(Originally published September 10, 2024. Modified for this post.)

In The little project that couldn’t, part 1, I described a proposed project to develop a cargo facility on an airport somewhere in the United States of America. Our consulting team was hired by the project proponent to perform Federal environmental review and public outreach; my specific role was to calculate aircraft air emissions. In part 1 I also described the public hearing for this project: a raucous affair where dozens of people commented on unhealthy air quality, wealth-sharing agreements, and more. But, our environmental document showed that the project would have no significant environmental impacts and would also bring thousands of jobs to the region.

That brings me to my thesis: business processes express power. Meaning, business processes are inherently political: they manifest power relations between people. To get a glimpse of those power relations, do a process analysis.

The above thesis is obvious to anyone with a hint of background in critical theory. But I was trained as an engineer, so bear with me…

Contextualizing the project: the business process

For the development of this airport cargo facility, I’ll illustrate the business process as notional statements from the project proponent:

1. “Okay, we propose to build a cargo facility on an airport. We’ve fully designed the facility, down to the departure and arrival times of each cargo flight.”

2. “Ahh, so the FAA is saying the Airport Layout Plan (ALP) needs to be updated before construction can start. Let’s get that ALP updated.”⁵

3. “Umm… so apparently an ALP update needs Federal environmental review?”⁶

4. “… and, we’re being told we should have a public comment period?! How long is this thing gonna take, Jimmy?”⁷

Simplified:

1. Design a facility for a specific airport

2. Before constructing the facility, complete Federal environmental review

3. Before completing Federal environmental review, do the following:
   (A) Publicly disclose potential environmental impacts of constructing and operating the facility
   (B) Receive and respond to public comments

I want to emphasize the following: our consulting team was engaged to support Federal environmental review for the proposed project, and my specific role was to calculate aircraft air emissions. This article reflects those facts. I can’t speak to the numerous other applicable laws, regulations, and policies because I wasn’t involved in compliance for those. I don’t believe that changes my overall thesis, however. And do not call me “Jimmy”…

What the business process makes clear

When laid out as I’ve done above, the business process makes the following clear: the only official focus for public comment was the environmental impacts of the proposed project — not the proposed project itself. Let’s illustrate this with some notional (but realistic!) comment responses from the project proponent.

The size of the facility? The number of takeoffs and landings for cargo flights? Not up for conversation.

What about the quality of jobs? Livable wages? Good healthcare? Also not up for conversation.

Why put this facility here? Why build it now? Not up for conversation.

What about the fact that the communities have been dealing with bad air quality and loss of economic opportunities for years?

Of course people could comment about all of the above… and they did! But, commenting is not conversation. It’s certainly not engagement.

So yes, you might say (as some of you have) that the community was expressing a huge unmet need — a need that the Federal environmental review process was not intended to meet.

Something was amiss… or maybe not?

At the end of Part 1, I wrote the following:

But then I had to face the question: Amiss for whom?

The answer: It was amiss for the impacted communities, but not for the project proponent.

You could say — and I would agree — that the proponent could make fundamental changes to the proposed project if they wanted to. But:

1. Federal environmental review did not require the proponent to make deeper changes to the proposed project, since its proposal was already compliant with Federal laws; and,

2. Because public comment came after project design (surely an expensive and lengthy activity), the proponent was heavily incentivized against fundamentally changing its proposal.

I suppose the project could have been stopped or fundamentally changed… but not because of Federal environmental review.

Let me present to you the business process again:

1. Design a facility for a specific airport

2. Before constructing the facility, complete Federal environmental review

3. Before completing Federal environmental review, do the following:
   (A) Publicly disclose potential environmental impacts of constructing and operating the facility
   (B) Receive and respond to public comments

Now let’s do a quick analysis of the process to uncover a few primary intentions and beneficiaries.

Business process intention 1

The first intention is to protect the project proponent and the Federal government from losing a lawsuit by complying with Federal law. This includes complying with a legal requirement to receive and respond to comments. By the way, some folks did indeed file a lawsuit… and they lost bigly.

Beneficiaries: The Federal government; the project proponent

Business process intention 2

The second intention is to protect the fundamentals of the project through:

• Initiating public engagement after project design is complete; and,

• Limiting the scope of public engagement to environmental impacts.

Beneficiary: The project proponent

The project proponent didn’t need to wait until the Federal environmental review process to talk to impacted communities. But, it was incentivized to wait in order to protect the fundamentals of its project. That’s how the above business process upholds the status quo of power relations between the proponent and impacted communities.

What “you” can do about it

Again — I wrote the following at the end of Part 1:

But then I had to face another critical question: Who are “you”?

Answer: I don’t know… but I know whom I’m speaking to.

I’m speaking to people who are interested in challenging existing systems of power and advocating for different systems. I’m speaking to people who want to know: where does power come from, and how is it perpetuated?

To question and challenge systems of power, you have to uncover them.

I would suggest, however, that the first step is to explore your own positionality.

Step 1: Explore your own positionality

“Positionality”: go put that in your Microsoft Word dictionary.

I like the words about positionality offered by Common Ground, an organization that supports Indigenous peoples in Australia. Their explanation begins as follows:⁸

I like these words because they emphasize that positionality is about how we relate to each other. That is to say: positionality involves truth-telling about who we are to begin exploring how we impact one another. All of us are very familiar with some aspects of the world while having no idea of other aspects. There are things we don’t know that we don’t know, and pretending otherwise is harmful.

Build relationships with people different from yourself. See what comes up within you when you talk to those people. Irritation? Frustration? Disbelief? Bewilderment? Sit with yourself and explore why those particular feelings come up. I think that inner work is essential to authentic relationship-building, so get a good therapist if you can afford one. Therapy helps… ask me how I know!

I offer my deep gratitude to Heather Luna and Lavinia Muth for introducing me to the concept of positionality.

Step 2: Review business processes from multiple perspectives to uncover power relations

I would urge doing this Step 2 in community with others, rather than alone. Like I said: positionality is relational. Here are some questions to ask when reviewing a business process:

• Who benefits from this business process?

• Who suffers from this business process?

• Are there official methods for different groups of people to engage with this process? If yes, how might those official methods perpetuate the status quo of power relations?

Step 3: Explore how your power extends beyond official methods of engagement

What unofficial channels can you use to influence business processes? What unofficial channels can you create?

For example, I took the introductory and intermediate sessions of the Your City, Your Voice activism training offered by Transportation Alternatives. This New York City organization has been advocating for alternatives to automobiles since 1972. The group recognized that the New York City Department of Transportation often deferred to city community boards on whether to build new bicycle lanes, even though community boards don’t have official power to stop such projects. The Transportation Alternatives response: influence community board members as a core unofficial channel of bicycle advocacy.

Advocates have the benefit of acting holistically by working outside of official engagement channels (if they exist). Here’s the secret: official engagement channels actually serve to limit the officials themselves. I saw this repeatedly over my years as an FAA employee and aviation environmental consultant.

Here are my questions for you

Take a look a business process that you work with regularly. It can be internally-facing or externally-facing. Ask these questions:

• Who has the power to decide what business process inputs and outputs are up for discussion? Where does that power come from?

• Who has power to change the business process?

• What groups are negatively impacted by the business process? Do those groups have the power to change the business process?

Ask the above from the perspective of official channels of power. Then ask from the perspective of unofficial channels.

The truth about the restaurant that night

In Part 1 of this article series, I wrote about my presence at a public hearing on the proposed air cargo project in the summer of 2019:

An hour went by. Two hours went by. Hundreds of people, in the hearing room and several overflow spaces. Dozens of comments — yes, some of which were supportive. Signs waving. A fight in the hallway — or threats of one, anyway (“hold me back, bro!”). And, plenty of prohibited applause.

Eventually, it was all over.

Later that night, we consultant team members were at a restaurant with our (indirect) client the airport director for dinner. I was sitting at the bar drinking the worst Manhattan that side of... uh, Manhattan, when I heard a verbal exchange that I'll never forget for the rest of my career.

It was the airport director, speaking to a senior member of our team. Without a moment's pause, that senior member turned and responded:

Then they laughed.

Now I’m going to give you some truth that I’d left out of Part 1.

At the end of the evening, we were settling our restaurant bill when I saw the airport director stand up and walk over to a table of people near the door. I can still picture the forms and color tones: rectangular, dimly lit, decor of browns or greens, with maybe 8 to 12 people having a meal together. I looked closer and squinted… then spoke to myself silently with mouth open.

Yes. Yes they were.

They all chatted together for a few minutes. Then, the airport director exited through the restaurant door and into the night.

I have no idea what he said to them and what they said back, but the conversation appeared friendly rather than heated. I think I even heard laughter — the peaceful kind, not the cynical kind.

Was this their first time talking together? If yes: why? If no: why?

Why not have this friendly-rather-than-heated discussion before the air cargo facility design was complete?

That summer night in 2019 was an unforgettable night in my life and a formative moment in my career. So much of what I’ve been exploring about “sustainability,” power, colonization, and decolonization has been about putting color and shape to that evening.

Playing that night in my mind, I still wonder how much I didn’t know… and what really could have been.

Got something to say to me?

I’m Chris, the Principal of CJSC, LLC, and I’m (un)learning along with all of you — so hit the “reply” button and give me a piece of your mind!

Introductory image from The Kids Should See This - Chocolate Candy Factory Conveyer Belt - I Love Lucy.

1  NEPA | National Environmental Policy Act. (n.d.). Retrieved September 10, 2024, from https://ceq.doe.gov/. Archived link.

2  Environmental Impacts: Policies and Procedures (FAA Order 1050.1F). (2015). Federal Aviation Administration. Retrieved September 10, 2024, from https://www.faa.gov/documentLibrary/media/Order/FAA_Order_1050_1F.pdf. Archived link.

3  1050.1F Desk Reference. (2023). Federal Aviation Administration. Retrieved September 10, 2024, from https://www.faa.gov/media/71921. Archived link.

4  What is General Conformity? | US EPA. (2024, June 3). US EPA. Retrieved September 10, 2024, from https://www.epa.gov/general-conformity/what-general-conformity. Archived link.

5  49 U.S. Code § 47107(a)(16).

6  FAA Order 1050.1F, paragraph 2-2.1(b)(2)(g).

7  FAA Order 1050.1F, paragraph 6-2.2(g).

8  Holloway-Clarke, T. (2024, July 9). What is Positionality? | Common Ground. Retrieved September 10, 2024, from https://www.commonground.org.au/article/what-is-positionality. Archived link.