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OCR for page 14
14 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning
Summary of Fact Sheet 1:
Physical Impacts to Wetlands and Other Surface Waters
Airport property may contain or be adjacent to wetlands or other surface waters. The infra-
structure siting associated with new development projects often results in unavoidable potential
physical impacts to these resources and/or their buffer zones. Avoidance of these impacts is the
top priority. At times, for example, where land availability is limited or airport design standards
require a project in a specific location, avoiding impacts is often not possible. Where impacts
appear unavoidable, permits and mitigation measures are required.
Regulations have been developed to protect wetlands and other surface waters from particular
physical impacts. Sections 9 and 10 of the Rivers and Harbors Act established a permit program
for structures affecting or work conducted in "navigable waters." Section 404 of the Clean Water
Act (CWA) established a permitting program under United States Environmental Protection
Agency (USEPA) guidance for discharges of dredge or fill materials into "waters of the United
States." If structures, work, or discharges of material are proposed for wetlands or other surface
waters, a permit authorizing the activity may be required by the United States Army Corps of
Engineers (USACE) before the activities commence. Prior to authorization of a Section 9, 10, or
404 permit, a Water Quality Certification under Section 401 of the CWA must be issued by the
state to certify that the federal permit meets state water quality standards. Since federal agencies
authorize Section 9, 10, and 404 permits, the requirements of NEPA apply. Typically, the USACE
ensures NEPA requirements are met through the agency's internal permit approval process; how-
ever, in some situations, another federal agency (e.g., the FAA) assumes the lead regulatory agency
role for the NEPA process for this type of water resource issue.
Characterizing the effects of a development project on wetlands and other surface waters requires
an understanding of how the project affects the development site and an understanding of the core
regulatory requirements. Federal agencies must evaluate the project, as well as ensure that options
to avoid or minimize impacts to wetlands and other surface waters have been assessed. Mitigation
is required as a condition for some permit authorizations when those impacts cannot be avoided.
Project planning and design considerations typically associated with physical impacts to wet-
lands and surface waters include the following:
· Do potential sites contain wetlands and other surface waters?
· Have those wetlands and surface waters been delineated on the site, had their quality assessed,
and received a jurisdictional determination to identify the governing regulatory agency?
· Have alternatives for avoiding the wetlands and surface waters been assessed?
· Have mitigation options, their cost, and an implementation schedule been assessed during the
early planning stages?
The process for assessing core regulatory requirements, determining the measures needed for
compliance, and reducing the effects of managing physical impacts to wetlands and other surface
water issues on the development project are presented in Fact Sheet 1 in Appendix B. A summary
of the guidance for reducing those project impacts follow.
Guidance for Reducing Project Impacts from Managing Issues
Associated with Physical Impacts to Wetlands
and Other Surface Waters
Water Resource Inventory Prepare water resource inventory for use on multiple
projects. Identify wetland acreages and quality.
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Handbook Overview 15
Impact Avoidance Consider relocation of some or the entire project to
avoid wetland or surface water impacts for all
development projects. Having alternate sites for
those projects, if feasible, may reduce delays if a
change is made.
Permit Acquisition Limit wetland and stream impacts if possible such
and Approval that Nationwide Permits (NWPs) rather than indi-
vidual permits can be used. This will minimize
schedule impacts and reduce permitting costs.
Design Development Consider whether changes to the development
project might reduce the cost and schedule
impacts for permitting.
Development Revenue Account for gained or lost revenue from changes if
project function or scope must change to achieve
compliance.
Schedule and Sequencing Recognize that schedule changes usually equate to
cost increases for consultation, design, and
construction.
Staffing Identify the expertise needed, select qualified
experts, and bring them in at the right time to
avoid re-doing work.
Stakeholder Coordination Seek to understand cost considerations raised by
stakeholders such as airlines and various airport
departments. Coordinate early with stakeholders
such as airlines, regulators, various airport
departments, and communities to avoid multiple
iterations of permitting and design. Plan for
early and ongoing coordination with regulators
(pre-application meeting).
Delineation Adequately delineate stream and wetland bound-
aries using required methods, preferably with an
airport-wide delineation, to reduce time commit-
ments on individual projects.
Documentation Submit complete notifications and applications.
Mitigation Consider enhancements to existing surface waters to
get mitigation credit rather than construction of
new wetlands or surface water segments. Con-
sider using a single mitigation site for multiple
projects to reduce coordination and costs. Verify
that the location of mitigation areas is compatible
with wildlife hazard management requirements.
Start of Work Verify that federal agencies have fully completed
activities and issued permits and approval before
construction.
