 

Face Many of the Same 

Challenges as U.S. 

Airports

Airports in Canada seeking to add capacity by constructing new runways 

face many of the same challenges that airports in the United States face, 

including environmental issues, wetlands mitigation issues, and the 

impacts of noise on the surrounding communities. These impacts generally 

lead to some community opposition to the proposed project. Canadian 

airports are also subject to site-specific constraints attributable primarily 

to the northern climate.

Because of the northern climate, airport operations in Toronto require 

extensive ice removal in the winter months, resulting in the use of a large 

quantity of Glycol that can cause an environmental impact on surrounding 

wetlands. The airport straddles both the Etobicoke and Mimico Creek 

watersheds, covering 1,640 hectares of land. Most of the airport, including 

runways, cargo areas, Terminal Three, Terminal One aprons, and infield 
Appendix VII

Lester B. Pearson International Airport, 

Toronto, Canada

Page 69 GAO-03-164 Aviation Infrastructure

areas, drains to Etobicoke Creek. According to the Toronto and Region 

Conservation Authority, although runoff contamination from these sources 

is a concern, significant progress has recently been made to mitigate the 

airport's impact on water quality through the expanded use of wastewater 

and storm water recovery and containment systems. Airport officials cited 

their wastewater treatment facility as contributing greatly to allaying the 

concerns of residents over ground and surface water contamination, and 

they stated that the airport has never exceeded contaminant limits.

The Council of Concerned Residents, a coalition of three residents’ 

associations near the airport, opposed the expansion of the airport 

fundamentally on the premise that the projects would increase the noise 

impacts on their communities. In 1993, the group filed a lawsuit against the 

airport claiming that the proposed project was illegal for three reasons: 1) a 

1973 order precluded the Toronto airport from expanding beyond its 

borders; 2) a federally approved airport master plan and the local 

municipality’s land use plan stipulated that they were based on the 

assumption that the airport would have no more than three runways; and 3) 

the Environmental Review Panel stated that the project should not be 

pursued because the adverse social impacts of the project outweighed the 

capacity gains at the airport. According to Transport Canada officials, 

Canada’s noise mitigation standards are very similar to FAA’s Federal 

Aviation Regulations Part 150 programs in the United States. According to 

airport officials, neither Transport Canada nor the airport authorities are 

required to acquire noise-sensitive properties surrounding the airport. 

According to airport authority officials, airports in Canada face a shortened 

construction season because of the sometimes severe winter weather 

associated with the northern climate. Therefore, airports seeking to 

construct runways must take the climate into account when entering into 

the construction phase of the runway development process. Airports must 

schedule construction tasks such that weather-dependent tasks such as 

concrete construction are scheduled during the warmer months, and 

reserve climate-independent tasks for the winter months.
Page 70 GAO-03-164 Aviation Infrastructure

Appendix VIII

Survey of Airports ApendxiVI

The following section provides a copy of the survey that we sent to airports 

that have built a runway between 1991 and 2000 or planned to do so by 

2010. Where appropriate, we have summarized their responses to each 

question. In instances where summarized answers are not possible—such 

as dates—we have listed the number of airports that answered the 

question.

In total, we sent 39 surveys to 34 airports—Dallas-Fort Worth, Detroit, 

Indianapolis, Louisville, and Washington Dulles received more than one 

survey, because each had more than one runway that met our criteria. We 

excluded five surveys because the airports reported that their projects did 

not meet our selection criteria. For our statistical analysis, we excluded 

responses from five airports—Kailua-Kona, Little Rock, Reno, Sacramento, 

and one of the two surveys sent to Washington Dulles—because their 

responses indicated that their projects did not meet our criteria. The 

primary reason why their responses were dropped from our statistical 

analysis was that they planned only runway extensions or no new runways 

during our time frame. We did, however, rely on their responses during the 

remainder of our review. In total, we received 32 out of a potential 34 

responses from 30 airports—a response rate of 94 percent. Table 8 lists the 

airports we surveyed.
Appendix VIII

Survey of Airports

Page 71 GAO-03-164 Aviation Infrastructure

Table 8: Airports Surveyed

Source: U.S. General Accounting Office.

1. Atlanta Hartsfield

2. Baltimore

3. Boston Logan

4. Charlotte

5. Cincinnati

6. Colorado Springs

7. Dallas-Fort Worth (2)

8. Denver

9. Detroit Wayne County (2)

10. Grand Rapids

11. Houston

12. Indianapolis (2)

13. Kansas City

14. Las Vegas

15. Los Angeles

16. Louisville (2)

17. Madison

18. Memphis Shelby County

19. Miami

20. Minneapolis

21. Nashville

22. Orlando

23. Philadelphia

24. Phoenix

25. Salt Lake City

26. San Francisco

27. Seattle

28. St. Louis Lambert

29. Tampa

30. Washington-Dulles
Page 72 GAO-03-164 Aviation Infrastructure

Appendix IX

Survey of Airports with Recent or Planned 

Runway Projects ApendxiIX

1

United States General Accounting Office

Survey of Airports With Recent or

Planned Runway Projects ___ ___ ___

Introduction Survey ID

The U.S. General Accounting Office (GAO) is an agency of the legislative branch that reviews federal programs

for the U.S. Congress. We have been asked by the Chairman and Ranking Member of the Subcommittee on

Aviation, House Committee on Transportation and Infrastructure, to review what long-term improvements can

be made to enhance capacity in the National Airport System, particularly as it relates to building runways.

As part of our study, we are asking a select group of 34 airports for information on their experiences with

building runways and how the process could be improved. Your airport was selected because you built a

runway between 1991 and 2000 or plan to build a runway before 2010. If you have more than one runway that

meets these criteria, you have received one survey for each runway. Your responses will help us better

understand the various phases of runway construction and the challenges you had or foresee in the future. We

will present the results of this survey in our report.

We have made every effort to minimize the amount of information we are requesting by using other data sources

when available. Your participation is important and will enable us to report to the Congress on what works well

and what can be improved to expedite the building of runways. Please have appropriate staff respond to these

questions including consultants that may have assisted in this project. Please return your completed survey,

within the next 15 working days or by January 11, 2002, in the enclosed pre-addressed, postage-paid envelope,

or fax your response to David Lehrer at (312) 220-7726. In the event that the envelope is misplaced, the return

address is:

Mr. David Lehrer

U.S. General Accounting Office

200 W. Adams Street, Suite 700

Chicago, IL 60606-5219

EMAIL: lehrerd@gao.gov

Your responses to this survey should pertain to the airport and runway stated below, unless the questions ask

you to do otherwise. If you have any questions, please call either David Lehrer (312) 220-7667 or Gary Lawson

at (202) 512-3649.

Thank you very much for taking time to complete the survey.

1. Airport Name: ______________________________________

2. Runway of interest is: ____________________ ___________

3. Name and phone number of person(s) completing this survey:

a. Name: ______________________________ Telephone: (_____) _____ - ____________

b. Name: ______________________________ Telephone: (_____) _____ - ____________

4. Name of a person we may call if we have questions:

a. Name: ___________________________________ Telephone: (_____) _____ - ____________

b. Best times of day to call: ________________________________________________________
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Runway Projects

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2

EXPERIENCES WITH PLANNING AND BUILDING RUNWAYS

5. Please provide the start and completion dates for each of the following phases of your runway project and

describe the event or task related to each date. (Note: The time frames associated with each of the phases

listed below can overlap.)

Phase Date Date

started completed

a. Planning _ [a] ___ _______ ______ _ [a] ___ _______ ______

N=32 (month/year) (month/year)

_Begin Master Plan______ _Complete Master Plan_ _

(event/task) (event/task)

b. Environmental process _ [a] ___ _______ ______ _ [a] ___ _______ ______

N=31 (month/year) (month/year)

_Begin EIS_______ ______ _Record of Decision_ ____

(event/task) (event/task)

c. Litigation _ [a] ___ _______ ______ _ [a] ___ _______ ______

N=16 (month/year) (month/year)

_ First Lawsuit Begun_ __ _ Last Lawsuit Settled ____

(event/task) (event/task)

d. Design and construction _ [a] ___ _______ ______ _ [a] ___ _______ ______

N=27 (month/year) (month/year)

_Begin Design____ _ _____ _Commission Runway______

(event/task) (event/task)

[a] Due to the differences in reporting, summarized responses are not possible. Event/task listed is the most

common response provided for each phase.

If necessary, provide clarifying information for your response:

N=18
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3

6. For each of the tasks listed below, please indicate to what extent it took more or less time than expected

(i.e., as compared to your timeline and schedule at the beginning of the project). Please indicate ‘not

applicable’ for those tasks that have not yet taken place.

A. Planning

N=32

Much longer

than expected

(25% longer

 or greater)

Longer than

expected

(up to

25% longer)

Time

expected

Less than

expected

(up to

25% less)

Much less than

expected

(25% less

 or greater)

Not

applicable

Preparing future forecast 9% 25% 59% 0% 0% 6%

Demand/capacity analysis 9% 16% 66% 3% 0% 6%

Alternatives analysis 16% 16% 56% 0% 0% 13%

Justification of future development 19% 22% 50% 0% 3% 6%

Development of Airport Layout Plan 3% 19% 69% 3% 0% 6%

Confirmation of financial feasibility 6% 13% 63% 3% 0% 16%

Other (Please specify) 22% 0% 0% 0% 0% 78%

Other (Please specify) 9% 0% 0% 0% 0% 91%

B. Environmental process

N=32

Much longer

than expected

(25% longer

 or greater)

Longer than

expected

(up to

25% longer)

Time

expected

Less than

expected

(up to

25% less)

Much less than

expected

(25% less

 or greater)

Not

applicable

National Environmental Policy Act

(NEPA) requirements

22% 19% 44% 0% 0% 16%

Environmental Assessment 6% 0% 38% 0% 0% 56%

Finding of No Significant

Impact--FONSI

3% 0% 16% 0% 0% 81%

Noise study 9% 9% 50% 0% 0% 31%

Noise compatibility program

--Part 150

6% 9% 28% 0% 0% 56%

Noise and access restrictions

--Part 161

0% 0% 3% 0% 0% 97%

Draft Environmental Impact

Statement—EIS

22% 19% 28% 0% 0% 31%

Public comment on draft EIS 13% 13% 41% 0% 0% 34%

General conformity 9% 16% 34% 0% 0% 41%

Environmental Justice 9% 6% 19% 0% 0% 66%

Governor’s certificate issuance 6% 9% 38% 6% 0% 41%

Scope definition 6% 9% 50% 0% 0% 34%

Final EIS 25% 19% 22% 0% 0% 34%

Record of decision 16% 9% 38% 3% 0% 34%

Other federal requirements 16% 6% 31% 0% 0% 47%

State and local requirements 19% 13% 25% 0% 0% 44%

Other (Please specify) 19% 6% 0% 0% 0% 75%

Other (Please specify) 3% 0% 3% 0% 0% 94%

Other (Please specify) 3% 3% 0% 0% 0% 94%

Other (Please specify) 3% 0% 0% 0% 0% 97%

Other (Please specify) 0% 0% 0% 0% 0% 100%
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4

Question 6 (con’t.)

C. Litigation

N=32

Much longer

than expected

(25% longer

 or greater)

Longer than

expected

(up to

25% longer)

Time

expected

Less than

expected

(up to

25% less)

Much less than

expected

(25% less

 or greater)

Not

applicable

Noise 6% 0% 3% 0% 0% 91%

NEPA litigation 3% 0% 6% 3% 0% 88%

Air quality 3% 0% 6% 0% 0% 91%

Land acquisition 6% 9% 22% 0% 0% 63%

General conformity 3% 0% 3% 0% 0% 94%

Environmental justice 0% 0% 0% 0% 0% 100%

Wetlands 3% 9% 0% 0% 0% 88%

Endangered species 0% 0% 6% 0% 0% 94%

Historical site 0% 3% 6% 0% 0% 91%

State legislation 6% 0% 3% 0% 0% 91%

Other (Please specify.) 6% 3% 3% 0% 0% 88%

Other (Please specify.) 6% 0% 0% 0% 0% 94%

D. Design and construction

N=32

Much longer

than expected

(25% longer

 or greater)

Longer than

expected

(up to

25% longer)

Time

expected

Less than

expected

(up to

25% less)

Much less than

expected

(25% less

 or greater)

Not

applicable

Project engineering 6% 6% 47% 9% 0% 31%

Contracting 3% 6% 56% 3% 0% 31%

Mobilization (facility relocation) 0% 6% 47% 6% 0% 41%

Land acquisition 0% 19% 47% 0% 0% 34%

Site preparation 0% 6% 47% 9% 0% 38%

Noise mitigation construction 0% 0% 25% 0% 0% 75%

Project construction 6% 13% 34% 6% 3% 38%

Other (Please specify) 6% 0% 0% 0% 0% 94%

Other (Please specify) 3% 0% 0% 0% 0% 97%

If necessary, provide clarifying information for your response:

N=18
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5

7. The following table lists stakeholders that may have been involved in your runway project. Please

indicate the extent to which each stakeholder’s involvement took more or less time than you

expected during each phase of your runway project. Please indicate ‘not applicable’ for those

stakeholders with which you have not yet interacted.

Using the following scale (without regard to set percentages as used in question 6), select the one that best

describes the impact of this stakeholder in each phase of the project. Please clearly indicate plus or

minus, as appropriate, next to the number you select.

-2= Much longer than expected

-1= Longer than expected

 0= Took the time expected

+1= Less than expected

+2= Much less than expected

NA= Not Applicable

Stakeholder Planning Environmental

process

Litigation Design &

construction

FAA Headquarters -.012 -0.48 0.00 -0.43

FAA Region -0.18 -0.52 0.29 -0.20

FAA District Office -0.04 0.00 0.00 0.16

FAA Air Traffic Control 0.00 -0.14 0.00 -0.10

U.S. Environmental Protection Agency -0.50 -0.80 -0.67 -0.45

U.S. Army Corps of Engineers -0.25 -0.57 0.00 -0.58

Department of Justice 0.00 -0.17 0.00 0.00

Airlines -0.38 0.05 -0.25 -0.09

State Department of Transportation -0.27 -0.20 0.00 -0.25

State Environmental Agency -0.35 -0.52 -1.00 -0.46

Local agencies -0.19 -0.42 0.00 -0.32

Community Interest Groups -0.32 -0.50 -0.43 -0.31

Metropolitan planning

Organization (MPO)

-0.04 -0.15 0.00 0.00

Financial institutions 0.00 0.00 0.00 -0.11

Contractors -0.22 -0.10 -0.25 0.13

Other (Please specify.) [a] [a] [a] [a]

Other (Please specify.) [a] [a] [a] [a]

[a] Insufficient number of similar answers to summarize.

If necessary, provide clarifying information to your responses:

N=12
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6

8. Which of the following geographic characteristics surrounding your airport had/will have an impact on the

runway project? (Check one column for each row.)

Characteristic None

Some

Impact

Moderate

Impact

Great

Impact

a. Lack of open space within airport boundary N=31 42% 19% 13% 26%

b. Community proximity N=32 13% 25% 19% 44%

c. Hills, mountains, or other obstructions near airport

N=32

50% 28% 6% 16%

d. Highways or railroads nearby N=32 16% 44% 9% 31%

e. Water surrounding area N=32 56% 25% 12% 6%

f. Wetlands considerations N=32 25% 34% 9% 31%

g. Other (Please describe) N=6 17% 17% 17% 50%

If necessary, provide clarifying information for your response:

Responding airports provided additional information to this question. The airports cited factors not

explicitly listed in the question, including endangered species, landfills, valleys and airspace conflicts

and/or described how the geographic characteristic affected their projects. (N=14)
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7

9. Please describe the most critical or significant events or factors that either delayed or accelerated the

completion of your runway project and briefly describe why or how each one affected it.

Events or factors that delayed the project:

Responding airports generally stated that events or factors that delayed their projects identified

challenges in three major areas—resolving differences among the stakeholders involved in the

runway development process, completing extensive federal and state regulatory and legal

environmental requirements, and handling site specific challenges related to the airport’s location.

(N=29)

 Events or factors that accelerated the project:

Responding airports generally stated that events or factors that accelerated their projects focused

primarily on improving communication and coordination with major stakeholders and streamlining

the environmental process. Some stakeholders also identified innovative construction techniques

that they believed accelerated the completion of their projects. (N=20)
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8

COSTS TO BUILD THE RUNWAY

10. What were your original cost estimates and actual costs incurred during each phase of your runway

construction project? (Please state dollars in millions.)1

Project Phase or step Original estimate Actual costs

Planning N=32 N=32

Environmental N=32 N=32

Environmental mitigation N=32 N=32

Litigation N=32 N=32

Land acquisition N=32 N=32

Design and construction N=32 N=32

Total N=32 N=32

11. What percentage of the funding for your runway project came from or will come from the following

sources?

Sources Percent Not applicable

Airport Improvement Program—entitlement 19% N=4

Airport Improvement Program—discretionary 25% N=7

Passenger Facility Charges 18% N=12

Airport bonds 22% N=9

State grants 2% N=25

Landing fee revenue 1% N=28

Other airport revenue 0% N=27

Other: (Please specify) 0% N=32

[a] Figures represent the average of the responses given, and therefore, do not total 100 percent.

12. For each of the funding sources listed below, please indicate the extent to which your project was delayed

because of delays in receiving the funds.

Source Delayed

greatly

Delayed

somewhat

No

 delay

Not

applicable

Airport Improvement Program—entitlement

N=32

6% 9% 59% 25%

Airport Improvement Program—discretionary

N=32

12% 12% 47% 28%

Passenger Facility Charges N=32 0% 0% 50% 50%

Airport bonds N=32 0% 3% 69% 28%

State grants N=32 0% 3% 28% 69%

Airport revenue N=32 0% 3% 41% 57%

Other: (Please specify) [a] [a] [a] [a]

[a] Insufficient number of similar answers to summarize.

13. Did you consider constructing this runway project without the use of federal AIP funds?

Yes [ 9% ] NA=6%

No [ 84% ] N=32

Please explain.

1

 Due to the various methods used to account for project costs, summarization is not possible.
Appendix IX

Survey of Airports with Recent or Planned 

Runway Projects

Page 80 GAO-03-164 Aviation Infrastructure

9

Responding airports generally stated that they were either required to use AIP funds, that non-use

would present significant financial burden upon the airport, or that federal funds were necessary to

establish the financial feasibility of the project. (N=17)
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Survey of Airports with Recent or Planned 

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10

IMPACT OF RUNWAY PROJECT

14. What impact do/did you expect this runway to have on the maximum number of operations per hour at

your airport?

Type of weather

Maximum number of hourly

operations before runway

completion

Estimated maximum number of

hourly operations after runway

completion

a. VFR conditions Range: 75 - 270 Range: 90 - 278

b. IFR conditions Range: 50 - 185 Range: 59 - 216

15. How did you estimate the maximum number of additional operations per hour that could be

accommodated from building your new runway? (Please include such information as the model used,

which contractor was used to prepare the estimates, based on what study.)

Responding airports briefly described the models used to construct the estimates: 25 used SIMMOD

primarily or exclusively, and 7 did not expect capacity to change as a result of the project or did not

specify the model used. Other models cited included TAAM, DELAYSIM, and ADSIM/RDSIM. (N=30)

16. In 2000, what percentage of annual operations was attributed to the three largest carriers (passenger or

cargo) at your airport?

Name of carrier Percentage of total annual

operations

a. N=32 Range: 8% - 78%

b. N=32 Range: 4% - 32%

c. N=32 Range: 3% - 22%
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11

IMPROVING THE RUNWAY PROCESS

17. What changes, if any, would you recommend to expedite the overall process (from planning through

construction) for building runways and which federal, state or local entity would be the most appropriate

one to address each of the changes?

Responding airports provided a number of potential initiatives directed at expediting the overall

process for building runways directed primarily at improving communication and coordination

between stakeholders and streamlining the environmental process. (N=31)

18. Other than building new runways, what can be done to increase the capacity of the National Airport System?

Responding airports provided a number of potential initiatives directed at increasing the capacity

of the National Airport System including changes to airspace utilization, technology improvements

and ATC modernization and the continuing construction of new infrastructure. (N=29)
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12

RUNWAY EXTENSION PROJECTS

Answer questions 19 – 21 in this section only if your airport completed one or more runway extensions from

1991 through 2000 or has one or more runway extensions planned from 2001 through 2010. (If you have

received more than one survey, please respond to questions 19 - 21 once.)

19. Describe the runway extensions you have completed or planned to complete by 2010.

Runway number Year extension

completed

Extension completion

time--years/months

Length of original

runway

Length of

extension

N=16 Range: 1991 -

2010

Range: 00/04 – 05/00 Range:

3,000 ft. - 12,636 ft.

Range:

489 ft. - 5,500 ft.

N=6 Range: 1992 -

2004

Range: 00/07 – 05/09 Range:

8,900 ft. - 11,388 ft.

Range:

1,000 ft. - 2,012 ft.

N=3 Range: 1998 -

2005

Range: 02/00 – 06/07 Range:

5,001 ft. - 11,388 ft.

Range:

2,000 ft. - 4,769 ft.

N=0 Range: N/A Range: N/A Range: N/A Range: N/A

20. What were you seeking to accomplish by building this extension (e.g., changed runway from commuter

runway to one for only large airplanes)? What impact did/will the extension(s) have on the capacity of this

airport?

Responding airports provided information regarding the purpose of their runway extensions. The

primary purpose for the extensions was to accommodate longer-range aircraft, heavier aircraft (i.e.,

cargo), increase safety, and/or reduce noise impacts. (N=19)

21. How is the process for planning and building an extended runway different from building a new runway at

your airport? (Please explain.)

Responding airports stated that the process for building an extended runway is virtually the same as

that for building a new runway, with minor exceptions. Exceptions included such things as, reduced

environmental impacts, less controversy, fewer legal challenges, and shorter construction time. (N=19)
Appendix IX

Survey of Airports with Recent or Planned 

Runway Projects

Page 84 GAO-03-164 Aviation Infrastructure

13

IMPACT OF THE SEPTEMBER 11, 2001, ATTACKS ON THE NATIONAL AIRPORT SYSTEM

22. How important is it to add capacity to a) your specific airport, and b) the National Airport System after the

terrorist attacks on America on September 11, 2001? Have your airport’s priorities changed as a result of the

terrorist attacks? If yes, please explain.

Responding airports stated that their short-term focus would shift to safety and security, however,

long-term plans remained largely unchanged. They also noted that capacity remains important to

the nation’s airport system. (N=32)

23. What impact, if any, have or will the terrorist attacks on September 11, 2001, have on the completion of any

 runway or runway extension planned at your airport?

Baltimore Washington International, Charlotte, Dallas, Minneapolis, and Phoenix experienced

delays or deferred airside projects. Several airports noted that their projects were demand driven

and that the extent to which demand returns to the airport would determine when the project would

be started. (N=29)

24. Given the current financial condition of the major airlines at your airport, what is the likelihood that these

airlines will be able to contribute financially to funding your runway project or repayment of existing debt?

Responding airports stated that in the short-term, airlines may have some difficulty in providing

financial contributions to the airport. The airports anticipate that the long-term financial

commitment of the airlines will not be impacted. (N=32)

Please feel free to include any additional documentation that you believe will help us

better understand your runway project and your experiences with it.

 Thank you for taking the time to complete this survey.

(390007)
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