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A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning (2011)

Chapter: Section 2 - Establishing a Water Resource Issue Management Program

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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
×
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
×
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
×
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
×
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
×
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
×
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
×
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
×
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
×
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
×
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
×
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Suggested Citation:"Section 2 - Establishing a Water Resource Issue Management Program." National Academies of Sciences, Engineering, and Medicine. 2011. A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning. Washington, DC: The National Academies Press. doi: 10.17226/14576.
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28 2.1 Introduction Section 2 identifies the elements of a Water Resource Issue Management Program. The purpose of such a program is to establish a framework and baseline information from which water resource issues can be managed within specific devel- opment projects. The Water Resource Issue Management Program presented this section serves as an example that an airport operator could follow to facilitate the project planning and execution process. It is expected that airport operators at specific airports would implement the program elements presented here to the degree deemed appropriate to meet their overall management structure, project needs, and available funds. Whatever the structure, a well-planned Water Resource Issue Management Program provides the foundation for improved integration of water resource management into the project implementation process. While the processes that airport operators use to implement development projects are rela- tively well established, the processes for managing water resource issues within development projects are not. In part, this is because water resource issue management is frequently not con- sidered to be an integral part of the development project planning process. This results in the tendency to manage water resource issues associated with development projects on an ad hoc basis in which issues are addressed as they arise. S E C T I O N 2 Establishing a Water Resource Issue Management Program Key Notes The assessment of water resource issues should be an integral part of the project planning process. This may require obtaining a more detailed under- standing of these issues earlier in the project implementation process. Consequences of Not Utilizing a Clear Structure for Managing Water Resource Issues in Development Projects 1. Project delays due to • Late identification of information needs; • Insufficient information on existing water resources when decisions are made; • Lack of clarity on responsibilities for tasks and decisionmaking; • Lack of clarity on how project and water resource issues are coordinated; • Lack of definition of the design completion level needed to support NEPA; and • Insufficient understanding of regulatory timeframes. 2. Increased costs due to • Failure to avoid water resource impacts; • Controls/mitigation designed larger than necessary;

Establishing a Water Resource Issue Management Program 29 Effective planning for water resource issues—with a goal of reducing effects on development projects—can be facilitated by establishing a Water Resource Issue Management Program. The program recommended herein includes the following elements: 1. Water Resource Issue Information Catalog— • Water resource inventory, • Project characteristics checklist, • Core regulatory requirements, and • Mitigation facility inventory. 2. Water Resource Issue Management Plan— • Management roles and responsibilities, • Protocols for managing the NEPA process, and • Protocols for integrating water resource issue management and project implementation process. The Water Resource Issue Information Catalog provides a common baseline of information from which assessment of water resource issues on all projects can proceed. The catalog should ideally be established outside of the planning process such that the information is accessible at the start of the plan- ning process; this will allow more informed consideration of water resource issues at a point in the planning process where water resource impacts can be most easily avoided. The Water Resource Issue Management Plan establishes the guiding principles, management structure, methods, and strategies that will be used to execute the management of water resource issues within the context of a development project. Documentation of findings during develop- ment of the Water Resource Issue Management Plan development is important. Examples of documentation for key elements of the process are provided in Appendix A and referenced in the subsequent sections. 2.2 Water Resource Issue Information Catalog 2.2.1 Defining Key Terms One of the challenges of facilitating input among stake- holders with varying experiences and interests is “speaking the same language.” In many cases, the same terms will have different meanings to different stakeholders. Some of these terms are crucial to effectively communicating during the development project implementation process. Key Notes The first step in efficient planning for water resource issue management is accurately documenting the existing state of water resources at your site. Key Notes Defining a common language for discussing water resource issues is an important—but often an overlooked—step. • Lack of understanding of mitigation options; and • Insufficient analysis of the interactions between multiple water resource issues. 3. Changes to project function due to • Making project design decisions before water resource issues are assessed; • Making decisions based on inadequate information; and • Unclear method for factoring in environmental considerations into site selection.

30 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning Terms associated with water resources are particularly important because they may have regulatory implications. Prior to discussing specific techniques for characterizing the water resources, it may be useful for stakeholders to ensure they have a common understanding of the water resource–related terms that will be used in their discussions. The following definitions of key water resource–related terms are used in the Handbook and recommended to stakeholders for consideration: • Water resources—sources of water that may be located on, near, or off airport property, including – Waterways (e.g., streams, creeks, rivers, and swales); – Water storage and frequent inundation areas (e.g., wetlands, floodplains, ponds, lakes, and detention/retention basins); – Subsurface sources (e.g., groundwater); and – Coastal and marine resources (e.g., oceans, estuaries, bays, coastal zones, and coastal barriers). These resources are valued for their beneficial uses and the life-sustaining qualities they offer to humans and aquatic life. In the context of the Handbook, the definition of water resource also extends to zones, boundaries, reaches, and classifications that have been created by regulations to allow for specific protection of water resources and their uses. • Water resource impact—a negative effect on a water resource based on the regulatory stan- dards for that resource that is caused by the development project. The term includes any effect that a project may have on a water resource and should not be confused with the term “impact,” as used by NEPA. • Water resource issue—a potential project effect associated with water resource regulatory requirements that dictates that an airport operator take action. A “water resource issue” moves beyond the direct effect on the water resource as defined by water resource impact and encom- passes the full scope of regulatory and project actions needed to manage the impact—including consideration of avoidance. Water resource issues are associated with particular regulations or groups of regulations. At some point in the development project implementation process, the detailed requirements of those regulations will need to be assessed with respect to the project’s water resource impacts. The emphasis on understanding regulation and issue-specific drivers for water resource man- agement is crucial. As such, to support the Handbook and its readers, seven categories for water resource issues have been identified. The categories are distinguished by a combination of the type of physical water resource in the environment and the regulations that are designed to pro- tect those resources for the benefit of human and aquatic life. Each water resource issue category has relatively unique regulatory requirements that must be assessed individually and in different stages of the planning process such that potential significant water resource issues are under- stood. Because of their distinct regulatory requirements and the fact that there are some unique strategy considerations for the management of each water resource issue, individual fact sheets have been prepared for each category. The fact sheets, listed below, are referenced in the remain- der of the Handbook and are found in Appendix B: 1. Physical Impacts to Wetlands and Other Surface Waters, 2. Surface Water and Groundwater Quality, 3. Storm Water Quantity and Floodplains, 4. Hazardous Wildlife Attractants, 5. Aquatic Life and Habitat, 6. Coastal Zones and Barriers, and 7. Wild and Scenic Rivers.

2.2.2 Creating a Water Resource Inventory An important Handbook principle is that airport staff know its water resources. Knowing water resources involves understanding the types of resources as well as their loca- tion(s), extent, quality, regional functions, and regulatory designation or status. Typically, the depth of knowledge of water resource increases as the project proceeds through the project imple- mentation phase. Having comprehensive and credible information on water resources available prior to project conception or during early project implementation phases is a crucial aspect of making good decisions and minimizing the effects of water resource issue management on the devel- opment project. One means of having water resource information available early in the project implementation process is through the development of a Water Resource Inventory. This can be done independent of project planning or as part of the planning process itself. A Water Resource Inventory should provide a baseline characterization of existing water resources on the airport site, as well as water resources on surrounding areas that may be affected by or affect airport development projects. A well-conceived inventory provides the following benefits: • Data for better informed initial siting and layout decisionmaking during the Conceptual Plan- ning Phase; • Information for initial discussions with regulators; • Information to support the NEPA process; • A common reference point for assessing water resources on multiple projects; • Information with documented sources and levels of accuracy to provide more representative comparisons of potential impacts for multiple projects; • Cost savings by avoiding the need to reassess water resources on a project-by-project basis; • Reductions in schedule impacts during early planning by potentially avoiding a data consoli- dation and collection step; and • Reductions in negative impacts to the development project function, airport operations asso- ciated with the development project, project schedule, and project costs resulting from deci- sions made using insufficient water resource data. The information contained in an inventory may vary depending on the water resources and local regulatory conditions, but generally should include the following, as available: • Maps showing general locations of the various resources, including – Wetland inventory maps (jurisdictional and non-jurisdictional); – Surface water maps for the local watersheds; – Onsite detention, retention basins, ponds, lakes, swales, ditches, creeks, streams, and regulated outfall locations; – Off-site features including basins, ponds, lakes, bays, oceans, ditches, creeks, streams, and rivers; – 100-year floodplain boundaries and floodway boundaries; – Coastal zone boundaries; – Hydrogeological maps; – Drainage or flood management district boundaries; and – Environmental or ecological zones. Key Notes It is difficult to make good planning decisions on water resource issues if the characteristics of the water resources at the site are not sufficiently understood. Key Notes Deciding to fund early assessment of water resource issues is a cost- and risk-based decision that may vary from project to project. Establishing a Water Resource Issue Management Program 31

32 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning • Narrative descriptions of the resources – Known past issues or regulatory actions, and – Comments on public interest. • Regulatory designations, including designated uses and quality ratings. • Other existing documentation, including – Storm Water Pollution Prevention Plans (SWPPPs); – Spill Prevention, Control, and Countermeasure (SPCC) plans, – Best Management Practice (BMP) manuals, – NPDES permits, and – Existing or historical permits for the facility. • Adjoining community or other land use plans. • Supporting information that may not specifically be a water resource, but supports assessment of water resources – Topographical maps, – Land use maps for the airport and adjoining communities, – Storm water infrastructure drawings, – Deicer use records and deicer application locations, – Water quality data, and – Water quantity data. Information for completing a Water Resource Inventory can come from a variety of sources. Typically, inventory information for identifiable water resources can be obtained from several sources, including • Publicly available information from historical characterization that an airport operator can obtain directly (e.g., National Wetlands Inventory [NWI] maps or watershed maps); • Publicly available information that can be obtained upon request from regulatory agencies (e.g., presence of endangered species and their habitats or floodplain boundaries); and • Regulatory documents. Information from these sources is typically easy and economical to obtain. The quality of the information, however, needs to be carefully considered in relation to its effect on project decision- making. The information in publicly available documents is frequently acquired from higher-level assessments that do not always capture important site details. The data also may not represent current conditions. Over reliance on data from these sources to characterize site-specific issues can increase the risk to project function, costs, and schedule from misinformed decisions. If it is determined that significant risks exist, the Water Resource Inventory can be supplemented by information from the following sources that may provide more detailed, site-specific data: • Information held by entities owning land surrounding the airport that may have been obtained from site-specific characterization. This should be limited to areas that can potentially impact or be impacted by the development project. • Existing site-specific characterization data at the airport from previous environmental inventories, previous proj- ect investigations, and past permit applications. If integration of this existing information proves insuffi- cient to reduce risk to the desired degree, it may be necessary to acquire detailed data from new field surveys. Obtaining site-specific information can be costly, and it may be difficult to justify the expense early in the planning process, espe- Key Notes It is crucial that the project team ask environmental compliance specialists to define the degree of accu- racy required in characterizing water resources for the purpose of assessing compliance. A lack of sufficient accuracy may trigger the need to collect additional field data on water resources late in the project.

cially if multiple project sites are under consideration and the development area is large. As a result, it is important to seek consultation on defining how the risk of not collecting sufficient water resource data will be assessed. Such an analysis is challenging because it involves a com- parison of real, verifiable, and short-term costs (the cost to complete the field assessments and establish the inventory) to potential costs that may be incurred should unanticipated water resource issues become problematic on a project. Allocating resources for early planning does run the risk of spending valuable budget on items that may have no clearly defined payback; however, it is entirely possible that paybacks greater than an order of magnitude can be achieved through costs saved by not having to manage issues that develop later in the project. One means of balancing cost and risk for a Water Resource Inventory is to identify the water resource locations that are most crucial to the development project moving forward and then perform a gap analysis comparing the quality of the existing information with the quality of data ultimately needed for permitting and design. Crucial water resource locations could be defined as • Sites where there is a high likelihood that the project will be constructed and • Sites where water resource issue management may be especially challenging. Focusing on crucial water resource locations for data collection can reduce the outlay of costs. Assessment of the most crucial areas may require input from experts of water resource and experts in associated regulations. The experts should identify the extent and characteristics of data that are acceptable to regulators during the permitting process. An airport may find that establishing methods for track- ing development project life-cycle costs on projects, specific to cost impacts from water resource issue management, strengthens the ability to demonstrate the benefit of early planning for water resource issues on future projects. Such a tracking system can certainly be a challenge to implement, but may be beneficial for airports with many planned devel- opment projects. It is important that the Water Resource Inventory be updated whenever additional site-specific information has been obtained on projects. Over time, this will build the extent and quality of the inventory to the benefit of future projects. It is recommended that water resource inventories be developed prior to the Conceptual Plan- ning and Detailed Planning Phases. Most often, this data is not collected until the NEPA process is initiated. The Handbook recommends that an inventory be established before project plan- ning and, thus, before the NEPA process. Creation of the inventory in this fashion will result in cost savings as the NEPA process is initiated because that process can rely on the same data, with little updating. 2.2.3 Water Resource Impact and Issue Checklist An additional step in improving the effectiveness of the process is achieving an increased awareness of the linkages between development projects and water resource impacts. Greater awareness of these linkages by those responsible for planning should facilitate improved decision making when initiating the project planning process. Creating a checklist Key Notes The risk to project function, cost, and schedule incurred late in projects by inadequately funding early assessment of water resource issues should be a consideration in budgetary planning. Evaluation of risk-based costs is a project-by- project consideration. Key Notes Water resources are not typically a problem until they are potentially impacted by a project. Early understanding of the possible impacts of project alternatives on water resources should be sought and documented. Establishing a Water Resource Issue Management Program 33

of possible water resource impacts and issues associated with potential projects can provide good baseline information for initial planning efforts. Despite seemingly significant differences in scope, many development projects can have sim- ilar effects on water resources. This is because when managing water resource issues, the features and characteristics of a development project and its post-construction operations are typically more important than the type of project. For example, a new runway development project may have vastly different operational objectives, extent, cost, and regulatory burden than a parking lot development project. From a water resource issue perspective, however, both projects may require a large amount of new impervious surface to be constructed on previously undeveloped land. Thus, both projects may have similar water resource impacts and water resource issues to manage, such as filling of wetlands, increases in storm water quantities, and impacts to water quality. Understanding the critical features of a project and its associated post-construction operations are therefore important steps in managing the water resource issues. The project characteristics affecting water resources can be considered from two perspectives: 1. Issues associated with siting and construction, which are short-term or one-time water resource issues, and 2. Issues associated with ongoing activities, which are continuous or repeated long-term water resource issues from operations after construction. An example of water resource issues related to siting and construction is the clearing of natu- ral vegetation and excavation of natural soils, replacement of them with engineered fill and sub- grades, paved surfaces, and structures. These actions can physically impact water resources not only by reducing the extent of the water resource, but also through disruption of natural processes, reduction in function or quality of the water resource, and destruction of habitat for aquatic and terrestrial species. Siting and construction issues can be minimized by thoroughly evaluating project alternatives including relocating the project to an area where no water resources will be impacted. Depending on the project type, the range of alternatives will vary. For example, alter- natives for new or relocated runways would be more limited compared with a parking lot because of aeronautical design standards (i.e., orientation to the wind) that often limit the location of aeronautical facilities. An example of a water resource issue related to ongoing activities after construction is the alteration of natural storm water runoff drainage patterns and characteristics caused by changes to the surface features. Increased impervious area, vegetation removal, steeper slopes or regrad- ing, and flow diversion have the potential to increase runoff flows, decrease infiltration, increase erosion and sedimentation, increase flooding, and degrade water quality. Water quality may also be impacted from runoff associated with construction activities and long-term airport opera- tions. The disruption of natural drainage patterns through land use and drainage system design can introduce avenues for water resource contamination and other impacts that did not previ- ously exist under pre-development conditions, as well as destabilize soils and fragile land fea- tures that may have previously been at equilibrium with natural processes. It is recommended that prior to the initiation of planning activities, airport operators create a checklist that links projects to project characteristics, to effects on water resources, and, finally, to water resource issues that need to be managed. Worksheet 2 in Appendix A provides an exam- ple of a checklist to identify potential impacts on the basis of project siting and construction impacts and ongoing operations impacts. Tables 2 and 3 can be used for guidance in completing the checklist. The checklist results can be used to help assess the water resource issues for which core regulatory requirements should be derived and to provide an initial assessment of the water resource issues that may be problematic. 34 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

Establishing a Water Resource Issue Management Program 35 2.2.4 Defining Core Regulatory Requirements An additional component of the Water Resource Issue Information Catalog is a summary of the core regulatory requirements associated with water resource issues that might be relevant to the airport. Airport operators should use the information from the Water Resource Inventory and Project Characteristics Checklist as the means to iden- tify which Water Resource Issue Categories should have core regulatory requirements summarized. To summarize the core regulatory requirements for water resource issues at an airport, operators should be familiar with individual water resource–related regulations. Water resource regulations exist at federal, state, regional, and local levels to protect water resources and the many beneficial uses they provide. The regulatory protections address a variety of impacts to water resources, including the following: • Water resources such as lakes, streams, reservoirs, and groundwater aquifers are frequent sources of drinking water for humans and animal populations, as well as habitats for aquatic Characteristic Defining Features Potential Water Resource Issue Project Dimensions • Total project footprint • Length/width/shape • Depth • Surface water quality • Physical impacts to wetlands and other surface waters • Groundwater quality • Floodplains • Aquatic life and habitat Project Location • Proximity to coast • Demolition requirements • Proximity to existing wetlands • Proximity to existing streams • Topography • Proximity to existing endangered species habitat • Groundwater characteristics • Surface water characteristics • Coastal zones and barriers • Aquatic life and habitat • Floodplains • Physical impacts to wetlands and other surface waters • Groundwater quality • Surface water quality • Hazardous wildlife attractants Surface Characteristics • Final open water features • Final groundcover/pavement/ land use • Area of earthwork during construction • Surface water quality • Hazardous wildlife attractants Subsurface Characteristics • Utility connections required • Subsurface piping • Depth/excavation requirements • Physical impacts to wetlands and other surface waters • Surface water quality • Groundwater quality Table 2. Water resource issues potentially associated with project siting and construction characteristics. Key Notes The core regulatory requirements associated with each water resource issue category should be rela- tively similar from project to project. Documenting the core regulatory requirements for each category will add consistency to the approach and develop a greater depth of knowledge for the staff.

36 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning and terrestrial species. Degradation in water quality can endanger human health as well as neg- atively impact the health, population, and biodiversity of terrestrial and aquatic species. • Water resource impacts have the potential to decrease the scenic and recreational values of certain water resources, including rivers and coastal zones, with a potential for impacts to tourism industries and local economies. • Economic impacts can result when water resource degradation impacts fishing, agriculture, and other industries that depend on the water resource. • Property damage and loss of human life can result from flooding caused by impacts to storm water quantity, floodplains, and wetlands, as well as from increased storm damage caused by impacts to wetlands, coastal zones, and barriers. Regulations in the United States provide a variety of means to protect the beneficial uses of water resources, including numeric criteria defining the uses, narrative restrictions, prohibitions on activities and construction locations, and specific conditions limiting degradation of the resource. The regulations define the processes used by airports and regulations to assess water resource impacts and how mitigation for impacts must be addressed. Managing the regulatory environment for airports can be complex because regulations can exist at multiple governmental levels and contain ambiguities and conflicts that can have various eussIecruoseRretaWlaitnetoPserutaeFgninifeDcitsiretcarahC Project Dimensions • Total project footprint • Length/width/shape • Depth • Groundwater quality • Storm water quantity • Surface water quality • Hazardous wildlife attractants • Aquatic life and habitat Surface Characteristics • Surface type – Water – Land • Perviousness • Topography • Activities on surface when operational – Exposure to precipitation – Storm water storage – Fueling – Deicing – Cleaning/washing – Pesticide/herbicide application – Material storage – Maintenance – Parking – Treatment processes • Hazardous wildlife attractants • Aquatic life and habitat • Storm water quantity • Surface water quality • Groundwater quality Subsurface Characteristics • Activities below surface – Storm water conveyance onto project site – Underdrains – Fuel transmission – Material storage – Areas of contamination/ hazardous materials • Groundwater quality • Surface water quality Table 3. Water resource issues potentially associated with project ongoing activities.

interpretations by various stakeholders. In the end, there is no substitute for careful review of the applicable regulations and interpretation of their meaning by qualified environmental profession- als, legal counsel, and regulators for the specific potential impacts to water resources on a project. Prior to the detailed, project-specific analysis of regulatory requirements that must occur, how- ever, it can be valuable to airports to identify the core regulatory requirements for guidance in the early planning processes. Greater awareness of the core regulatory requirements prior to planning can reduce the risk of impacts to project function, airport operations, schedule, and cost. The core regulatory requirements for individual water resource issue categories should be rel- atively consistent from project to project at a given airport. Understanding those requirements can provide airports with greater facility in assessing issues that may arise and their effects on the development project planning process. Having a common understanding of the core regulatory requirements can save time and money at the start of project planning and can provide a more- informed means of screening initial project alternatives. The core regulatory requirements should include documentation of the following: • Potentially applicable regulations (federal, state, regional, and local); • Regulatory documents to reference; • Agencies with jurisdiction and regulator points of contact; • Regulated parameters; • Compliance requirements; • Submittal requirements for the regulatory approval process; • Mitigation criteria; and • Statutory timeframes. To assist in developing this understanding, flow charts illustrating the recommended steps for defining the core regulatory requirements are provided in each individual fact sheet in Appen- dix B. The flow charts are specific to the water resource issue. An example of one of the flow charts is provided in Figure 3. Documenting a summary of the core regulatory requirements for each water resource issue at an airport for a project can be a useful communication tool. An example of a summary sheet for core regulatory requirements is given in Worksheet 3 in Appendix B. 2.2.5 Creating a Mitigation Facility Inventory It is the goal of most stakeholders to avoid impacts to water resources if possible. It is hoped that implementation of the methods in the Handbook will facilitate a greater degree of avoidance. In cases where water resource impact avoidance and meeting project objectives are incompatible, impacts can be allowed if authorized by regulatory agencies with appropriate jurisdiction. Approval of impacts will typically require some form of mitigation to offset the loss of the water resource or reductions in its value. Mitigation can take many forms: there are typically hierarchies of preferred mitigation measures associated with individual regulations and regulatory agencies. The hierarchies include use of existing facilities specifically designed to support mitigation from multiple projects. At the earliest stages of planning, it is useful to have an understanding not only of the general mitigation requirements (obtained from documentation of the core regulatory requirements), but also of the mitigation facilities that might be available in the airport’s locale. It is recommended that operators identify these mitigation facilities for inclusion in the Water Resource Issue Information Catalog. Potential mitigation facilities to seek out include • Wetland mitigation areas specifically developed by airport operators to support multiple air- port projects; Establishing a Water Resource Issue Management Program 37

38 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning • Wetland mitigation banks approved by the USACE; • Stream mitigation areas approved by the USACE (these may be available within some wetland mitigation banks); • Regional storm water management facilities that can be used to manage storm water quantity compliance requirements from development projects; and • Publicly owned treatment works (POTWs) that can accept discharges of storm water or process wastewater. In addition to these facilities, airport operators may want to consider local waterways that might be suitable for stream restoration actions or for creation of conservation easements that would protect the streams from development in perpetuity (provided they do not create or enhance habitats attractive to wildlife hazardous to aviation). Figure 3. Example process for defining the core regulatory requirements for physical impacts to wetlands and other surface waters.

In the Mitigation Facility Inventory, the airport operators should document the following for each mitigation category: • Currently available capacity within the facility; • Permit requirements for use of the facility, including submittal requirements for permit applications; • Costs for use of the facility; • Copies of standard permit conditions and agreement terms; • Verification that facility is approved for mitigation of the affected water resource issue by the regulating agency; and • Timeframes associated with use of the facilities. 2.3 Water Resource Issue Management Plan A Water Resource Issue Management Plan is a document used to guide the process of managing water resource issues within the development project implementation process. The plan identifies the stakeholders who will be involved and the protocols, methods, and strategies that will be used. Some airports may want to include airport policies related to the subject matter in the plan. It is recommended that the general elements of the Water Resource Issue Management Plan be developed as part of the Water Resource Issue Management Program outside of the planning process. When planning processes are initiated, the plan should be modified to adapt to project-specific needs. Utilization of this strategy should provide an important level of consistency to the approach to water resource issue management through the ongoing implementation of multiple development projects. Individual elements of the plan are described below. 2.3.1 Project Management Roles and Responsibilities A well-defined and communicated program structure for managing water resource issues will reduce the potential for unnecessary project delays and costs. All airports have their own unique organizational, management, and personnel structures for development project implementation and water resource issue management. The uniqueness in management structures can be traced to a variety of factors, including the following: • Number and types of operations (e.g., hub, non-hub, cargo, general aviation, or military); • Staff resources and time commitments; • Organizational mission, policies, philosophies, and protocols; • Funding availability; • Number, distribution, and level of involvement of airlines; • Roles and relationships with tenants; • Use of airport staff or consultants; • Local regulatory structure, regulations, and involvement; • Regional and local attitudes and approaches toward environmental compliance, stewardship, and sustainability; and • Involvement of interest groups. Key Notes A well-thought-out and documented plan for how to coordinate between water resource issue man- agement and development project implementation will have a significant effect on reducing impacts to the project. Establishing a Water Resource Issue Management Program 39

The organizational structure for development projects can encompass a variety of stakeholders. Frequently involved stakeholders, their typical roles, and descriptions of their responsibilities are provided as follows. 1. Airports (5): • Airport Authority, Board, or Government Commissioners—responsible for administra- tion and development of the airport. • Airport Director—responsible for day-to-day operation of airport with authority over air- craft operations, personnel, finance, maintenance, construction, and community-relations matters. Involved in the planning process for airport expansion projects and capacity enhancement. Also responsible for compiling the annual airport budget. • Finance and Administration—responsible for financial matters including purchasing, personnel, facilities, and office management. Participates in fiscal planning and budget administration. • Planning and Engineering—responsible for supporting airport groups and activities with technical assistance for construction and development projects and industrial safety mat- ters. Also develops standards and performs reviews related to construction documents and contracts and industrial safety. • Environmental—many airports have a separate environmental department that tracks and manages environmentally related matters, including the acquisition of required per- mits and approvals; compliance with existing permits and regulatory conditions; response to environmental issues such as spills or contamination; coordination of operations and maintenance (O&M) related to environmental compliance, including compliance moni- toring and BMPs; development and maintenance of pollution prevention and spill control plans and programs; and coordination with other departments to review environmental considerations for development projects. • Operations—responsible for matters involving both airside and landside operations. Airside-related matters include airfield and airline activities, airfield safety, aircraft gate assignments, monitoring of airfield conditions, recommendation of procedures, and com- pliance with airside regulations, noise, and safety areas. Landside-related matters include security, access, parking, public safety, terminal use, and compliance with operational and security regulations. • Maintenance—responsible for the maintenance of all airport facilities including buildings, vehicles, and utilities, development of standards and policies for maintenance of these facil- ities, overseeing maintenance contracts and responsibilities, and coordinating and inspect- ing maintenance activities. 2. Airlines: • Properties/Real Estate Management—sits on the Airline and Airport Affairs Committee (AAAC) and plays the key role in the approval of airport projects affecting the airline and coordinates the airline’s other participants in the project. • Facilities Management—represents the airline in working with the airport on plans and construction of facilities affecting the airline. • Environmental Management—works with the airport’s environmental staff to address any environmental issues/impacts related to the project from an airline perspective. • Station Management—the airline’s eyes and ears on the day-to-day issues related to the project. Also coordinates cooperative efforts required of airline to accommodate the proj- ect such as relocation of activities during construction, and so forth. • Station Plant Maintenance Management—maintains the airline’s station facilities and interfaces with the airport regarding existing station-specific facility information. • Flight Operations—includes navigation management, flight safety management, runway and taxiway construction group management. There are several functions the flight oper- 40 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

ations group performs that deal primarily with accessing the impacts of airport projects on flight safety and changing the information in the pilot manuals regarding airport-specific changes resulting from projects. • Station Operational Certification and Compliance Management—manages the airline’s FAA compliance issues at the stations and will assess project impacts on that compliance. 3. Outside Consultants: • Development Project Planners—work with airport operators to assess capacity require- ments, lead assessment of development needs and alternatives, and prepare planning doc- uments such as Master Plans. • Development Project Engineers and Architects—prepare conceptual and detailed design of the development project features. Work with airport on integrating project design with existing airport operations. • Water Resource Issue Engineers and Scientists—understand details of environmental regulations, provide guidance on coordinating with regulatory agencies on permitting and compliance for individual water resource issues, consider mitigation options, and prepare conceptual and detailed design of controls and mitigation measures. • NEPA Consultants—assist the FAA and airport planners with project planning and scope; lead the preparation of Environmental Impact Statements (EISs), Environmental Assess- ments (EAs), or Categorical Exclusions (CatExs); direct data collection efforts; identify project alternatives; and conduct agency and public coordination. and 4. Outside Legal Counsel, 5. Construction Management Firms, 6. Commissioning Agents, 7. Contractors, and 8. Regulatory Agencies. Both development project implementation and water resource issue management have numerous actions that need to be executed. Matching the responsibilities for executing those actions within specific projects to the general project roles and responsibilities of the various stakeholders can be challenging at times. It is not unusual for projects to have gaps, ambiguities, and conflicts in responsibilities and among project roles. As part of the Water Resource Issue Management Plan, it is recommended that a template for typical roles and responsibilities be created for general use on development projects that include water resource issue management. Once planning is initiated for a particular project, the tem- plate can be used as a base from which project-specific roles and responsibilities can be defined. The definition of roles and responsibilities can be supplemented by protocols describing the interactions among the roles, including identification of points of contact, coordination meet- ings, protocols for information exchange, and means for addressing conflicts among stakehold- ers with differing priorities. This process might also benefit by establishing specific environmental and planning goals that are understood by all members of the project team. Worksheet 4 in Appendix A provides an example of how key roles and responsibilities can be documented. 2.3.2 Protocols for Managing the NEPA Process For all airport projects requiring federal approval, meeting the requirements of NEPA are an essential and overarching aspect of the planning process. An overview of the NEPA process is provided in Appendix C. For the purposes of effectively managing water resource issues associ- ated with development project implementation, it is crucial to define how the NEPA process will be executed as part of the Water Resource Issue Management plan. It is recommended that Establishing a Water Resource Issue Management Program 41

essential elements of the NEPA process be defined as part of the original Plan development. As individual projects are initiated, the plan for that project can be modeled on those essential elements and modified as needed for the specific project. This may improve the consistency of the NEPA process from project to project. In the context of water resources, the NEPA process includes an environmental review of a project’s (or pro- gram’s) impacts to water resources and an assessment of water resource mitigation, which may, for example, include storm water detention, wetland mitigation banking, and so forth. NEPA evaluation can be based on a less-detailed def- inition of a project than is needed in the permitting process. NEPA approval does not guarantee permitting approval. The NEPA process requires a clear understanding of the elements of a project, the purpose of and need for the project, an assessment of alternatives to the project, and an environmental review of the project’s effects on environmental resources—for example, a demonstration that all efforts to avoid and minimize impacts to water resources were considered. In terms of reviewing effects on environmental resources, a demonstration that a project meets all regulatory guidance, stan- dards, and thresholds and the provision of mitigation, if needed, are required under NEPA. Collection of environmental baseline or inventory data is often delayed until the NEPA process is underway. Virtually all development at an airport cannot occur without one or more federal actions, which triggers compliance with the NEPA. That compliance is demonstrated in the form of a CatEx, an EA, or an EIS. In all cases, the objective of the NEPA documentation is to identify whether the project would exert significant adverse effects on the environment and, where appropriate, identify steps necessary to mitigate adverse effects. If a Water Resource Inventory is assembled independently prior to the NEPA process, the scope of work necessary under NEPA can be streamlined because the understanding of the prob- able effect of a project on water resources would be advanced. However, to the degree that FAA participates in the funding of the NEPA process, the early Water Resource Inventory would likely not receive funding unless included in an FAA-funded effort. Refer to Section 2.2.2 for additional information on early planning and Water Resource Inventories. A key decision in the project timeline is whether to conduct permitting of individual water resource issues as part of the NEPA process. For instance, if a Section 404 permit is required, the USACE must also comply with NEPA before the permit can be issued. Often the FAA NEPA docu- ment can be and is used to meet the USACE NEPA needs. A decision by sponsors to include per- mitting in the NEPA process is usually based on the ability to prepare the permits using the level of project definition/design available at that point. FAA will typically only allow sponsors to prepare up to 25% project design before NEPA is complete, so as not to prejudice the project environmen- tal finding/approval. Depending on the water resource issues and their complexity, undertaking per- mitting during the NEPA process can slow the NEPA review, but also can shorten the time after NEPA before the permit is issued. Conversely, separating the processes can speed NEPA and, thus, enable the project to move further into design. However, should notable project changes occur during the remaining design (including permitting), the changes could require the NEPA process to be revisited. Therefore, the project team needs to weigh the risks of the two approaches. In the Water Resource Issue Management Plan, the basic approach to NEPA at the airport should be documented, along with key considerations to decide at the start of the planning process for individual projects. 42 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning Key Notes The project management team must define—in coordination with regulators—when permitting for individual water resource issues will occur relative to the schedule for the NEPA process. This will drive the determination of information needs and the schedule for development of design documents.

2.3.3 Protocols for Integrating Water Resource Issue Management and Development Project Implementation The final aspect of the Water Resource Issue Management Plan is defining the protocols, methods, and strategies for integrating water resource issue management with development project implementation. A recommended approach to this integration is presented in Section 3. The approach is based on the following elements: • Having sufficiently comprehensive and accurate information on which decisions are based; • Understanding the continual feeding of information back and forth between the water resource issue assessment and development project implementation; • Needing to understand compliance concepts independently for individual water resource issues; and • Grasping the importance of consolidating the effects of complying with multiple water resource issues on development projects. As part of the Water Resource Issue Management Plan, it is recommended that the guiding principles and execution methods for managing the individual water resource issues be defined. Establishing a Water Resource Issue Management Program 43

Next: Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process »
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TRB’s Airport Cooperative Research Program (ACRP) Report 53: A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning identifies appropriate responses to a variety of water resource issues affecting airport planning and development.

The handbook includes options for setting up a water resource management program and outlines the steps necessary to implement that program in response to local conditions.

The handbook also presents strategies for including water resource planning and management as part of a broader life-cycle planning and development process.

In addition, the handbook provides an overview of National Environmental Policy Act (NEPA) procedures that control environmental reviews affecting airport development.

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