When does NEPA apply to an FAA action?
FAA presumes these are major Federal actions: airport layout plan (ALP) approvals, airport development funded with federal grants or passenger facility charges, and commercial space licenses. Projects with 14 percent or less FAA funding and little federal control are presumed not to be; advisory part 77 airspace determinations fall outside NEPA[1].
For SpaceX's Starship at Boca Chica, Texas, FAA's tiered EA for up to 25 launches a year opened for comment in July 2024, was revised in November, closed comment January 17, 2025, and ended in a mitigated FONSI. Three more tiered EAs have followed, the latest with comment from July 13 to August 3, 2026[4].
FAA categorical exclusions (CATEXs) and extraordinary circumstances
Order 1050.1G renumbered the CATEXs without revising them[2][3]. An extraordinary circumstance, such as an adverse effect on historic properties, listed species or Section 4(f) land, or noise in noise-sensitive areas, rules out a CATEX only if it may cause a significant effect that analysis or changes cannot resolve[1]. Airport examples:
- B-2.4(e): taxiway, apron, safety area and runway extension work without significant impacts[1]
- B-2.4(f): hangars, small parking areas, signs, fences and similar minor development[1]
- B-2.4(gg): airport projects with limited federal funding, under inflation-adjusted thresholds[1][5]
- B-2.4(hh): rebuilding facilities damaged in a declared emergency, in place, within two years[1]
Airport environmental review: the sponsor's role and Order 5050.4
The airport sponsor, the public agency or private owner seeking federal grants, prepares most airport documents[5][1]. FAA helps define purpose, need and alternatives, joins in choosing the consultant, and independently evaluates and takes responsibility for the content[1].
FAA sets the EA's start date once the sponsor supplies a sufficient scope of work and, for grant projects, shows it can fund its share[1]. Order 5050.4B, FAA's 2006 airport NEPA instructions, is still active, but 1050.1G wins any conflict[6][5][1].
Which airport projects need an EA or an EIS?
An EA is normal for a new general aviation airport, a new runway outside a metropolitan statistical area (MSA), or new procedures routing aircraft over noise-sensitive areas below 3,000 feet. FAA presumes an EIS for a new commercial service airport or air carrier runway in an MSA, a major runway extension, or a launch site license requiring construction on undeveloped land[1].