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OCR for page 49
Strategies for Integrating Water Resource Issue Management with the Project Implementation Process 49 · 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