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

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1.1 Introduction and Background As the aviation industry evolves in response to societal changes including air travel demand, con- tinued implementation of airport development projects is a virtual certainty. Airport development projects are undertaken for a wide variety of reasons, ranging from the replacement of aging infra- structure to the need for additional capacity. Implementing an airport development project can be a complex exercise that, in some cases, takes many years and costs hundreds of millions of dollars. The exercise can involve many stakeholders, both internal and external to the airport organization. During implementation of a development project, project planners and project managers must balance a multitude of considerations: • Costs, revenue, and funding; • Project capacity and functionality; • Regulatory compliance; • Sequence and schedule; • Airport policies and operations; and • Stakeholder concerns and objectives. The timing and extent to which the issues associated with each consideration are assessed can have a profound impact on meeting the project’s objectives. Some of the more crucial and complex aspects of a project that stakeholders must consider are the issues associated with managing water resources that are potentially impacted by the devel- opment project. The need to manage “water resource issues” is created when airport stakeholders identify potential water resource impacts and determine the regulatory requirements associated with those impacts. This Handbook examines the potential consequences of insufficiently addressing water resource issues and provides guidance for managing these issues: • Greater overall project cost, • Missed schedule milestones, • Changes to project functionality, • Compromised airport operations, and • Greater compliance risk. The guidance is designed to facilitate the management of water resource issues within the context of the development project implementation process. Managing water resource issues for a development project is ultimately a site-specific exercise. Still, there are many commonalities in managing various types of water resource issues across the 1 S E C T I O N 1 Handbook Overview

industry that can be synthesized to provide guidance for individual projects. The approach described in this Handbook is derived from the experiences of multiple types of stakeholders in managing water resource issues at airports across the aviation industry. It provides guidance based on commonalities in approaches to individual projects that can form a framework for addressing site-specific issues. The Handbook approach is designed to facilitate sound decisionmaking based on reliable information, as well as effective coordination between management of water resource issues and management of the development project throughout the life-cycle of the project. To be most effective, the foundation for decisionmaking and coordination must be established at the earliest stages of the project planning process. A principal objective of early planning is to iden- tify project alternatives that avoid water resource impacts. If avoidance is incompatible with project objectives and resources, early planning will facilitate identifi- cation of project alternatives that minimize impacts to water resources while still meeting project objectives. Early planning provides an essential baseline for improv- ing the effectiveness of identifying, understanding, commu- nicating, coordinating, and ultimately finding solutions for water resource issues that are satisfactory to the various proj- ect stakeholders. Deferring sufficient consideration of water resource issues until late in the process creates a cascade of project management problems, including project regulatory processing and implementation delays. A more structured approach facilitates an early exchange of crucial information between personnel managing water resource issues and those managing the larger development project planning and implementation. This type of approach can lead to bet- ter decisionmaking and fewer unexpected project effects. The Handbook considers this situation through the lens of seven different categories of water resource issues: 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. Assessment of water resource issue management by examining individual categories of issues allows commonalities and important differences to be identified. Effectively synthesizing man- agement of those issues with the overall project management can reduce the risk of long-term impacts to the development project and provide for more efficient project implementation. 1.2 Handbook Objectives The Handbook provides guidance to stakeholders involved in development project planning and to those responsible for management of the associated water resource issues. The Handbook content is drawn from industry experience, existing reference documents, case studies, and con- sideration of techniques that can improve the effectiveness of water resource issue management in development project implementation. 2 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning Keys to Reducing Negative Consequences of Insufficient Water Resource Management in Development Projects • Recognizing the importance of managing water resource issues • Early planning to identify project alternatives with minimal impact on water resources • Employing a structured approach to coordinating project and water resource management through- out project life-cycle • Considering input from stakeholders on the right issues at the right time

Guidance Principles for Management of Water Resource Issues in Airport Development Projects • Using a Water Resource Issue Management Program provides a management structure for water resource issues on all airport development projects. • Using a Water Resource Issue Information Catalog provides a common baseline of airport-specific, water resource–related information. Handbook Overview 3 The overarching objective of the Handbook is to facilitate implementation of development projects in a way that protects water resources while minimizing the effects of water resource issue management on the project function, schedule, and costs and on airport operations. To support this objective, the Handbook promotes consideration of these issues through the structure of a Water Resource Issue Management Program (Program). An individual airport’s Program will facilitate the early collection of baseline information needed to support decisionmaking and the development of method- ologies needed for decisionmaking as issues are identified on individual projects. The approach promotes a “cradle to grave” strategy for integrating the management of water resource issues into the development project implementation process. The strategy is applicable from initial conceptualiza- tion of the project through completion of construction and startup of the project’s operations. The Handbook is not intended to be a comprehensive reference for all potentially applicable water resource regu- lations. The number of regulations, complexity of individ- ual regulations, site or state-specific nature of permitting, and ongoing evolution of the regulatory environment lim- its the practicality of presenting a comprehensive review of potentially applicable regulations. As such, the regulatory material presented in the Handbook is not suitable as a substitute for actual review of the regulations. Appropriately qualified personnel will need to specifically identify and review the regulations applicable to their project to fully assess compliance requirements. The potential stakeholders involved in water resource issues and the project implementation process are • Various airport departments, • Airlines, • Airport tenants, • Regulators/government officials, • Consultants, • Construction contractors, • Interest groups, and • The public. Use of the Handbook can provide value to both individual project stakeholders and to the project team as a whole. As with any project, stakeholders will have some common objectives and some objectives specific to their own needs. It is hoped that use of the Handbook will pro- vide a focal point for a structure, process, and language through which stakeholder needs and objectives can be better communicated such that overall project objectives can be more effec- tively met. To that end, the primary guiding principles found in the Handbook and recom- mended to stakeholders are described in the box following. Handbook’s Value in Managing Water Resources in Development Project Implementation • Guidance for developing a planning structure • Information to increase understanding of issues • Tips for more effective management of the issues • Common frame of reference for project stake- holders

1.2.1 Handbook Structure The Handbook is structured as follows: 1. Guidance Summary. Section 1.3 summarizes the key elements presented in the Handbook and its appendices. This summary may be particularly applicable to those interested in planning- level guidance on integrating development project implementation and water resource issue management. 2. Water Resource Issue Management Program Implementation. Section 2 provides detailed guidance on establishing a Water Resource Issue Management Program to provide baseline information and guiding protocols for addressing water resource issues in development proj- ect implementation. 3. Integration Strategies. Section 3 provides detailed guidance on specific methods and strate- gies for integrating the management of water resource issues and development project imple- mentation through the life-cycle of the development project. 4 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning • Recognizing that the management of water resource issues and development project implementation is a “cradle to grave” process is important. An ongoing, iterative exchange of information between water resource issues and develop- ment project management reduces the likelihood of significant disruptions to project schedule and design. • Understanding project-specific water resource issues and regulatory require- ments and consulting with environmental specialists having experience in those issues and regulations early in the process is an effective means to reduce nega- tive effects on development project function, schedule, and cost. • Making an early assessment of water resource issues will require allocation of funds earlier in the project implementation process. Comparing the costs of early water resource issue assessment to the financial and operational risks of not addressing water resource issues until later in the project implementation process is advised. • Tailoring an airport’s Water Resource Issue Management Program to site-specific considerations, protocols, and available resources within the over-all Program framework is best. The site-specific nature of water resources, development proj- ect impacts, and water resource regulatory requirements do not lend themselves to a one-size-fits-all approach to water resource issue management. • Establishing early in the process a common understanding among stakeholders as to the approach, protocols, roles, terminology, and communication methods to be used in assessing water resource issue management and development proj- ect implementation is important. Perspectives will likely vary significantly among stakeholders on development project implementation and water resource issue management priorities and processes. • Deciding whether to complete permitting for individual water resource issues inside or outside the National Environmental Policy Act (NEPA) process timeline is an important scheduling factor. Establishing the factors driving the decision, and coordinating with stakeholders on that decision is crucial.

Handbook Overview 5 4. Supplementary Worksheets. Documentation of the findings of the planning process is important. To help illustrate how key information collected early in the planning process can be documented, four example worksheets have been included in Appendix A: • Worksheet 1: Project Roles and Responsibilities • Worksheet 2: Project Characteristics and Water Resource Effects • Worksheet 3: Summary of Water Resource Inventory Information for Potential Site 1 • Worksheet 4: Summary of Applicable Core Regulatory Requirements 5. Water Resource Issue Fact Sheets. Fact sheets are provided in Appendix B for the following seven individual water resource issue categories: • Fact Sheet 1: Physical Impacts to Wetlands and Other Surface Waters • Fact Sheet 2: Surface Water and Groundwater Quality • Fact Sheet 3: Storm Water Quantity and Floodplains • Fact Sheet 4: Hazardous Wildlife Attractants • Fact Sheet 5: Aquatic Life and Habitat • Fact Sheet 6: Coastal Zones and Barriers • Fact Sheet 7: Wild and Scenic Rivers 6. Overview of the NEPA Process. Appendix C provides an overview of the NEPA process and guidance on coordinating this process with airport development planning and the manage- ment of water resource issues. 1.2.2 Handbook Use The guidance provided in the Handbook is not intended to be a form-fitting procedure for water resource issue management at every airport for every development project; it is intended to provide structure, ideas, tips from the experience of others, and concepts that can be adapted by staff at individual airports of all sizes in ways that fit their organizational needs. Full imple- mentation of the Water Resource Issue Management Program and methods identified in the Handbook—adapted to an individual airport’s needs—may be a valuable tool for some facilities. In other cases, airport operators and other stakeholders may simply identify insights from the Handbook for use on specific projects. This section has been developed to provide users with guidance on general use of the Hand- book as they craft their site-specific means of managing water resource issues in development projects. General tips on use of the Handbook are found in the adjacent inset. How to Use the Handbook 1. Review basic elements of recommended approach in Figure 1 and Table 1 (see end of Section 1.2.2). 2. Determine elements of recommended approach that will be used on the project. 3. Use material in Section 2 for guidance in establishing the Water Resource Issue Management Program prior to project planning. 4. Use the worksheets in Appendix A for examples of how to document key findings. 5. Use Fact Sheets in Appendix B to assist in understanding and approaching individual water resource issue categories. 6. Use NEPA guidance in Appendix C to assist in determining the relationship between the project development, compliance with individual regulatory issues, and NEPA compliance.

Guidance on use of the example worksheets found in Appendix A is shown in the correspond- ing inset. The worksheets are intended to provide example tables for how to track key informa- tion on the development project and water resource issues. It is envisioned that airport and project-specific worksheets could be passed along to stakeholders as a means of communicating key issues and facilitating decisionmaking. 6 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning 7. Review the information in Section 3 to provide guidance on the process of integrating water resource issue management and development project management at the various project implementation phases. How to Use Worksheets to Support Project Documentation 1. Review example worksheets in Appendix A. 2. Create site or project-specific template using worksheet structure as basis. 3. Document key information as process progresses on worksheet. 4. Provide worksheets to project stakeholders to aid information exchange. Guidance on the use of the Water Resource Issue Fact Sheets in Appendix B is found in the corresponding inset. The fact sheets in Appendix B are designed to provide information and guidance on specific issues. The level of detail in Appendix B should be useful to anyone seeking an in-depth understanding of particular issues. For those more interested in an overview, impor- tant information from the fact sheets is summarized in Section 1.3.4. How to Use Fact Sheets for Individual Water Resource Issue Categories 1. Obtain an overview of the category. 2. Identify potentially applicable laws and regulations. 3. Seek guidance on procedures for managing the water resource issue. 4. Extract tips for dealing with specific aspects of the water resource issue. How to use the NEPA guidance provided in Appendix C is found in the corresponding inset. The guidance is intended as a supplement to other available NEPA guidance including the FAA’s Environmental Desk Reference for Airport Actions (1). The guidance in Appendix C focuses on interaction of the NEPA process with the development planning process and the compliance process for regulatory requirements associated with individual water resource issues. Figure 1 and Table 1 provide a means of linking the recom- mended sequence of planning and management activities to their referenced locations in the Handbook. Figure 1 illus- trates the sequence of activities that form the core of the approach recommended in the Handbook. Table 1 identifies the locations within the Handbook and appendices where relevant information on the main recommended activities can be found. How to Use NEPA Guidance 1. Review Appendix C. 2. Coordinate information in Appendix C with other sources of NEPA guidance. 3. Look to NEPA guidance as specific issues come up during project.

Handbook Overview 7 How to Use Figure 1 1. Review the five primary activities in the process outlined in Figure 1 prior to the start of development project planning. 2. Compare the primary activities in the recommended process to those used at the facility. 3. Review the support activities associated with each of the five primary activities. Identify the activities that may be executed, and align the support activities with the primary activities for the airport’s process. 4. Reference Table 1. How to Use Table 1 1. From Figure 1, identify the primary and support activities that the airport and project will implement. 2. Refer to Table 1 to find the specific parts of the Hand- book to consult for guidance. 3. Review the referenced sections of the Handbook. Figure 1. Primary and support activities recommended for managing water resource issues on airport development projects.

koobdnaHseitivitcAtroppuSytivitcAyramirPpetS Reference Worksheet Reference 1 Review Summary of Handbook Guidance 4.3.1noitceSecnadiugdednemmocerhtiwrailimafemoceB 2 Prepare Water Resource Issue Information Catalog (Ideally, catalog is completed for entire airport for use on multiple projects, but it can be project- specific.) 2.2.2noitceStropriaehtrofyrotnevnIecruoseRretaWpoleveD Appendix B Fact Sheets 3.2.2noitceStropriaehtrofyrotnevnIytilicaFnoitagitiMeraperP Appendix B Fact Sheets Review project characteristics typical of the airport’s projects Section 2.2.4 5.2.2noitceStropriaehtrofstnemeriuqeryrotalugererocenimreteD Appendix B Fact Sheets Worksheet 4 3 Develop Water Resource Issue Management Plan for the Project 1teehskroW1.3.2noitceSseitilibisnopserdnaselorcificeps-tcejorptnemucoD 2.2.2noitceS)s(etistcejorprofyrotnevnIecruoseRretaWetadpU Appendix B Fact Sheets 3.2.2noitceSyrotnevnIytilicaFnoitagitiMetadpU Appendix B Fact Sheets Define key project characteristics for the site that might affect water resources Section 2.2.4 Appendix B Fact Sheets Worksheet 2 Eliminate from consideration water resources at sites that will not be affected Section 2.2.4 Appendix B Fact Sheets Worksheet 3 Assess and decide upon protocols for managing the NEPA process for water resource issues that need to be considered Section 2.3.2 Appendix C NEPA Guide Define the protocols for managing the integrated assessment of water resource issues and project implementation Section 2.3.3 Appendix B Fact Sheets 4 Perform Activities Associated with Conceptual Planning Target data collection based on initial cost and project risk Section 2.2.2 Identify and characterize specific water resource issues on sites Section 3.3 Determine project alternatives and consider water resource issue impacts Section 3.3 ediuGAPENCxidneppAtcejorPehtnoAPENothcaorppAenimreteD 5 Perform Activities Associated with Detailed Planning Identify permit and permit schedule needs for specific water resource issues Section 3.4 Acquire site-specific field data to support permitting and design Section 3.4 4.3noitceSsevitanretlalortnocdnanoitagitimpoleveD ediuGAPENCxidneppAnoitatnemucodAPENetelpmoC 4.3noitceSsisylanadnanoitisiuqcaatadnodesabtcejorptpadA 6 Perform Activities Associated with Project Execution Reassess water resource issues based on detailed siting and design analyses Section 3.5 Complete permit applications for individual water resource issues Section 3.5 Modify project as necessary based on regulatory approval and feedback Section 3.5 Table 1. Sections associated with each recommended water resource issue management step.

Handbook Overview 9 1.3 Summary of Handbook Guidance 1.3.1 Overview of Guidance to Planners One of the key stakeholder groups in the management of water resource issues in the project implementation process is the leaders in the planning of the development project. The roles and responsibilities of the personnel involved in the development project planning process can vary widely from one airport to another. The degree to which these individuals are involved with and/or knowledgeable of the details of water resource issue management can also vary widely. For those who are seeking a greater understanding of the key recommended actions found in the Handbook and for those who do not have the opportunity for a detailed review of the Handbook, an overview of the recommended actions is provided below. Overview of Recommended Actions for Planning Personnel Planners should consider the following actions to promote a more effective man- agement of water resource issues in the development project implementation process. 1. Prior to conceptual planning: • Define, with the project management team, the responsibilities and protocols for coordinating information exchange among planners, environmental spe- cialists, and other stakeholders; • Request information from environmental compliance specialists that defines existing water resources on the site and potentially applicable regulations; and • In consultation with environmental compliance specialists, define the timing and protocols for managing the NEPA process and the process of obtaining permits for individual water resource impacts. 2. During the initial conceptual project layout and identification of potential sites: • Ask environmental compliance specialists to identify potential water resource issues for the selected sites; • Coordinate with environmental compliance specialists to identify opportuni- ties to avoid water resource impacts; • Coordinate with environmental compliance specialists to develop conceptual alternatives for minimizing water resource impacts where impacts cannot be avoided; and • Facilitate documentation of alternatives for avoiding and minimizing water resource impacts to support NEPA and other project needs. 3. Following identification of potential project alternative(s): • Ask environmental and engineering staff to define controls that may be needed to achieve compliance with applicable laws and regulations; • Coordinate with environmental and engineering staff to determine whether implementation of compliance controls and mitigation measures might affect project; and • Ask environmental compliance specialists to define the schedule for prepar- ing and obtaining permits for impacts to water resources. 4. Following selection of project alternative: • Coordinate with engineering, construction, operations, and environmental compliance departments to see that information exchange between project implementation and water resource issue management continues through project life-cycle.

1.3.2 Overview of Recommended Airport-Specific Water Resource Issue Management Program As will be discussed in detail in Section 2, effectively planning for water resource issues asso- ciated with development projects can be aided by establishing an airport-specific Water Resource Issue Management Program that provides a structure to the information assessment and com- pliance assessment process. The Water Resource Issue Management Program proposed in the Handbook includes the following components: 1. Water Resource Issue Information Catalog— • Water Resource Inventory, • Mitigation Facility Inventory, • Core Regulatory Requirements, and • Development Project Checklist. 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 Development Project Implementation. 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 cata- log should ideally be developed in advance of the planning process for a specific project so that the information is avail- able at the earliest stages of planning. 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 exe- cute the management of water resource issues within the context of a development project. The initial development of the catalog and plan will result in water resource information and a project execution framework that can be used on any development project at the airport with potential water resource issues. While there will be an initial investment to develop these items, there should be long-term cost reductions achieved by implementing the Program through: • Decreases in schedule impacts associated with insufficient and late assessment of water resource issues; • Reductions in duplicate efforts in acquiring information and in assessing potential sites for multiple projects; • Reductions in planning, design, and construction expenses through a more integrated con- sideration of water resource issue management and development project planning; and • Reductions in the risk of noncompliance with regulatory requirements. 1.3.3 Overview of Guidance on Integrated Life-Cycle Management of Water Resource Issues Within the Project Implementation Process In Section 3, a method for a life-cycle-based strategy of managing the interaction between water resource issue management and development project implementation is proposed. For the purposes of the Handbook, “life-cycle” incorporates actions taken between the “initial assess- ment” of the project concept to the “operational startup” period for the project that has been 10 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning Key Notes Ideally, baseline information on site water resources and the general approach to water resource issue management would be available to planners prior to the start of the planning process.

Handbook Overview 11 implemented. The definitions of “initial assessment” and “operational startup” can clearly be project and site-specific. In general, however, the following definitions apply: • Initial assessment—any activities that are associated with consideration of the concepts and locations for the development project. This includes activities undertaken to characterize water resources before they are considered in the context of a specific project. • Operational startup—a period of time after construction is completed in which the desired operational activities associated with the project are occurring. Operational startup could include such varied factors as flight activities on a new runway, process operations for a treat- ment facility, or maintenance activities associated with a mitigation wetland. It is important to consider this operational period during the planning stages since the compliance risk, costs, and revenue projections associated with operations can have a crucial impact on decisionmaking for some projects. Between the initial assessment and operational startup, a project can have a variety of phases. In this Handbook, the project life-cycle is divided into three broad phases: concep- tual planning, detailed planning, and project execution. At many airports, conceptual planning would encompass the master planning process; detailed planning is work associ- ated with a specific project. Project execution encompasses the post-planning activities of detailed design, bidding, con- struction, and operational startup. The essence of the proposed life-cycle approach is that managing the interaction of water resource issue and project implementation is an iterative process in which information is con- tinually exchanged and management strategies are continually adapted. Four main elements of that iterative process tend to recur in each project stage: characterize water resources, define compliance requirements, assess project effects, and consolidate all effects (see Figure 2). Typical Phases in Water Resource Issue/ Project Implementation Process • Conceptual Planning (one or more projects; includes master plans) • Detailed Planning (individual project) • Project Execution (design, construction, operation) Figure 2. The four recurring activities within each of the three project implementation phases.

The objective of implementing this cyclical, iterative approach is to identify and address issues continuously throughout the project implementation process, making incremental changes as necessary to keep the project on track and on budget. Using this method should reduce the potential for unexpected, large-scale disruptions to the project schedule and lessen the likelihood of costly project design revisions late in the project. 1.3.4 Overview of Guidance in Water Resource Issue Fact Sheets Appendix B contains a series of fact sheets on seven water resource issue categories. The cate- gorization was derived primarily from similarities in impacts from development projects, sim- ilarities in the measures that are typically taken to mitigate for impacts to the water resources, and commonalities in the regulatory requirements. It is important for planners and develop- ment project management to understand that project impacts must be understood, even in early planning stages, from the standpoint of the individual water resource issues. Each issue may have its own unique set of regulatory requirements, and compliance with those require- ments may have its own unique effect on the project—for example, the presence of wetlands on a potential development site can affect the ability to site that project. On the other hand, water quality-based impacts may have relatively little effect on the ability to site a project at the desired location, but could require land in other locations at the airport for storm water storage and treatment. Each fact sheet provides a detailed approach to managing the process of complying with reg- ulatory requirements for a specific water resource issue within the context of a development proj- ect. The fact sheets include information to promote a general awareness of the issue, summary of applicable regulations, and planning considerations drawn from industry experience on man- agement of the water resource issue within the context of development projects. The fact sheets have four sections, each designed to help readers understand a different aspect of the water resource issue management process: 1. Description of water resource issue and impacts, 2. Identification of core regulatory requirements, 3. Determination of the measures needed for compliance, and 4. Reduction of water resource issue effects on development projects. The level of detail in each fact sheet presented in Appendix B may be most appropriate for environmental professionals or others who will be preparing materials for compliance and for the project team by providing detailed assessments of potential impacts of compliance on proj- ect design, layout, schedule, costs, and operation. To facilitate the understanding of the water resource issue for those who do not need the level of detail presented in Appendix B, a summary of key information for each water resource issue category is presented at the end of this section. The summaries focus on guidance obtained from industry experience on considerations for reducing project impacts associated with each particular water resource issue. 12 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

Water Resource Issue Fact Sheet Summaries 14 Physical Impacts to Wetlands and Other Surface Waters 16 Surface Water and Groundwater Quality 18 Storm Water Quantity and Floodplains 20 Hazardous Wildlife Attractants 22 Aquatic Life and Habitat 24 Coastal Zones and Barriers 26 Wild and Scenic Rivers S U M M A R I E S

Summary of Fact Sheet 1: Physical Impacts to Wetlands and Other Surface Waters Airport property may contain or be adjacent to wetlands or other surface waters. The infra- structure siting associated with new development projects often results in unavoidable potential physical impacts to these resources and/or their buffer zones. Avoidance of these impacts is the top priority. At times, for example, where land availability is limited or airport design standards require a project in a specific location, avoiding impacts is often not possible. Where impacts appear unavoidable, permits and mitigation measures are required. Regulations have been developed to protect wetlands and other surface waters from particular physical impacts. Sections 9 and 10 of the Rivers and Harbors Act established a permit program for structures affecting or work conducted in “navigable waters.” Section 404 of the Clean Water Act (CWA) established a permitting program under United States Environmental Protection Agency (USEPA) guidance for discharges of dredge or fill materials into “waters of the United States.” If structures, work, or discharges of material are proposed for wetlands or other surface waters, a permit authorizing the activity may be required by the United States Army Corps of Engineers (USACE) before the activities commence. Prior to authorization of a Section 9, 10, or 404 permit, a Water Quality Certification under Section 401 of the CWA must be issued by the state to certify that the federal permit meets state water quality standards. Since federal agencies authorize Section 9, 10, and 404 permits, the requirements of NEPA apply. Typically, the USACE ensures NEPA requirements are met through the agency’s internal permit approval process; how- ever, in some situations, another federal agency (e.g., the FAA) assumes the lead regulatory agency role for the NEPA process for this type of water resource issue. Characterizing the effects of a development project on wetlands and other surface waters requires an understanding of how the project affects the development site and an understanding of the core regulatory requirements. Federal agencies must evaluate the project, as well as ensure that options to avoid or minimize impacts to wetlands and other surface waters have been assessed. Mitigation is required as a condition for some permit authorizations when those impacts cannot be avoided. Project planning and design considerations typically associated with physical impacts to wet- lands and surface waters include the following: • Do potential sites contain wetlands and other surface waters? • Have those wetlands and surface waters been delineated on the site, had their quality assessed, and received a jurisdictional determination to identify the governing regulatory agency? • Have alternatives for avoiding the wetlands and surface waters been assessed? • Have mitigation options, their cost, and an implementation schedule been assessed during the early planning stages? The process for assessing core regulatory requirements, determining the measures needed for compliance, and reducing the effects of managing physical impacts to wetlands and other surface water issues on the development project are presented in Fact Sheet 1 in Appendix B. A summary of the guidance for reducing those project impacts follow. 14 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning Guidance for Reducing Project Impacts from Managing Issues Associated with Physical Impacts to Wetlands and Other Surface Waters Water Resource Inventory Prepare water resource inventory for use on multiple projects. Identify wetland acreages and quality.

Handbook Overview 15 Impact Avoidance Permit Acquisition and Approval Design Development Development Revenue Schedule and Sequencing Staffing Stakeholder Coordination Delineation Documentation Mitigation Start of Work Consider relocation of some or the entire project to avoid wetland or surface water impacts for all development projects. Having alternate sites for those projects, if feasible, may reduce delays if a change is made. Limit wetland and stream impacts if possible such that Nationwide Permits (NWPs) rather than indi- vidual permits can be used. This will minimize schedule impacts and reduce permitting costs. Consider whether changes to the development project might reduce the cost and schedule impacts for permitting. Account for gained or lost revenue from changes if project function or scope must change to achieve compliance. Recognize that schedule changes usually equate to cost increases for consultation, design, and construction. Identify the expertise needed, select qualified experts, and bring them in at the right time to avoid re-doing work. Seek to understand cost considerations raised by stakeholders such as airlines and various airport departments. Coordinate early with stakeholders such as airlines, regulators, various airport departments, and communities to avoid multiple iterations of permitting and design. Plan for early and ongoing coordination with regulators (pre-application meeting). Adequately delineate stream and wetland bound- aries using required methods, preferably with an airport-wide delineation, to reduce time commit- ments on individual projects. Submit complete notifications and applications. Consider enhancements to existing surface waters to get mitigation credit rather than construction of new wetlands or surface water segments. Con- sider using a single mitigation site for multiple projects to reduce coordination and costs. Verify that the location of mitigation areas is compatible with wildlife hazard management requirements. Verify that federal agencies have fully completed activities and issued permits and approval before construction.

Summary of Fact Sheet 2: Surface Water and Groundwater Quality The term “surface water,” from a water resource perspective, can include streams, rivers, lakes, wetlands, harbors, territorial seas, waters of the contiguous zone, and oceans. Groundwater is a natural resource that is relied upon as a source of drinking water for much of the United States (2). Because surface water and groundwater have a clear relationship and are primarily distin- guished by their location, they are jointly discussed in a single fact sheet. Airport development projects can affect surface water and groundwater quality as a result of changes in the site characteristics affecting storm water discharges from the development site, changes in pollutants associated with construction, changes in pollutants associated with subse- quent operations, and controls required to mitigate for those changes. Often the impacts to sur- face water quality at airports are related to changes in the quality, quantity, and discharge location of storm water runoff. Above ground and underground contamination sources can also impact groundwater quality. Activities that may affect surface water and groundwater quality are regulated primarily through the CWA and the Safe Drinking Water Act (SDWA). When assessing the applicability and impacts of these regulations on development projects, it is important to understand that the terms “surface water” and “groundwater” can have very specific regulatory meanings that may not always correspond to the general understanding of the terms. Changes to the characteristics of discharges to surface waters and groundwater associated with a development project may be subject to existing airport-specific permit conditions associated with those regulations. New or amended permits allowing the discharges under specified conditions may also be required for the execution of the project. Project planning and design considerations typically associated with surface water and groundwater quality include the following: • Will the location(s) for discharge of surface waters be changed? • Will new or additional pollutants be exposed to storm water runoff as a result of the project? • Will the locations where pollutants are exposed to storm water change? • Will changes in storm water runoff quantities or flow routing affect pollutant concentrations? • What is the timeframe for assessing water quality issues, preparing permit applications, and receiving permit conditions from regulators? • Will storage and treatment be necessary to meet regulatory criteria, where will it be located, and how much space will be required? The process for assessing core regulatory requirements, determining the measures needed for compliance, and reducing the effects of managing surface water and groundwater quality issues on the development project are presented in Fact Sheet 2 in Appendix B. A summary of the guid- ance for reducing those project impacts follows. 16 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning Guidance for Reducing Project Impacts from Managing Issues Associated with Surface Water and Groundwater Quality Characterization of Discharges Modeling, Calculations, and Analyses Obtain buy-in from all stakeholders on the baseline data for future pollutant discharges. Submit modeling plans to regulators for approval prior to executing work.

Handbook Overview 17 Wasteload Allocation Analysis for Assessing Water Quality-Based Effluent Limits Siting for Controls Unintended Impacts Design Implementation Permit Acquisition Storm Water Management Stakeholder Coordination Perform calculations for assessing receiving stream assimilation capacities and allowable effluent limits and submit to regulator for review. Consider potential land areas needed for storm water storage and treatment in the earliest plan- ning stages. Seek to locate the development project in areas that will not impact surface or groundwater resources and not attract wildlife hazardous to aviation. Verify that meeting compliance requirements asso- ciated with surface water quality for one devel- opment project do not inadvertently trigger additional compliance requirements for others. Provide alternatives that avoid or minimize impacts to surface water or groundwater and design proj- ects that do not require unique engineering, con- struction, or monitoring needs. Perform detailed cost analyses that consider both capital and oper- ating costs when considering treatment alterna- tives for storm water containing pollutants. Notify regulatory agencies early in the process and discuss key issues and permit requirements. Define National Pollutant Discharge Elimination System (NPDES) permit limits and conditions prior to design to avoid changes during design. Under- stand that controls and mitigation measures may not be able to be assessed until regulatory condi- tions are defined. Determine times to prepare permit applications, statutory schedule and review requirements, and expected review time by regulatory agencies. Submit permit to install applications as far in advance of construction as possible once design documentation is available. Seek to minimize the volume of storm water that must be managed to achieve compliance. Coordinate with stakeholders such as airlines, vari- ous airport departments, and nearby communi- ties to avoid multiple iterations of permitting and design.

Guidance for Reducing Project Impacts from Managing Issues Associated with Storm Water Quantity and Floodplains Water Resource Inventory Create an inventory for storm water data that includes maps of airport areas with flooding issues and capacity limitations. Understand the source of the floodplain boundaries obtained from federal agencies and include mapping of floodplain boundaries in the inventory. The boundaries in Flood Insurance Rate Map (FIRM) documents may not be accurate on smaller project scales. Summary of Fact Sheet 3: Storm Water Quantity and Floodplains Many of the most common airport development projects can affect the quantities of storm water discharged from the airport site. Those storm water discharges can in turn affect the propensity for regional flooding and runoff-related impacts. Airports are frequently located near water bodies and as such, airport projects can affect, and be affected, by floodplains. Regulation of storm water quantities associated with development projects has occurred pri- marily at municipal, regional, and state levels to date. Storm water quantity regulations are typ- ically designed to protect downstream infrastructure and minimize flooding during large, infrequent storm events. The regulations often include requirements allowing little, if any, change in the runoff quantities before and after development projects. A series of federal orders and guidelines, plus some state regional requirements have been enacted and developed to pro- tect floodplains. The key elements of the regulatory framework include developments within a floodplain, increases to flood elevations, and changes to runoff inside the floodplain. Airport development projects that involve construction of new impervious surfaces (e.g., pavement, buildings) in previously undeveloped areas are typically the types of projects most affected by storm water quantity and floodplain regulations. Projects where one type of imper- vious surface is replaced by another typically are not affected significantly. Project planning and design considerations typically associated with storm water quantity and floodplain regulation compliance include the following: • Does the project extend into the 100-year floodplain? • Will the project’s unavoidable location result in additional flooding or endanger human life? • What are regulatory requirements governing flow rates and volumes from new developments? • Is there an existing storm water runoff and transport model to characterize discharges? • Will any storm water be diverted to a new discharge location and new watershed? • Will storm water detention be required to meet regulatory requirements, how much space will it require, and where will it be located? • Will storm water detention cause issues with wildlife attractants? • Will storm water piping and pumping be required to convey storm water to detention struc- tures, treatment facilities, or new discharge locations? The process for assessing core regulatory requirements, determining the measures needed for compliance, and reducing the effects of managing storm water quantity and floodplain issues on the development project are presented in Fact Sheet 3 in Appendix B. A summary of the guid- ance for reducing those project impacts follows. 18 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

Handbook Overview 19 Modeling, Calculations, and Analyses Conceptual Planning Control Siting Design Implementation Construction of Controls Scheduling and Sequencing Stakeholder Coordination Coordinate with regulators to determine approved modeling programs, calculation protocols, and level of detail that may be acceptable. Identify the appropriate level of detail to collect in sup- port of modeling and analyses and provide a reasonable estimate of storm water discharges (e.g., select a minimum pipe size or drainage basin size to be modeled). Consider development of a storm water master plan or integrating storm water master planning into airport master planning. Master plans may be useful for considering the storm water needs for long-term or phased development, in addi- tion to widespread development. Consider potential floodplain impacts associated with long-term development as part of storm water master planning process. Identify and characterize potential sites for controls in the Conceptual Planning Phase. Avoid impacts inside the floodplain, where possible. Build infiltration and temporary storage into devel- opment project design where possible to reduce extent of necessary end-of-pipe controls. Avoid project-by-project designs of controls that do not consider effects to overall airport storm water drainage. Consider the need for modifications to controls to minimize attraction of hazardous wildlife. Coordinate design and construction of controls with design and construction of the develop- ment project to avoid development project delays from unfinished work. Reduce management and consultant costs with well-planned and coordinated schedules for development project and storm water quantity assessments. Coordinate with local agencies, property owners, and regulators to assist with identifying core reg- ulatory requirements, interests, and data on local flooding issues.

Guidance for Reducing Project Impacts from Managing Issues Associated with Wildlife Hazard Attractants Identification of Hazardous Wildlife Attractants Determine the potential for hazardous wildlife attractants associated with the project and sur- rounding areas early in the Detailed Planning Phase. Summary of Fact Sheet 4: Hazardous Wildlife Attractants The category “hazardous wildlife attractants” encompasses the impacts of airport development projects on wildlife hazards and the associated public safety and aircraft operational issues. The focus of the hazardous wildlife attractants issue is on the potential creation or enhancement of water-based hazardous wildlife attractants associated with new projects or redevelopment at an airport. Although hazardous wildlife attractants are considered a water resource issue in the Handbook, the primary impact associated with these hazards is to airport operations and safety, rather than to the water resources themselves. They are considered a water resource issue because the need to manage wildlife hazards can complicate water resource management associated with new development projects. Requirements for managing wildlife hazards at airports are aimed at minimizing the attraction of hazardous wildlife to Airport Operations Areas (AOAs), and thus minimizing the risk for colli- sions between aircraft and wildlife. Federal Aviation Regulation (FAR) 14 Code of Federal Regula- tions (C.F.R.) Part 139.337 contains specific requirements for performing Wildlife Hazard Assessments (WHAs) as well as developing Wildlife Hazard Management Plans (WHMPs) to investigate and address, respectively, observed wildlife hazards at airports. The FAA’s requirements for wildlife hazard management for existing and proposed facilities are largely encompassed in FAA Advisory Circular (AC) 150/5200-33B: Hazardous Wildlife Attractants on or Near Airports (3). Air- port personnel should note that special expertise is needed to conduct much of the analyses described in the fact sheet (e.g., wildlife biologists certified under FAA AC 150/5200-36 or airport wildlife hazard specialists from the U.S. Department of Agriculture’s [USDA’s] wildlife services). The FAA’s goal for minimizing water-based hazardous wildlife attractants can sometimes con- flict with the goals of other regulatory agencies to improve water quality and to provide storm water quantity control through onsite detention and treatment. Coordination among multiple agencies may be required to resolve conflicts to allow the project to move forward. Project planning and design considerations typically associated with wildlife hazard attrac- tants include the following: • Will storm water detention be required, will the open basin drain in less than 48 hours, or will the basin need to be covered? • Does the project have the potential to change infiltration rates, thus creating or reducing the presence of surface waters such as wetlands? • How long will it take to obtain a resolution among regulatory agencies on conflicting regula- tions for wildlife hazards, storm water quantity control, surface water quality, and physical impacts to wetlands and other surface waters? The process for assessing core regulatory requirements, determining the measures needed for compliance, and reducing the effects of managing wildlife hazard attractants on the development project are presented in Fact Sheet 4 in Appendix B. A summary of the guidance for reducing those project impacts follows. 20 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

Handbook Overview 21 Data Collection Design Development Control Siting Mitigation Staffing Stakeholder Coordination Perform a WHA and develop a WHMP early in the Detailed Planning Phase and submit to the FAA and USDA for review. Consider combinations of project modifications, operational techniques, deterrents, or controls that are the most cost effective. Carefully con- sider the documented effectiveness of wildlife hazard attractant control methods. Locate projects in areas where there are no issues associated with hazardous wildlife attractants. Identify potential hazards and mitigation approaches in the Conceptual Planning Phase, and incorporate management techniques and wildlife hazard deterrents into design features to the extent possible. Involve airport and airline experts in wildlife hazard management and aircraft safety and local Wildlife Service representatives in Conceptual Planning and Detailed Planning Phase discussions. Communicate wildlife hazard attractant concerns to other entities that may be considering storm water or flooding controls in vicinity of airport. To the extent possible, facilitate coordination between agencies regulating storm water quan- tity and agencies regulating wildlife hazard attractants in the Conceptual Planning and Detailed Planning Phases.

Summary of Fact Sheet 5: Aquatic Life and Habitat The category “aquatic life and habitat” encompasses the impacts of airport development projects on the aquatic organisms and their habitats. This includes plants, animals, fish, microorganisms, and so forth associated with or dependent upon water resources or the immediate surrounding area; federally threatened and endangered species; and state-protected species and habitat. While most of the regulations associated with aquatic life and habitat are federal, protected species are listed under both federal and individual state regulatory requirements. The principal federal regulations governing aquatic species and their habitats are associated with the Endan- gered Species Act of 1973 (ESA). Section 7 of the ESA requires federal agencies to conduct con- sultations to ensure that federal actions that are authorized, funded, or carried out are not likely to jeopardize listed species or result in destruction or adverse modification of designated critical habitats. Compliance with the ESA is typically administered by the U.S. Fish and Wildlife Service (USFWS). The Magnuson–Stevens Fishery Conservation and Management Act of 1976 (MSFCMA) is the primary law governing marine fisheries management in U.S. federal waters. Compliance with the MSFCMA is administered by the National Marine Fisheries Service (NMFS). NMFS also enforces Section 7 ESA requirements for marine and anadromous fish species, marine animals, and critical habitats for those organisms. Airport development projects may require the physical removal of aquatic species or habitat. Species and habitats can also be affected through secondary effects associated with ongoing oper- ations such as changes in discharges of storm water or treated wastewater. To satisfy the ESA and MSFCMA, as part of the NEPA process, a review must be conducted to determine whether a pro- posed action would affect a listed species or crucial habitat. This requires consultation between the lead NEPA agency and the agencies administering compliance. Project planning and design considerations typically associated with aquatic life and habitat issues include the following: • Are there designated crucial habitats on the project site? • Will storm water or other waters discharge from the site into protected habitats or areas poten- tially containing protected species? • Which agencies administer compliance with the regulations? • How will the airport operator coordinate with the NEPA lead agency and the consulting agencies? • What information is required by the agencies to provide approval for the requested activities? • How long will it take to acquire the required information and what is the expected timeframe for agency response? The process for assessing core regulatory requirements, determining the measures needed for compliance, and reducing the effects of managing aquatic life and habitat issues on the develop- ment project are presented in Fact Sheet 5 in Appendix B. A summary of the guidance for reduc- ing those project impacts follows. 22 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

Handbook Overview 23 Guidance for Reducing Project Impacts from Managing Issues Associated with Aquatic Life and Habitat Data Collection Storm Water Management Design Implementation and Control Siting Permit Acquisition or Approvals Construction Stakeholder Coordination Mitigation Perform consultation early in the Detailed Plan- ning Phase to identify potential aquatic life or habitat issues. Adequately delineate protected species habitat, including downstream areas of the project. Consider the need for storm water controls for projects to minimize impacts to downstream aquatic life or habitat. Relocate the project to avoid impacts to aquatic life or habitat or provide alternatives that minimize impacts. Obtain information or perform site assessments in association with other permitting or approvals that may be needed. Consider the possibility that controls and mitigation for other water resource issues (e.g., detention basins) could lead to impacts to existing species or habitats. Coordinate with regulators early to discuss poten- tial documentation requirements and schedule. Identify options to mitigate impacts and propose to agency for concurrence.

Guidance for Reducing Project Impacts from Managing Issues Associated with Coastal Zones and Barriers Data Collection Consult with state agency to confirm coastal zone boundaries. Summary of Fact Sheet 6: Coastal Zones and Barriers The category “coastal zones and barriers” encompasses the impacts of airport development projects on coastal resources and the associated effects on water quality, biotic habitat, public safety, and infrastructure. Regulation of coastal zones and barriers occurs primarily through • The Coastal Zone Management Act (CZMA) (regulated under 15 C.F.R. 923 and 930) as amended by the Coastal Zone Management Reauthorization Amendments of 1990 (23 C.F.R. 650.211) and the Coastal Zone Protection Act of 1996 and • The Coastal Barrier Resources Act (CBRA) as amended by the Coastal Barrier Improvement Act of 1990. The CZMA requires that any development projects with the potential to impact a state’s coastal zone comply with requirements of the federally approved state coastal zone management program (if the project is being performed or funded by the federal government). The CZMA is implemented by the states, with federal oversight from the National Oceanic and Atmospheric Administration (NOAA). Airports performing development along coastal areas need to consider the potential for impacts to coastal zones and barriers. Construction of facilities and infrastructure (e.g., sea walls, jetties, channels, and piers) can have a direct physical impact on coastal resources. Development along the shoreline can also disrupt natural coastline processes (e.g., barrier island migration). Airport projects that change airport features such as land use, vegetation, grading, and increased storm water runoff can result in localized increases in erosion and sedimentation and in the destabilization of the coastline. New development projects also have the potential to alter water quality and quantity. Nonpoint source industrial runoff and point source storm water discharges may contribute to degradation of water quality along the coast. Project planning and design considerations typically associated with coastal zone and barrier issues include the following: • Are there designated coastal zones or barriers within the vicinity of the project? • What local and state agencies manage compliance with coastal zone and barrier regulations and what are the requirements? • What information is required by the agencies to provide approval for the requested activities? • How long will it take to acquire the required information and what is the expected timeframe for agency response? • Can possible mitigation needs and options be assessed in the early planning stages to deter- mine whether they might impact the site, cost, or schedule? The process for assessing core regulatory requirements, determining the measures needed for compliance, and reducing the effects of managing coastal zone and barrier issues on the devel- opment project are presented in Fact Sheet 6 in Appendix B. A summary of the guidance for reducing those project impacts follows. 24 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning

Handbook Overview 25 Design Development and Control Siting Stakeholder Coordination Documentation Construction Mitigation Consider siting or design alternatives that avoid or minimize impacts to coastal zones or barriers. Coordinate on the siting and design of controls and discharges associated with other water resource issues that are associated with coastal zone impacts. Coordinate with state agency to determine whether there are controls or design modifications that may minimize potential coastal impacts. Consult with state agencies to identify required permits and approvals and potential timeframes to be incorporated into project planning. Submit complete documentation associated with consistency evaluation and in accordance with state-specific requirements. Ensure agencies fully complete consultation, coor- dination, and permitting authorizations before conducting project work. Coordinate with state agency to determine whether mitigation may be required to address coastal impacts.

Summary of Fact Sheet 7: Wild and Scenic Rivers The National Wild and Scenic Rivers System was created by Congress in 1968 to preserve cer- tain rivers with outstanding natural, cultural, and recreational values in a free-flowing condition for the enjoyment of present and future generations. Rivers or portions of rivers are designated as wild, scenic, or recreational by an act of Congress or by the Secretary of the Interior at the request of a state governor (4). Federal agencies that are responsible for managing a particular stretch of river (including the U.S. Bureau of Land Management [BLM], the U.S. Forest Service [USFS], USFWS, and the National Park Service [NPS]) are required to develop a Comprehensive River Management Plan that provides for the protection of designated river values as well as describes requirements for land development in the vicinity of the river. Consent for projects affecting wild, scenic, or recreational rivers (also called “Section 7 Con- sent”) must be received before the activity is approved. The federal agency managing compli- ance may also be invited to be a cooperating agency in the NEPA process. If a designated river is affected, the potential effects of the development project must be characterized with respect to the designated uses and mitigation measures may be necessary to prevent adverse impacts. Project planning and design considerations typically associated with aquatic life and habitat issues include the following: • Does the project have the potential to impact areas within the 1/4-mile corridor protection zone or change the designated values (i.e., scenery, geology, fish and wildlife, historic resources, or cultural resources) of wild and scenic rivers? • Does airport property contain use restrictions with respect to wild and scenic river issues? • What documentation is required by consulting agencies (i.e., USFWS, NPS, BLM, and USFS)? The process for assessing core regulatory requirements, determining the measures needed for compliance, and reducing the effects of managing wild and scenic river issues on the develop- ment project are presented in Fact Sheet 7 in Appendix B. A summary of the guidance for reduc- ing those project impacts follows. 26 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning Guidance for Reducing Project Impacts from Managing Issues Associated with Wild and Scenic Rivers Water Resource Inventory Modeling, Calculations, and Analyses Data Collection Control Siting Design Implementation Understand location of wild and scenic rivers early in the project implementation process. Identify the appropriate level of detail and specific methods required by agencies when calculating water quality–related impacts. Collect additional information beyond the project footprint to ensure downstream impacts are avoided. Identify potential sites in the Conceptual Planning Phase. Design controls that meet the project needs out- side of wild and scenic river corridors. Coordinate with development project construction.

Handbook Overview 27 Staffing Stakeholder Coordination Maintenance Permit Acquisition or Approvals Identify the expertise needed, select qualified experts, and bring the experts in at the right time. Coordinate with regulators in the Conceptual Plan- ning and Detailed Planning Phases including dis- cussions of funding, authorizing, and NEPA lead agency—especially if impacts necessitate the need to ensure aircraft safety. Coordinate early with stakeholders such as airlines, regulators, various airport departments, and communities to avoid multiple iterations of permitting and design. Design project so that maintenance needs are minimal. Coordinate permit approval documentation needs with agencies during the planning process.