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.
To learn more about EPA’s Audit Policy or to access screening checklists and audit protocols, visit http://www.transource.org.
August 7, 2000, EPA Letter to Airports on Voluntary Disclosures and Environmental Auditing http://airportnet.org/depts/environmental/epalet2.pdf
August 7, 2000, Enclosures with EPA Letter to Airports on Voluntary Disclosures and Environmental Auditing http://airportnet.org/depts/environmental/epalet3.pdf
AAAE Airport Environmental Audit Manual, https://airportnet.org/marketplace/e1.htm
AAAE Environmental and Occupational Safety and Health Inspection Manual, https://airportnet.org/marketplace/e3B.htm