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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.