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46 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning The information acquisition and assessments related to these characterizations may occur in all three project phases. Decisions on the type and level of detail of information that is acquired at each phase in the project are some of the most important decisions in the project implemen- tation process. The characterization of water resources in the initial project implementation stages should build upon the Water Resource Inventory developed for the Water Resource Issue Information Catalog. Once initial information on potential development project characteristics and sites is available, a water resource expert should be consulted to assess the types of data and level of detail for the data that are needed to form a sound basis for decisionmaking. The required data should then be compared with available information (from the Water Resource Inventory, if possible) to assess gaps in the database. From there, cost quotations can be solicited from water resource issue experts for field data acquisition, analysis of the data, and updating of the Water Resource Inventory. To manage costs, airports may want to prioritize the sites that are likely to be used so that data collection efforts can be reduced. Sites with particularly challenging envi- ronmental conditions may also receive a higher-priority designation. Once the water resources on the likely sites are documented, the layouts for the development projects can be overlaid on mapping to identify the likely areas of water resources impacts. Coordination of timing of the project implementation process and acquisition/analysis of water resource data is crucial. Information acquisition for water resource issues to supplement the baseline Water Resource Inventory should begin when initial concepts for site layouts are known. Conversely, final siting of development projects for master plan documents needs to be timed so that plans can be informed by the water resources analysis. To properly time these actions, planners and project managers should solicit feedback from water resource experts on the schedules necessary to complete the various tasks. Crucial needs for information acquisition and exchange that might delay tasks should be identified. When characterizing water resource impacts, it is important to understand that some water resource issues--especially storm waterrelated issues--can touch many areas of an airport. Often times, water resource issues are examined within the context of a single development proj- ect. Development decisions, and the mitigation measures associated with compliance for those specific projects, can often have unintended consequences on areas of the airport that do not appear to be directly related to the development project. This situation frequently occurs, for example, when the effects of changes in storm water quantities are only addressed within the con- fines of the project's site or drainage area. Limiting the consideration of storm water effects to the development project areas can potentially create flooding issues in other airport drainage areas and can also handicap storm water management options for other development projects. 3.2.2 Step 2: Defining Compliance Requirements for Individual Issues It is important that planners and other decisionmakers direct qualified personnel to assess the detailed requirements for demonstrating compliance with water resource regulations. The com- pliance assessment can build upon the core regulatory requirements documented in the Water Resource Issue Information Catalog. Communication of the key results of the compliance assess- ment process to the stakeholders is crucial. Qualified experts should perform the review of the compliance requirements based on the potential water resource impacts. In communicating a summary of the compliance requirements with stakeholders, the following should be provided for each of the relevant water resource issue categories discussed in the fact sheets in Appendix B: Regulating agency, Applicable regulations, Regulated parameters,

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Strategies for Integrating Water Resource Issue Management with the Project Implementation Process 47 Basis of mitigation, Required permits and approvals, Estimated time to complete permit and approval applications, Information needed to complete permit and approval applications, Information exchange needed with stakeholders, Statutory deadlines for submittal and review, Plan for coordination with regulatory agencies, Considerations for regulatory review time, and Quotations for preparing permit and approval applications. The detailed analysis of compliance requirements can occur in the Conceptual Planning Phase, but typically occurs during the Detailed Planning Phase. Permit application associated with controls and mitigation measures may occur in the Project Execution Phase as design doc- uments may be needed to support permit applications. As discussed earlier, the timing for the review of compliance requirements and preparation of permit applications must be coordinated with the NEPA process. Characterizing the compliance requirements associated with water resource issues can be a complex process especially if multiple issues and regulations are involved. In addition to federal regulatory issues, there may be significant variation in state, regional, and local requirements due to unique localized water resource concerns and priorities. Familiarity with existing regulatory conditions and priorities for local issues in advance of development planning can streamline the process for managing water resource issues as well as minimize potential project impacts such as cost and schedule implications. Guidance is provided within the individual fact sheets for the compliance assessment process. Selecting the time to coordinate with regulators is another important decision. While most regulators emphasize the importance of early communication, it is also true that the airport should have a basic understanding of the issues and compliance requirements prior to any detailed discussions with regulators to make those discussions more fruitful. It may also be ben- eficial early in the process to identify any pre-existing permits, regulatory agreements with these agencies, and past regulatory issues at the airport. The decision on when to initiate regulatory coordination must be made on a case-by-case basis and may involve an assessment of the signif- icance of potential water resource issues and the complexity of the permitting process. Establish- ing relationships with particular agency contacts can be extremely helpful when trying to identify regulatory requirements and coordinate reviews. Once communication with regulators has been established, it is crucial to maintain contact at appropriate points in the process and seek to have a mutual understanding of needs regarding information, submittals, and schedule. Because of budgetary challenges in regulatory agencies, it would also be informative to have a common understanding of principle regulatory contacts and their availability to work with the airport in the compliance process. This is crucial--one of the biggest unknowns in the development proj- ect implementation process is the time required for regulatory review. Airport operators may also benefit by consulting with regulators and their resource agencies during the identification and selection of controls. Regulators and their resource agencies often have significant insight and guidance to offer with regard to water resource issue management and may be able to offer creative suggestions for controls or project modifications that will meet project needs. They may also be able to provide feedback on airport-identified conceptual con- trols and project modifications before significant effort has been invested in design. Airports should seek consultation from water resource experts on the permits and agencies that are likely to be crucial. Because of the challenges in predicting regulatory review time, enti- ties having experience with crucial agencies on similar projects should be sought. These entities

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48 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning may also be able to provide guidance on regional or cultural perspectives on water resource impacts. Regions with more restrictive environmental regulations, less historical tolerance for impacts, and particular geographical features (such as coastal areas) may be more reluctant to approve airport projects affecting water resources than regulators in other regions. In these regions, it is especially important to have community involvement and support. It is also impor- tant to get input from regulatory officials early on in the process to find out whether preferred alternatives are likely to face extreme permitting challenges. Representatives from other airports can also be consulted to share experiences on compliance challenges. This could include insight on the timeframe for agency reviews when the airports share a common regulator. Information gathered at this stage may be able to provide insight as to the submittal require- ments for permit applications, including the level of design completion required for different permits. The level of design completion required to support permit submittals can vary widely by water resource issue, by regulatory agency, and by project. Approximate rules of thumb for design documentation required at various planning stages include Initiation of discussions with regulators--in many cases, it is necessary to have basic con- ceptual information on a project and potential impacts determined before meaningful discus- sions can occur with regulatory agencies. This would include conceptual level capacities, footprints, potential controls, and potential capacities of control measures. This information should be available in the Conceptual Design Phase. Submittal of permit applications to individual agencies--the level of design completion required by agencies with jurisdiction over a particular water resource issue can vary widely. For example, management of storm water quantity issues requires a detailed understanding of the development project surfaces, drainage pathways, and drainage system piping. In that case, an agency may require development project designs that are 75% to 100% complete (expressed as the percent completion of the detailed design) before considering permit appli- cations to be complete. For other water resource issues such as construction in floodplains, only knowledge of the footprint of project impacts relative to the 100-year floodplain bound- aries may be needed to describe the impacts. The level of design completeness that is needed for individual permits and approvals can be an important factor in determining whether permitting occurs concurrently with or subsequent to the NEPA process. Completing the NEPA process is a prerequisite to the federal action (such as the Airport Layout Plan [ALP] approval or federal funding.) A summary of the NEPA process is provided in Appendix C. The following are considerations crucial to an effective NEPA process: Maintaining coordination with the lead agency on the NEPA process, which is often the FAA; Coordinating with other regulatory agencies with authority to provide specific permits and approvals; Using FAA's staff experience on water resource issues and working relationships with the reg- ulatory agencies; Coordinating with airport safety personnel to maintain compliance with FAA hazardous wildlife attractant guidelines; Developing a clear project definition and project purpose and need on why a water resource must be impacted and how water resource issues and impacts are being addressed; Demonstrating that the analysis has been exhaustively evaluated for project alternatives that minimize or avoid impacts to water resources; Demonstrating that the project can/will meet all regulatory requirements such as accommo- dating increased storm water runoff, minimizing onsite storage (e.g., basins must drain within 48 hours per FAA guidance), meeting outfall regulatory standards, and so forth;