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

Chapter: Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process

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Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 47
Page 48
Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 48
Page 49
Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 49
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Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 50
Page 51
Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 51
Page 52
Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 52
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Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 53
Page 54
Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 54
Page 55
Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 55
Page 56
Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 56
Page 57
Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 57
Page 58
Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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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Page 59
Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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.
×
Page 59
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Suggested Citation:"Section 3 - Strategies for Integrating Water Resource Issue Management with the Project Implementation Process." 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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3.1 Introduction The information and overall protocols provided by the Water Resource Issue Information Cat- alog and Water Resource Issue Management Plan described in Section 2 provide the foundation for initiating the analysis of water resource issues in development projects. The information pre- sented in Section 3 provides strategies and recommendations for the management of water resource issues within the three primary phases of project implementation: Conceptual Planning, Detailed Planning, and Project Execution. In Section 3, the reader will be provided with • Identification of the four recurring elements that form the basis of an iterative approach to water resource issue management and development project implementation; • Description of the phases of development project implementations; and • Strategies and recommendations for actions to consider for each project phase. The information in Section 3 of the Handbook is complemented by the strategies and recom- mendations provided in Appendix B fact sheets for specific water resource issues. 3.2 Recurring Elements of Water Resource Issue Management at Each Phase During each project implementation phase, there are planning actions associated with devel- opment project implementation and planning actions associated with water resource issue man- agement. Understanding the relationship between those actions is crucial. In most cases, the relationship between development projects and water resource issues should not be a linear or one-time consideration: it is an iterative, cyclical process (see Figure 4.) As illustrated in Figure 4, information on the project characteristics informs the assessment of measures needed to achieve compliance with water resource issue regulatory requirements. Likewise, an understanding of the compliance needs feeds back information to the development project, potentially triggering revisions to the project. This process repeats itself in each project implementation phase. This iterative approach facilitates the optimization of the project planning and management process so that decisions can be informed by appropriate experts analyzing appropriate levels of water resource infor- mation at appropriate points in the timeline. The objective of the methodology presented herein is an iterative, small-scale exchange of information that better manages risk and cost as an alternative to a less frequent, large-scale exchange of information. The proposed iterative, 44 S E C T I O N 3 Strategies for Integrating Water Resource Issue Management with the Project Implementation Process Key Notes Throughout the life-cycle of a project, information must be exchanged regularly between those imple- menting the development project and those man- aging water resource issues.

small-scale approach requires a greater degree of coordination and probably additional finan- cial resources in the early stages of planning. The intent is that this investment of resources would reduce the risks to project function, costs, schedule, and airport operations as a whole. While each phase of development project implementation has its own unique needs for man- agement of water resource issues, the planning can be reduced to a common set of four steps that recur in each phase. The steps are shown in the corresponding inset as well as in Figure 2 (see Section 1.3.3). Strategies for Integrating Water Resource Issue Management with the Project Implementation Process 45 Recurring Steps in the Integration of Development Project Implementation and Water Resource Issue Management 1. Characterize the water resources and potential development project impacts on those resources. 2. Define/reassess the compliance requirements. 3. Assess the effects of complying with regulatory requirements for individual water resource issues on the development project. 4. Consolidate and assess the effects of complying with the full suite of regula- tory requirements for all water resource issues on the development project. Typically, each of these four steps occurs at each project implementation phase. The end result is an adaptive management system in which the implementation of the development project is adapted in response to information obtained from the management of water resource issues and vice versa. The work level and significance of the tasks will vary as the project progresses through- out the project implementation process. The four recurring steps are discussed in the following subsections. Recommendations for planning considerations and planning actions are provided for each element within the three development project implementation phases. It is not expected that those leading the planning efforts would necessarily perform these activities, but they can facilitate their execution. 3.2.1 Step 1: Characterizing Water Resources and the Water Resource Impacts from Development Projects The most fundamental aspect of planning for water resource management in development project planning is the characterization of the water resources. The characterization has two indi- vidual, but related, elements: 1. Characterizing the water resource as it exists on potential sites and 2. Characterizing how the development project will impact the water resource. PROJECT CHARACTERISTICS WATER RESOURCE ISSUE COMPLIANCE NEEDS Figure 4. Project and water resource issue relationship.

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 water–related 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, 46 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

• 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 Strategies for Integrating Water Resource Issue Management with the Project Implementation Process 47

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; 48 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

• Completing the appropriate level of environmental evaluation and agency and public coordi- nation required depending on the level or type of impact (e.g., impacts to wetlands of 1.5 acres or greater require preparation of an EA); • Developing appropriate mitigation alternatives and conducting appropriate agency and pub- lic coordination; • Understanding that NEPA approval does not guarantee or provide specific permit approvals; • Understanding the level of project refinement needed for NEPA approval versus for obtain- ing permits (e.g., NEPA processing can be based on conceptual plans such as 0%–25% design documents whereas permitting often requires greater detail); • Implementing changes in the project identified through more detailed design or other con- siderations determined in support of permitting can require reassessment of the project and consideration of additional alternatives under NEPA; • Recognizing that schedules looking to begin construction immediately post-NEPA approval must consider conducting concurrent permitting; and • Minimizing uncertainties in project definition, alternatives considered, and overall impacts requires advancing project design and operational assumptions earlier in the planning process. 3.2.3 Step 3: Assessing Effects of Compliance Requirements on Development Project for Individual Water Resource Issues The third step in managing water resource issues in development projects is assessing the effects of achieving compliance on the development project for individual water resource issues. As discussed in previous sections, the process of determining the compliance requirements establishes the restrictions and standards that must be met to protect the water resource. In some cases, the restrictions may be complex (e.g., effluent limits for multiple parameters or restrictions on flow rate and total discharge volume), while in others they may be straight for- ward (e.g., all impacted wetlands must be mitigated for). In any case, if impacts cannot be avoided, measures must be evaluated and approved to meet the restriction and mitigation requirements. The process for assessing the effects of achieving compliance on the development project is one of the more important steps in the entire water resource management process because it often involves the highest cost and has the greatest potential to affect the develop- ment project itself. Every effort should be made to avoid water resource impacts. Avoidance can carry a high proj- ect cost or, in some cases, can eliminate the ability of the project to meet its intended purpose. In those cases, controls (e.g., onsite treatment or storm water storage) or offsite mitigation might be necessary for the project to move forward. A well-informed cost analysis is vital in comparing these alternatives. The cost analysis should include not only capital costs, but also post-construction operating and maintenance costs as well as potentially lost revenue. Even when water resource issues are planned for and regulatory coordination is underway, there may be changes to the project design or regulatory requirements or other unforeseen con- ditions that arise during the course of project implementation. It can be difficult to know how best to respond to these changing circumstances while still meeting project goals and conditions of compliance. Airports should be advised that changes in project design, project functional plans, or siting may initiate a reassessment of compliance requirements. At early project implementation phases, it is easy to overlook “secondary” water resource issues that may be created by the mitigation measures needed to achieve compliance with the original development project’s water resource issues—for example, storm water controls may be needed to comply with development project impacts to storm water quantities. Implementation of those controls (e.g., a detention basin) might result in impacts to water resources, such as wet- lands. Permitting and mitigation for those impacts would be required. If these secondary water Strategies for Integrating Water Resource Issue Management with the Project Implementation Process 49

resource issues are not foreseen early in the planning process, they can contribute to difficulties getting timely NEPA approvals, affect the construction schedules for controls, and, in general, increase costs. 3.2.4 Step 4: Consolidating Water Resource Issue Effects and Revision of Project Effectively managing water resource issues in a planning project requires two important considerations: 1. Understanding and managing the effects of individual resource issues on development proj- ect implementation and 2. Integrating effects from multiple water resource issues into a cohesive planning strategy. As discussed in the previous steps, at each phase of the development project implementation, the individual water resource issue impacts need to be assessed and planned for independently because each issue has unique regulatory requirements and unique mitigations measures. While the concerns and planning items associated with individual water resource issues are a necessary baseline approach, an airport can most effectively improve its development project implemen- tation process by considering the synergistic effects of managing multiple water resource issues. One of the principal reasons why an integrated consideration of the causes and effects of mul- tiple water resource issues is recommended is because the same development project character- istics tend to cause multiple issues. For example, an increase in impervious area from a new runway can affect both surface water quality and storm water quantity. Even though those water resource issues are governed by different regulations, the controls and measures needed to achieve compliance can sometimes be considered jointly. This process involves first consolidat- ing the various water resource issues and the potential project impacts—consolidating manage- ment techniques where possible—and then developing an integrated planning strategy that incorporates these techniques. As airport operators begin to implement elements of water resource planning, they should begin to consolidate the potential effects on the project from multiple water resource issues. The consolidation will provide the information to assess the following: • Whether the combined effects from multiple water resource issues provide a more significant driver for avoiding impacts to water resources; • The options for implementing compromises in the development project functional design that benefit more than one impacted water resource or make compliance less challenging and less costly; • The need to change nonfunctional elements of the development project design to accommo- date controls and mitigation measures (e.g., storm water piping near a runway); and • The options for integrating controls from multiple issues (e.g., storm water quality and quan- tity management). Consolidation of considerations for the various water resource issues should include the following: 1. Project characteristics or features associated with issues—a review of project characteris- tics or features associated with the various issues may allow the identification of a particular project aspect that can be modified to reduce potential impacts. 2. Detailed steps required for compliance—a review of compliance requirements, including required permits or approvals, may reveal some synergy for related efforts and the need for coordination on issues that will be regulated by the same authority. 50 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

3. Information acquisition needs—the review of overall information acquisition needs can facilitate combined efforts for data collection and may provide further justification for fund- ing particular data collection efforts. Information acquisition needs for each step in the com- pliance process can also be tied to planning activities and estimated timeframes for data availability to facilitate development of a timeline or schedule that integrates development project planning activities and water resource management activities. 4. Potential need for controls or mitigation measures—a review of potential control options will provide an opportunity to look for multi-faceted solutions to multiple issues (e.g., a detention basin that meets both storm water quantity and surface water quality needs), as well as the potential for secondary issues associated with controls (e.g., hazardous wildlife con- cerns associated with detention basins). It will also be beneficial to coordinate land use and utility connections for various required controls. 5. Timeframes for compliance activities—the timeframes for various compliance activities, as coordinated with information acquisition needs and availability, will help to build the over- all compliance schedule. These timeframes will also help to identify critical path items and prioritize project activities as needed to minimize project impacts. 6. Potential cost implications to project—a review of the potential costs for complying with the various issues will illustrate the overall burden of regulatory compliance for the project as it is currently planned. In addition, potentially costly issues may become apparent as those that should be prioritized when it comes to planning efforts and resources. 7. Potential options for project modifications that may minimize issues—this step may shed light on any project features that are common to many of the issues, or particularly signifi- cant issues, and may warrant reconsideration or modification. Following the review and consolidation of the items above, airport operators may wish to revisit planned project features and characteristics to determine whether any changes may min- imize project impacts. This step would require reevaluation of the effects on individual issues and overall impacts to the project. Once airport operators have determined that further modi- fications would not be warranted to address the anticipated water resource issues, they may choose to proceed as planned and integrate elements of the items above into the overall project plan. A log of key compliance activities can be developed to allow planners to follow along with activities that will be performed by environmental staff or outside environmental consultants. As the project progresses into later phases, airport operators can track the progress of these activ- ities to keep informed of any obstacles as they arise or any issues that appear to be changing in significance. If and when project design conditions change, the water resource issues should be revisited and the planning strategy updated. If unanticipated impacts arise, any lessons learned should be documented to allow for the further adaptation of airport planning strategies for use on future airport development projects. 3.3 Conceptual Planning Phase Management Strategies 3.3.1 Development Project Management in Conceptual Planning Phase The Conceptual Planning Phase for airport development projects, as defined herein, is the phase in which development projects are conceived at a conceptual level to meet some need— such as long-term, airport-wide operational needs—based on aviation activity projections. Development projects considered in the Conceptual Planning Phase may include improve- ments to landside, airside, and airport support facilities. This phase may include planning efforts for more than one project, and it can include airport master planning, but also includes plan- ning for projects not typically included in a master plan. Strategies for Integrating Water Resource Issue Management with the Project Implementation Process 51

Airport master plans and other conceptual plans typically identify high-level airport improve- ment or expansion projects for a single airport, potentially with information from state or regional airport system plans as a basis. As described in the FAA AC 150/5070-6B, an airport master plan is a “comprehensive study of an airport and usually describes the short, medium, and long-term development plans to meet future aviation demand” (6). Airport master plans may vary significantly in scope and level of detail from one airport to the next, depending on the unique challenges and issues faced by individual airports. An airport master plan generally iden- tifies and considers several possible development alternatives to meet improvement or expansion goals, as well as the potential financial, socioeconomic, and environmental impacts associated with each alternative. A variety of other airport planning documents may be developed to describe conceptual planning efforts not associated with a master plan. Multiple stakeholders contribute to the conceptual planning process: representatives from air- ports and airport authorities, airlines, tenants, consultants, community entities, regulatory agen- cies, and other local entities that have an interest in the long-term development at the airport. The outcomes of the Conceptual Planning Phase include • Identification of capacity needs, • Concepts for means to achieve capacity needs and other airport development needs, • Intended project function, • Identification of potential sites, • Conceptual sizes and capacities for major project components, • Conceptual footprints and layouts of the major project components, and • Conceptual level opinion of probable cost. 3.3.2 Water Resource Issue Management in Conceptual Planning Phase The Conceptual Planning Phase is an ideal opportunity to identify and begin management of potential water resource issues since it is the time of maximum flexibility in project design and location. It is also the time when steps can best be taken to avoid significant issues later in proj- ect implementation. Important planning actions related to water resource issues in this phase include • Identifying the features for projects documented in conceptual planning efforts that might result in significant water resource impacts, • Using the Water Resource Inventory as a starting point and soliciting feedback from water resource experts on additional level of detail needed to characterize water resources for cru- cial development areas, • Performing, if necessary, risk-based cost analysis to justify additional data collection, • Revising project concepts and locations to avoid significant water resource impacts, • Revising project concepts and locations to minimize water resource impacts if they cannot be avoided, and • Identifying major control and mitigation features that might require significant infrastructure additions and land use such as detention basins or treatment facilities. The Conceptual Planning Phase is also the time to develop project-specific Water Resource Issue Management Plans based on the plan developed for base Water Resource Issue Manage- ment Program. The plan developed at this time can be adapted, expanded, and refined for indi- vidual development projects as the implementation proceeds. A significant question that airports face in this phase is the degree to which water resources and other environmental issues are considered. As discussed above, the upside to a more rigor- 52 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

ous assessment of water resource issues at this stage is the opportunity to revise the development project plan during a time of maximum flexibility. Revisions to the development plans at this time can reduce the potentially costly project revisions later in the implementation process. The downside to providing significant consideration to water resource issues at this phase is that the project characteristics may be subject to further change during later project phases and may require that water resource issues be reassessed at a later date—which may entail additional costs and possible schedule delays. Several factors need to be managed to contain costs while still pro- viding useful information: • Prioritizing the sites and alternatives for which water resource issues will be evaluated (as nec- essary, beyond the Water Resource Inventory discussed in Section 2); • Deciding upon the appropriate extent and level of detail for water resource issue assessment to be performed at this phase through use of risk-analysis techniques; • Understanding the sensitivity of the conclusions on the effects of water resource issue man- agement on development project implementation to the level of detail of water resource infor- mation that is acquired; and • Facilitating coordination between those considering water resource issues and those planning other aspects of the development project implementation. Another important factor in the Conceptual Planning Phase is establishing the mechanisms of coordination amongst stakeholders, including airport staff, airlines, consultants, regulators, and community entities. These stakeholders can play a large role in facilitating or complicating the management of water resource issues affecting airport development projects. A lack of con- sistent coordination can result in missed opportunities to combine efforts and can ultimately lead to project impacts if the project design or compliance measures are unacceptable to one or more stakeholders. The following stakeholder involvement strategies are recommended for consideration in development of overall water resource management strategies: • Defining roles and responsibilities. • Coordinating activities among airport staff and their representatives—a lack of coordina- tion among airport staff or groups, as well as consultants representing them, on simultaneous or consecutive development projects may lead to missed opportunities to share resources and collaborate on comprehensive solutions. Regulators are currently placing a greater emphasis on site-wide, cumulative water resource issues; a lack of consideration for these may compli- cate regulatory approvals. Inconsistent or uncoordinated regulatory submittals among mul- tiple airport projects can also cause regulatory delays. • Coordinating development and mitigation efforts with airlines—airlines have a vested interested in development projects from both a financial and operations perspective. The level of airline involvement at different airports and airport projects can vary, but developing a means to inform and seek input from airlines early in the project implementation process can reduce impacts to schedules and budgets late in the project. • Understanding and addressing public receptiveness—underestimation of potential public involvement or resistance can lead to unforeseen delays and design rework to obtain regula- tory approvals. Airports sometimes present design alternatives that could have been foreseen as potentially infeasible or challenging if public resistance over potential water resource issues had been better understood. Table 4 summarizes planning items and planning actions for the Conceptual Planning Phase that are frequently associated with each of the four recurring steps in assessing water resource issues in development projects. Strategies for Integrating Water Resource Issue Management with the Project Implementation Process 53

54 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning Step 1: Characterize Water Resource and Water Resource Impact snoitcAgninnalPmetIgninnalP Water Resource Data Acquisition • Obtain recommendations from water resources expert based on sensitivity analysis considerations • Assess cost and risk if sufficient information cannot be obtained from properties not owned by the airport • Update Water Resource Inventory Development Project Siting • Create prioritization plan for data acquisition if needed for multiple sites, based on likelihood of use • Develop mapping to superimpose development project layouts on water resources boundaries • Plan for acquiring water resources information on sites not yet owned by airport Timing for Data Acquisition and Analysis • Allow at least 6 months prior to the time the information is needed for use in the Conceptual Planning Phase • Coordinate master plan and water resource assessment timing Costs for Data Acquisition and Analysis • Consolidate data collection needs from various water resource categories to identify common data • Obtain quotations from qualified entities Stakeholder Coordination • Identify stakeholders, their areas of interest, and their desired level of engagement Step 2: Assess Compliance Requirements snoitcAgninnalPmetIgninnalP Applicable Regulations and Regulating Agencies for Identified Issues • Refer to Core Regulatory Requirements Worksheet Compliance Requirements Determination • Solicit key compliance requirements from assessment by water resource experts Timing for Actions • Initiate after initial siting of projects and after Water Resource Inventory has been updated • Complete prior to final siting on master plan Regulatory Coordination • Coordinate with regulators to clarify interpretations of regulations for permitting • Coordinate with the FAA to develop the NEPA processing strategy Stakeholder Coordination • Solicit feedback from stakeholders, including the NEPA team, to identify key water resource issues and potential compliance requirements Table 4. Planning items and actions for Conceptual Planning Phase.

Strategies for Integrating Water Resource Issue Management with the Project Implementation Process 55 Step 3: Assess Effects on Development Project from Individual Water Resource Issues snoitcAgninnalPmetIgninnalP Issue Avoidance • Assess whether any water resource issues can be avoided by changes to the project Potential Controls Outside of Project • Assess possible types and scope of compliance measures that wouldn’t directly affect project • Assess need for additional sites and property acquisition Potential Modifications to Project • Assess if project changes may be necessary to achieve compliance or reduce overall costs Potential Effects on Other Airport Operations • Qualitatively assess interactions with airport operations and among multiple development projects Timing of Actions • Initiate after significant water resource impacts are identified and compliance assessment is completed • Complete prior to finalization of master plan layout Regulatory Coordination • Coordinate with regulators for questions on viability of controls/mitigation Stakeholder Coordination • Present options for controls/mitigation measures Step 4: Consolidate Effects of Water Resource Issues on Development Project snoitcAgninnalPmetIgninnalP Issue Consolidation • Consolidate information on avoidance, controls, and modifications to achieve compliance from individual issues Issue Avoidance • Assess whether consolidated information presents a greater driver for avoidance than drivers from individual issues Potential Controls Outside of Project • Assess whether controls for multiple issues can be integrated Potential Modifications to Project • Identify project modifications that would benefit compliance for multiple issues • Compare benefits to reductions in project functionality Potential Effects on Other Airport Operations • Identify any combined effects of water resource impacts and mitigation on airport operations Timing of Actions • Initiate after compliance options for individual issues have been assessed • Complete before master plan finalization Regulatory Coordination • Coordinate with regulators and the FAA as appropriate on viability of mitigation Stakeholder Coordination • Present options for controls/mitigation Table 4. (Continued).

3.4 Detailed Planning Phase Management Strategies 3.4.1 Development Project Management in Detailed Planning Phase The Detailed Planning Phase, as defined in this Handbook, includes the activities that are asso- ciated with developing plans for implementing the development project concept. At this phase, the project retains a significant degree of flexibility, but the basic components of the project have been established. The outcomes of the Detailed Planning Phase include • Finalizing project function and capacity objectives, • Assessing and selecting the project site, • Developing a basis of design for all project components, • Developing the approach to project implementation, • Preparing layouts of project components, • Developing project schematic diagrams, • Identifying equipment needs, • Preparing opinions of cost, and • Assessing and securing the source of funding. 3.4.2 Water Resource Issue Management in Detailed Planning Phase The Detailed Planning Phase for development projects also corresponds to the time that man- agement of project-specific water resource issue compliance requirements frequently occurs, although the work can begin earlier during conceptual planning if determined in the Water Resource Issue Management Plan. This phase may include the following water resource man- agement actions: • Initiating NEPA activities, • Identifying and quantifying the presence of water resources on potential project sites, • Performing a detailed review of compliance requirements for individual water resource issues, • Initiating permitting and approval process for specific water resource issues, • Assessing the effort required to fully manage water resource issues, • Holding pre-permitting meetings with water resource regulatory agencies, and • Determining potential control and mitigation options. Table 5 summarizes planning items and planning actions for the Detailed Planning Phase that are frequently associated with each of the four recurring steps in assessing water resource issues in development projects. 3.5 Project Execution Phase 3.5.1 Development Project Management in Project Execution Phase The Project Execution Phase, as defined in the Handbook, includes the activities involved in final implementation of the development project once the site, layout, function, sizes, and capac- ities have been determined. At this point in the implementation process, the flexibility to change the project is significantly reduced. Effects on the following project aspects from unresolved water resource issues can be significant: • Detailed design, • Bidding, • Construction, • Commissioning and startup, and • Initiating operations. 56 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

Strategies for Integrating Water Resource Issue Management with the Project Implementation Process 57 Step 1: Characterize Water Resource and Water Resource Impact noitcAgninnalPmetIgninnalP Water Resource Data Acquisition • For each water resource issue, perform detailed review of applicable regulations using methodologies in Sections 2 and 3 of the fact sheets to identify data quality needed for regulatory approval • Perform gap analysis comparing data needs with data obtained in Conceptual Planning Phase Timing for Data Acquisition and Analysis • Complete 3 months before permit applications are due Costs for Data Acquisition and Analysis • Obtain quotations from qualified entities Stakeholder Coordination • Meet with stakeholders at start of phase Step 2: Assess Compliance Requirements noitcAgninnalPmetIgninnalP Permitting and Compliance Process • Initiate the NEPA process • Initiate development of the permit and approval application processes Identify Key Compliance Parameters • Solicit summary information from water resources experts on permits, deadlines, compliance parameters, and mitigation requirements Timing for Actions • If seeking to begin construction immediately upon receipt of NEPA approval, initiate permitting concurrent with the NEPA process • Understand that NEPA processing timeframes vary significantly based on anticipated project impacts and can range from a couple months to several years • Initiate permit application development process for individual water resource issues 6 to 12 months prior to planned submittal Regulatory Coordination • Conduct pre-permitting meetings with regulators for individual water resource issues and the FAA on NEPA processing • Verify required permits and mitigation criteria Stakeholder Coordination • Coordinate on permitting approach Table 5. Planning items and actions for Detailed Planning Phase. (continued on next page)

58 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning levellautpecnocehttasnoitacifidom Potential Effects on Other Airport Operations • Conduct detailed modeling and other assessments of effects Timing for Actions • Select controls and perform conceptual design in time to support NEPA documents Regulatory Coordination • Verify suitability of proposed avoidance and control measures for NEPA approval • Prepare control descriptions for NEPA documents Stakeholder Coordination • Coordinate with other development project teams, NEPA team, and airlines on scope and cost of controls and mitigation measures Step 4: Consolidate Effects of Water Resource Issues on Development Project noitcAgninnalPmetIgninnalP Potential Controls Outside of Project • Identify conceptual options for combining controls and mitigation measures Potential Modifications to Project • Coordinate integration of project design with design of controls Potential Effects on Other Airport Operations • Identify infrastructure or operational changes needed to manage project impacts Timing for Actions • Select controls and perform conceptual designs in time to support NEPA documents Regulatory Coordination • Verify suitability of proposed avoidance and control measures for NEPA approval • Prepare control descriptions for NEPA documents Stakeholder Coordination • Coordinate with other development project teams, NEPA team, and airlines on scope and cost of controls and mitigation measures Step 3: Assess Effects on Development Project from Individual Water Resource Issues noitcAgninnalPmetIgninnalP Potential Controls Outside of Project • Select and design controls at the conceptual level Potential Modifications to Project • Make decisions on and design project Table 5. (Continued).

3.5.2 Water Resource Issue Management in Project Execution Phase The Project Execution Phase for development projects corresponds to the time that the water resource issue management associated with construction is completed and the operational man- agement of water resource issues commences. The following water resource–related activities typically occur during the Project Execution Phase: • Completing the NEPA process; • Submitting permit applications and approval documentation for individual water resource issues; • Coordinating with regulators on status and timing of actions; • Receiving permits and approvals; • Modifying development project design to accommodate water resource compliance requirements; • Evaluating whether project design modification requires NEPA reassessment, consideration of alternatives, or additional mitigation requirements; • Designing, bidding, permitting, constructing, commissioning and starting up the control and mitigation measures needed to accommodate water resource compliance requirements; • Initiating monitoring of mitigation measures; and • Initiating operation of water resource issue control systems. Table 6 summarizes planning items and planning actions for the Project Execution Phase that are frequently associated with each of the four recurring steps in assessing water resource issues in development projects. Strategies for Integrating Water Resource Issue Management with the Project Implementation Process 59

60 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning Step 1: Characterize Water Resource and Water Resource Impact noitcAgninnalPmetIgninnalP Information Types • Assess new data needs based on regulator review of permit applications Level of Detail in Data Acquisition • Plan for detailed collection for missing data to support design Timing for Data Acquisition and Analysis • Complete by start of detailed design Costs for Data Acquisition and Analysis • Obtain quotations from qualified entities Stakeholder Coordination • Meet with stakeholders at start of detailed design and construction Step 2: Plan Items and Actions for Assessing Compliance Requirements noitcAgninnalPmetIgninnalP Permit Conditions • Review final permit conditions from regulators and mitigation commitments in NEPA approval and assess significance • Submit applications for controls Timing for Actions • Coordinate submittal dates permits and design development level • Coordinate permit effective dates with construction schedule Stakeholder Coordination • Obtain input and review on proposed permit conditions Step 3: Plan Items and Actions for Assessing Effects on Development Project from Individual Water Resource Issues noitcAgninnalPmetIgninnalP Controls Outside of Project • Final design and construction • Submit applications for implementation of controls Timing for Actions • Coordinate submittal dates for control permits and design development level Regulatory Coordination • Meet with agencies to verify controls and permit submittal requirements Stakeholder Coordination • Coordinate among design, construction staff, and representatives for other projects Step 4: Plan Items and Actions for Consolidating Effects of Water Resource Issues on Development Project noitcAgninnalPmetIgninnalP Design of Controls and Mitigation Measures • Ensure coordination among various design entities Timing for Actions • Coordinate submittal dates for control permits and design development level Regulatory Coordination • Meet with agencies to verify controls and permit submittal requirements Stakeholder Coordination • Coordinate among design, construction staff, and representatives for other projects Table 6. Planning items and actions for Project Execution Phase.

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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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