Airport Environmental Audits Issue Briefs____________

Author:  Claudio Ternieden, (703) 824-0504


What’s at Issue?

In light of the increasing environmental regulations and extraordinary costs for cleanup, some airports are developing comprehensive environmental management programs. An environmental audit is one of the first toward initiating such a program.


Why it’s Important

In recent years, EPA has encouraged airports to participate in voluntary environmental audits. In July of 2000, Eric Schaeffer, then EPA’s Director of Enforcement, sent numerous letters to mid-sized airports encouraging the use of the Agency’s Audit Policy.

For example, EPA highlighted its settlement with American Airlines (AMR Corporation) concerning Dallas/Fort Worth International Airport. When American Airlines conducted a voluntary audit in accordance with EPA’s Audit Policy, EPA forgave more than 90 percent of the violations under the Clean Air Act, saving American Airlines $1.4 million in penalties, plus the expense of costly litigation.

Individual states have also developed “audit privilege” policies to foster greater voluntary compliance and reporting of violations.

As the airport industry continues to grow and as federal and state environmental regulators continue to increase scrutiny of airport facilities, understanding environmental liabilities is essential.

Airports should closely investigate and examine all potential liability issues before looking into conducting an environmental audit of their facility. Consideration of local, state and federal laws, regulations and policies is important.


Major Provisions

EPA’s Audit Policy, revised in May 2000, offers incentives to organizations that voluntarily disclose and correct environmental violations. The recent revisions were designed to facilitate the audit process, and allay fears of recrimination from EPA upon disclosing entities.


Related Links

To learn more about EPA’s Audit Policy or to access screening checklists and audit protocols, visit

August 7, 2000, EPA Letter to Airports on Voluntary Disclosures and Environmental Auditing

August 7, 2000, Enclosures with EPA Letter to Airports on Voluntary Disclosures and Environmental Auditing

AAAE Airport Environmental Audit Manual,

AAAE Environmental and Occupational Safety and Health Inspection Manual,