Assessing Opportunities for Alternative Fuel Distribution Programs (2013)

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61 This section corresponds to Step C in the evaluation framework presented in Figure 3. The goal of this section is to identify and review the critical siting and location-specific criteria, as well as to document a suggested sequencing strategy for this evaluation and future development. The workbook spreadsheet has templates to help with this evaluation. 6.1 Introduction to Siting Considerations FAA policies and regulations largely control what can or cannot be done in the airport set- ting. The construction and operation of alternative fuel infrastructure is no exception. The FAA compiles and maintains a number of documents, including Advisory Circulars (ACs), Orders, and references to other documents that should be considered when evaluating the feasibility of placing alternative fuel infrastructure in the airport setting. In addition, given the complex technical issues surrounding fueling system and airfield design, engaging an aviation engineer familiar with these topics may be advisable to assist with locating a processing facility. The following is a summary list of important documents for evaluating siting criteria for alternative fuel distribution programs: • Applicable regional transportation planning documents • Applicable zoning and comprehensive planning documents • FAA Airport Sponsor Grant Assurances (http://www.faa.gov/airports/aip/grant_assurances/) • FAA AC 150/5300-13, Airport Design (http://www.faa.gov/airports/resources/advisory_circulars/ index.cfm/go/document.current/documentNumber/150_5300-13) • Federal Aviation Regulations (FAR) Part 77, Subpart C: Standards for Determining Obstruc- tions to Air Navigation or Navigational Aids or Facilities (http://www.ecfr.gov/cgi-bin/text-idx? c=ecfr&sid=2d79c95db81aec2c906f2211aa809a28&rgn=div5&view=text&node=14:2.0.1.2.9& idno=14#14:2.0.1.2.9.3) • FAA Order 1050.1E, Environmental Impacts: Policies and Procedures (http://www.faa.gov/ documentLibrary/media/order/energy_orders/1050-1E.pdf) • FAA Order 5050.4B, National Environmental Policy Act (NEPA) Implementing Instructions for Airport Projects (http://www.faa.gov/airports/resources/publications/orders/environmental_ 5050_4/) • FAA AC 150/5070-6B, Airport Master Plans (http://www.faa.gov/documentLibrary/media/ advisory_circular/150-5070-6B/150_5070_6b_chg1.pdf) • FAA AC 150/5200-33, Hazardous Wildlife Attractants on or Near Airports (http://www.faa. gov/documentLibrary/media/advisory_circular/150-5200-33B/150_5200_33b.pdf) S e c t i o n 6 Evaluation Framework Step C: What Are the Main Siting Considerations for Alternative Fuel Distribution Programs?

62 Assessing opportunities for Alternative Fuel Distribution Programs • FAA AC 150/5210-20, Ground Vehicle Operations on Airports (http://www.faa.gov/document Library/media/advisory_circular/150-5210-20/150_5210_20.pdf) • FAA AC 150/5230-4A, Aircraft Fuel Storage, Handling, and Dispensing on Airports (http:// www.faa.gov/documentLibrary/media/advisory_circular/150-5230-4A/150_5230_4a.pdf) • FAA Order 5190.6B, Appendix R, Airport Layout Plan, Airport Compliance Manual (http:// www.faa.gov/airports/resources/publications/orders/compliance_5190_6/media/5190_6b_ appR.pdf) • FAA Order 5190.7, Minimum Standards for Commercial Aeronautical Activities (http:// www.faa.gov/documentLibrary/media/advisory_circular/150-5190-7/150_5190_7.pdf) • National Fire Protection Association (NFPA) 407, Standard for Aircraft Fuel Servicing • NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages, 2012 Edition (if applicable) • NFPA 52, Vehicular Gaseous Fuel Systems Code, 2010 Edition (if applicable) • NFPA 58, Liquid Petroleum Gas Code, 2011 Edition (if applicable) • NFPA 59A, Standard for Production, Storage, and Handling of Liquefied Natural Gas (LNG), 2009 Edition (if applicable) • NFPA 415, Standard on Airport Terminal Buildings, Fueling Ramp Drainage, and Loading Walkways, 2008 Edition (if applicable) • Title 14 of the Code of Federal Regulations (CFR) Part 139, Certification of Airports (http:// www.faa.gov/airports/airport_safety/part139_cert/) • Transportation Security Administration, Recommended Security Guidelines for Airport Plan- ning, Design and Construction, May 2011 (http://www.tsa.gov/assets/pdf/airport_security_ design_guidelines.pdf) • Title 40 CFR Part 112, Oil Pollution Prevention (http://www.epa.gov/osweroe1/docs/oil/ cfr/0703_40cfr112.pdf) • Applicable Fire Code regulations (i.e., International Fire Code, Uniform Fire Code, NFPA 1 Fire Code, or other) • FAA Best Practices for Environmental Impact Statement (EIS) Management (http://www.faa. gov/airports/environmental/eis_best_practices/) • FAA Environmental Desk Reference for Airport Actions (http://www.faa.gov/airports/ environmental/environmental_desk_ref/) Any successful site planning project begins with comprehensive knowledge and understanding of the operation, function, and use of the proposed facility. Planners must gather and assemble a variety of baseline information, which establishes the framework to conduct a detailed evaluation of any development proposal and to make recommendations regarding the alternative planning strategies. A generalized siting plan is presented in Table 8. The following sections expand the categories of the site planning process, presenting them in a narrative format to help airports quickly identify the key considerations and make informed planning and development recommendations. The flowchart shown in Figure 6 illustrates these steps graphically. 6.2 Steps for Siting Alternative Fuels 6.2.1 Step 1: Inventory Airport Fuel Storage Facilities/ Distribution Systems The first step in the process for evaluating the siting of alternative fuel storage and distribu- tion systems is to complete a comprehensive inventory of the airport’s existing facilities. It is important to note that there are a variety of possible ownership and operational arrangements

evaluation Framework Step c 63 relating to aviation fuel storage and distribution on airports. These arrangements can vary from airports that own and operate the aviation fueling facilities to others that simply lease property to individual fuel service providers who own and operate the facility. Specific examples of pos- sible fuel storage facility ownership and distribution facility arrangements include the following: • Airport ownership and distribution • Airport ownership and self-serve distribution • Airport ownership and FBO distribution • FBO ownership and distribution • Fuel company ownership and FBO distribution • Private ownership and distribution Therefore, the fueling goals and objectives of airport operators can vary significantly, depending on the airport owner’s interest and capabilities in the operation and maintenance of the fueling concession. A detailed description of all fuel storage facilities and distribution systems should initially be prepared, along with a drawing that maps the locations of all improvements. The location of the airport’s aviation fuel storage facilities is typically depicted on the Airport Layout Plan (ALP) drawing or may be included in the airport’s existing geographic information system. Also, many Step Key Considerations 1. Inventory existing airport fuel storage facilities and distribution systems, and initial site analysis Identify location of existing aviation and non- aviation fuel storage facilities, document fuel types and quantities, and specify method of distribution 2. Identify and update existing and long- term alternative airport fuel storage facility and distribution system requirements Determine if the existing fuel storage facility or distribution system can accommodate the future alternative airport fuel storage requirements 3. Identify long-term goals and objectives for the alternative airport fuel storage facility and distribution system Determine which alternative airport fuel storage facilities and distribution systems should be considered and identify the appropriate planning track for evaluation (see Figure 6) 4. Identify preliminary alternative fuel storage facility development sites Determine if existing airport fuel storage and distribution facilities can be expanded or redeveloped to accommodate alternative fuels Determine if a new alternative fuel storage and distribution facility must be constructed Determine if the existing fuel storage and distribution facility must be decommissioned 5. Screen preliminary alternative fuel storage facility development sites Screen sites for compliance with FAA design standards, local planning and zoning, and local, state, and federal regulations 6. Select recommended alternative fuel storage facility site plans for planning approval process Initiate preliminary design and engineering drawings, including cost estimates Complete FAA review and approval process for updating Airport Layout Plan drawing set Complete NEPA process and receive compliance determination 7. Finalize recommended alternative fuel storage facility site plans for construction Finalize construction drawings and obtain required construction and development permits Table 8. General considerations for siting alternative fuel distribution programs at airports.

64 Assessing opportunities for Alternative Fuel Distribution Programs 1. Fuel Facility Inventory Aviation vs. Non-Aviation • Fuel Type • Tank Type/Size • Ownership/Distribution • Condition/Compliance • Utilities • Mapping 2. Fuel Requirements • Airport Fuel Demand Analysis 5. Site Plan Screening Analysis • Regional Transportation Planning Document Review • Zoning and Corporate Planning Review • Federal and State Regulatory Agency Compliance Review • Hazard to Flight Analysis • Preliminary Environmental Review • Building Code Review 6. Recommended Fuel Facility Site Plan Confirmation • Preliminary Cost Estimates • State and Federal Funding Eligibility (Including Grants) • Private Capital Funding Sources • FAA Grant Assurance Compliance • ALP Drawing Set Update for FAA Review & Approval • Environmental Review Process (NEPA) • State and Local Environmental Permitting 7. Fuel Facility Construction • Design & Engineering Drawings • Final Cost Estimates • Coordinate Phasing & Development for Required Support Projects • Building Permits TRACK B Non-Aviation Fuel Projections • Unleaded • Diesel • Green Diesel (Alternative) • CNG (Alternative) • LPG (Alternative) 3. Development Goals • Expansion • Relocation/Decom- missioning • Consolidation • Upgrade • Alternative Fuels Facilities (Public vs. Private Use) 4. Preliminary Development Sites (Non-Aviation Fuel) • Vehicular access (landside) • Easement access (underground pipeline/hydrant distribution • Setback criteria (property line, roadways, buildings, etc.) TRACK A Aviation Fuel Projections • Jet A • Avgas • Green Jet A (Alternative) 3. Development Goals • Expansion • Relocation/Decom- missioning • Consolidation • Upgrade • Alternative Fuels (Green Jet A Drop-in) 4. Preliminary Development Sites (Aviation Fuel) • Vehicular access (landside) • Vehicular access (airside) • Easement access (underground pipeline/hydrant distribution Figure 6. Planning process for siting alternative fuel storage and distribution facilities at airports.

evaluation Framework Step c 65 airports likely have a Storm Water Pollution Prevention Plan or a Spill Prevention, Control, and Countermeasure Plan that details fueling facilities and systems inventories. Depending on the size or classification of the facility, airports may have a variety of other fuel storage facilities that are related to aviation support facility functions. These include airline GSE, airport operations vehicles (e.g., maintenance and aircraft rescue and fire fighting), and rental car facilities. Therefore, it is recommended that both aviation-related fuels (i.e., Jet A and avgas) and non-aviation-related fuels (e.g., unleaded gasoline, diesel, E85, CNG, and LPG) be inventoried separately, because each category would likely have different storage requirements, siting criteria, and distribution systems. For each storage facility in the inventory, the following items should be documented: type and number, fuel type, storage capacity, condition, age, pumping capacity, ownership, lease terms, and environmental compliance status. Once the inventory is complete, the airport should evalu- ate each item for the following: • Compliance with existing zoning regulations • Consistency with existing comprehensive planning documents • Consistency with existing airport planning documents – Airport Master Plan – ALP – Airport Rules and Regulations – Airport Minimum Standards for Commercial Activities • Compliance with FAA planning and design standards • Compliance with NFPA guidance/regulations • Compliance with local fire code regulations 6.2.2 Step 2: Identify Fuel Storage and Distribution System Requirements (Existing/Future) The second step in the planning process is to document both existing and future fuel storage requirements, which requires an up-to-date assessment of the aviation and non- aviation fuel demand at the airport and an identification of the distribution system necessary to accommodate that demand. Again, the airport’s existing planning documents, such as the Airport Master Plan, may include an analysis of fuel storage requirements, and the ALP may illustrate the expansion or possible relocation of existing fuel storage facilities. Depending on the currency of these documents, this demand analysis will likely need to be updated, and the existing planning documents may only include fuel storage requirements for aviation- related fuels. In the case of non-aviation-related fuels, an analysis of related fuel storage requirements will also be necessary. The land footprint of a typical off-airport refueling station should be utilized as a reference to determine airport land requirements for the siting of any new refueling stations for non-aviation. Traditional gasoline refueling stations vary significantly in size and required land footprint. While plots of land hosting gasoline stations range from as small as 0.3 acres to 5 acres or more, the average size is about 1 acre (Xerxes Corporation 2012). Because underground fuel tanks can range from 7 feet in length (600-gallon tank) to nearly 75 feet in length (50,000-gallon tank), airports should ensure that they allow enough room for adequate underground storage to meet foreseeable demand for the selected stocked fuels. An overview of infrastructure require- ments is shown in Table 9. Once the fuel storage demand (for both aviation- and non-aviation-related fuels) has been quantified, these requirements must be allocated to site-specific storage requirements for the

66 Assessing opportunities for Alternative Fuel Distribution Programs various fuel types under consideration. Depending on the amount of aviation fuel dispensed by either refueler trucks or a hydrant system, and the proximity of the airport to the location of the bulk fuel storage terminal, a general rule-of-thumb is to target a fuel storage capability of 7 to 14 days of supply at the airport to allow for any equipment or delivery problems or tank outages. Also, these storage projections should be validated with existing fuel service providers (if applicable), to assist the airport in identifying any future fuel service goals (e.g., provision of additional fuel types, capacities, or distribution methods). Fuel Land Requirements Infrastructure & Storage Requirements Delivery System to Fueling Site Storage System Distribution System Alternative jet fuel Same as conventional jet fuel Same as conventional jet fuel Same as conventional jet fuel Same as conventional jet fuel Same as conventional jet fuel Gasoline 0.3–5 acres Storage tanks, pumps, control system, piping system Pipeline, truck Underground tanks Fuel pump Diesel 0.3–5 acres Storage tanks, pumps, control system, piping system Pipeline, truck Underground tanks Fuel pump with diesel-only connector LPG Similar to gasoline/diesel Storage tanks, pumps, control system, piping system Pipeline, truck Underground or aboveground tanks Fuel pump with LPG connector CNG Larger than gasoline/diesel Compression system, pressurized storage tanks Pipeline Underground tanks, line packing CNG dispensing system, fast fill nozzles E85 Similar to gasoline/diesel E85-compatible dispensers, pumps, pipes, and tanks Truck Underground tanks Fuel pump with E85-specific markings Biodiesel Similar to gasoline/diesel Dedicated tanks recommended for higher blends (above B20). Existing diesel tanks can be used, but filter clogging is likely to occur Truck Underground or aboveground tanks Fuel pump with diesel-only connector (also specific markings to differentiate from ULS diesel) Green diesel Similar to gasoline/diesel None, if there is existing diesel infrastructure present Truck Underground or aboveground tanks Fuel pump with diesel-only connector Electricity Smaller than gasoline/diesel Electric utility point of service, individual parking spaces, charging stations, utility branch ac- counting system (to separate electricity used by site from that used by charging vehicles) Electric distribution system None Electric distribution system Table 9. Summary of infrastructure requirements for alternative fuels distribution systems (FAA 2010b, Xerxes Corporation 2012).

evaluation Framework Step c 67 6.2.3 Step 3: Identify Alternative Fuel Storage and Distribution Goals The third step in the siting process is to incorporate the findings of Steps 1 and 2 into the formulation of specific goals for alternative fuel storage and distribution. This process should begin with a determination of whether enough aviation and non-aviation fuel is dispensed at the airport to warrant consideration of additional alternative fuel storage and distribution facilities. The following list presents possible development scenarios that may arise relative to the future provision of alternative fuels on the airport: • Non-aviation fuels – Develop new public-use fuel-dispensing facilities for alternative vehicles on airport prop- erty (facilities would serve private vehicles that operate on alternative fuels). – Develop new private-use fuel-dispensing facilities for alternative vehicles on airport prop- erty (facilities would serve airport operation and maintenance vehicles, airline ground service vehicles, rental car facilities, etc.). • Aviation fuels – Expand existing airport fuel storage facility to accommodate increased demand. – Relocate or decommission existing airport fuel storage facility due to environmental com- pliance or development and expansion constraints. – Consolidate multiple existing fuel storage facilities. – Install new fuel hydrant delivery system to serve the passenger terminal apron area (e.g., individual gate parking positions or an adjacent fuel depot to reduce travel times by re- fueler trucks). Note that hydrant systems have high capital costs and complex monitoring requirements once installed. Careful analysis should be conducted to assess if such a solu- tion is practical. As with any airport facility, fuel storage and distribution facilities must comply with FAA AC 150/5300-13 (FAA 1989), which contains definitions for runway protection zones (RPZs) and runway object free areas (ROFAs) (see Figures 7 and 8). This AC prohibits objects non-essential to air navigation or ground maneuvering purposes in ROFAs and states that fuel storage facilities may not be located in the RPZ. FAA Order 5190.6B (FAA 2009) reiterates that fuel storage facili- ties are a prohibited RPZ land use. Additionally, 14 CFR Part 77 (FAA 1993) establishes standards for determining obstructions to air navigation by defining criteria for imaginary surfaces that RUNWAY RUNWAY PROTECTION ZONE (RPZ) RUNWAY OBJECT FREE AREA (ROFA) CONTROLLED ACTIVITY AREA (CAA) CENTRAL RPZ BUILDING RESTRICTION LINE (BRL) NOT TO SCALE Figure 7. Controlled activity area [Figure 2-3 (FAA 1989)].

68 Assessing opportunities for Alternative Fuel Distribution Programs must not be pierced by any structure, including fuel production and storage facilities. Another consideration is that the proposed project must be shown on the ALP, as indicated in FAA Order 5190.6B (FAA 2009). FAA AC 150/5230-4A (FAA 2004) states that NFPA 407 (NFPA 2007) lists specifications for the design, operation, maintenance, and location of fuel storage areas and aircraft fueling devices. Generally, it requires that fuel pumps, storage tanks, and related facilities be at or below ground level. However, NFPA 407 itself does not give many specifics on the design and siting requirements of fuel facilities. NFPA 407 allows the authority having jurisdiction to establish these requirements. The authority having jurisdiction may be a federal, state, local, or other regional department or individual. The construction of alternative fuel facilities on or proximate to an airport will require an environmental review to adequately assess and disclose the potential for impacts to the environ- ment from such a facility. FAA Order 5050.4B (FAA 2006b) provides information relative to the environmental review process that may be required. A NEPA determination is required for an obligated airport. FAA Order 5050.4B specifies three types of reviews: categorical exclusions (CATEXs), environmental assessments (EAs), and environmental impact statements (EISs). The type of review required will be determined by the responsible FAA official with jurisdiction over the program. The type of review will also depend on the estimated significance of the impact of the pro- gram on the environment. A governmental agency’s involvement expands depending on the circumstances that are likely to be highly controversial on environmental grounds. FAA Orders 1050.1E and 5050.4B both stress the importance of early contact with the FAA to avoid delays in the NEPA process. Alternative fuel facilities located outside of the airport limits are not subject to the FAA policies and regulations governing on-airport facilities; however, near-airport and off-airport facilities must still comply with 14 CFR Part 77. For example, objects such as light poles, trees, construc- tion cranes, and even tall buildings (sometimes miles away from the airport) can be in violation of 14 CFR Part 77 and would, therefore, present a potential hazard to aircraft operating in the area. Form 7460-1, Notice of Proposed Construction or Alteration, needs to be completed and filed with the FAA prior to construction for an airspace analysis and determination for on- or off-airport programs. RUNWAY CROSS SECTION INNER TRANSITIONAL OBSTACLE FREE ZONE (OFZ) RUNWAY OBSTACLE FREE ZONE (OFZ) HORIZONTAL SURFACE 150 FEET ABOVE AIRPORT ELEVATION NOT TO SCALE 1 3 or 6† †DETERMINED BY AIRCRAFT CATEGORY AND APPROACH PRECISION HEIGHT SPECIFIED BY EQUATIONS (PARAGRAPH 306, FAA AC150/5300-13) Figure 8. Obstacle free zones around runways [Figure 3-5 (FAA 1989)].

evaluation Framework Step c 69 In addition to the FAA documents discussed in the previous paragraphs, it is important to indicate other resources available to jet fuel handlers. For example, A4A (formerly known as Air Transport Association or ATA) publishes the ATA Specification 103: Standard for Jet Fuel Qual- ity Control at Airports (ATA 2009). This document includes recommended specifications that have been developed to provide guidance for safe storage and handling of jet fuel at commercial airports. While these recommendations are not mandatory, they are very closely followed by all major airlines and airports in the United States. 6.2.4 Step 4: Identify Preliminary Alternative Fuel Storage Facility Development Sites The fourth recommended step in the process is to incorporate the findings of Steps 1, 2, and 3 to identify preliminary alternative fuel storage facility development sites. Typically, separate potential development sites would be identified for aviation- and non-aviation-related fuel stor- age; however, for some airports, it may be advantageous to consider the co-location of these fuel storage facilities. Key planning considerations in the siting of fuel storage facilities on the airport include (1) the provision of vehicular access, (2) the method of fuel distribution, and (3) the separation distances of storage tanks from adjacent buildings, property lines, and aircraft movement areas. With respect to vehicular access, the fuel storage sites must provide convenient landside access to the fuel delivery tankers that use the regional roadway transportation system as well as airside access to the refueler trucks that use a combination of internal non-licensed vehicle roads and airfield pavement to serve individual aircraft. These criteria include adherence to local roadway engineering design standards (lane dimensions, curb radii, outside radius, roadway cul-de-sac dimensions, etc.) for tanker trailer maneuvering and emergency vehicle response. Ideally, fuel storage facilities allow both off-airport and on-airport vehicles to access the site conveniently. Therefore, a design solution should be sought that accomplishes the following: • Minimizes travel times to and from the designated aircraft fueling areas • Minimizes or avoids the crossing of aircraft movement areas by refueler trucks • Does not interfere with future airport development or the expansion of aeronautical services, both airside and landside • Allows for off-airport vehicles that are unfamiliar with airport operations to safely and intui- tively utilize the facilities It is important to highlight the need to separate ground vehicle access and aircraft operational areas for safety and security reasons, as indicated in 14 CFR Part 139 and AC 150/5215-20, Ground Vehicle Operations on Airports. In addition, the location of fuel facilities should be outside the secure aircraft operational areas and in places that do not require vehicles to cross aircraft apron areas. This is particularly important if the fuel distribution system includes users not familiar with airport operations, such as private vehicles and taxis. For commercial service airports that dispense conventional jet fuel via a hydrant system from the storage facility to the terminal ramp, a piping system is required to supply the fuel to the hydrant valves located at the individual gate positions on the ramp. Therefore, a centralized fuel storage facility that is located in the general proximity of the terminal ramp area is preferred to reduce the expense associated with the underground piping distribution system. The advantages of implementing the hydrant fueling system at the terminal gate positions include a continuous supply of fuel to the aircraft that is not limited by the capacity and travel times of the refueler trucks, as well as the elimination of the refueler trucks from operating on the terminal ramp and their associated emissions.

70 Assessing opportunities for Alternative Fuel Distribution Programs In consideration of the specified separation distances between aviation fuel storage facilities and adjacent airfield development, the various NFPA documents offer some guidance contingent upon tank sizes and fuel types. For example, NFPA 407 provides specifications for the design, operation, maintenance, and location of fuel storage facilities, including aircraft fueling devices. NFPA 407 specifies that fuel storage tanks “located in designated aircraft movement areas or aircraft servicing areas shall be underground or mounded over with earth” and that the authority having jurisdiction shall determine the clearances required from adjacent airfield components with “due recognition given to national and international standards establishing clearances from obstructions.” Accord- ing to NFPA 415, “the authority having jurisdiction may be a federal, state, local, or other regional department or individual such as a fire chief; fire marshal; chief of the fire prevention bureau, labor department, or health department; building official; electrical inspector; or others having statutory authority.” Other generalized fuel storage facility design considerations specified in NFPA 407 include the following: • Fuel storage tanks shall conform to the applicable requirements of NFPA 30, Flammable and Combustible Liquids Code (e.g., siting criteria specifying separation/setback criteria from property lines, buildings, or public ways, and spacing between tanks). • Antennas of airport flight traffic and ground traffic surveillance radars shall be located so that the radar beam will be separated from any fuel storage area, loading racks, or aircraft fuel servicing areas by a minimum of 300 feet for flight traffic radar and 100 feet for ground traffic radar. • Parking areas for unattended aircraft fuel servicing tank vehicles shall be arranged to provide a minimum 50-foot separation from any parked aircraft or building other than designated maintenance facilities for these vehicles. In addition, the FAA AC 150/5300-13 prohibits the siting of fuel storage facilities within RPZs, and the Transportation Security Administration has published more comprehensive guidelines regarding the protection of fuel storage facilities. These security recommendations include the provision of security fencing that is access controlled to monitor all traffic movements. Also, closed-circuit television monitoring and various alarm systems should be considered for instal- lation at fuel storage facilities to enhance security surveillance. These documents and others should be referenced extensively to ensure compliance with specified separation development standards. 6.2.5 Step 5: Screen Sites and Prepare Preliminary Fuel Storage Facility Site Plans The fifth step in the process is to develop a draft schematic site plan and begin to screen the sites for compliance with applicable FAA design criteria, NFPA codes and standards, and local fire codes associated with fuel storage facilities and methods for distribution. In addition, for each alternative site, the airport should consider and document the following: • Consistency with existing regional transportation planning documents • Compliance with existing zoning and comprehensive planning documents • Cursory compliance review of draft schematic site plan with applicable federal and state regulatory agencies • Supplemental hazard to flight analysis (e.g., FAA airport design criteria and FAR Part 77) • Preliminary environmental review of the draft schematic site plans It may also be helpful to develop a scoring or ranking system for the alternative sites in an effort to determine a preferred or recommended site.

evaluation Framework Step c 71 6.2.6 Step 6: Select One of the Recommended Fuel Storage Facility Site Plans The sixth step in the process is to identify and select one or more recommended alternative fuel storage site plans. This step includes the initiation of preliminary design and engineering drawings with cost estimates for proposed development. In this step, it will be important to do the following: • Identify those portions of the program that may be eligible for federal or state funding participation • Confirm FAA grant assurance compliance and legal considerations • Prepare FAA Form 7460-1 for airspace analysis • Update ALP Drawing Set to reflect selected alternative fuel storage facility site plans • Submit updated ALP Drawing Set to FAA for review and approval • Implement NEPA process: review for potential CATEX for proposed action, or determine the need for environmental analysis based on potential for extraordinary circumstances. Review program for the potential need to conduct EA for those proposals involving a change to the ALP or federal funding participation • Apply for necessary state and local environmental permits, such as those pertaining to water quality, air quality, and noise 6.2.7 Step 7: Construct Alternative Fuel Storage Facility The seventh step in the process is to implement construction of the alternative fuel storage and distribution facility including the finalization of design and engineering drawings with cost estimates for proposed development. Also, if applicable, coordinate the phasing of any support projects that are related to the construction of the alternative fuel facility (such as access road, gates, etc.) and obtain local building or construction permits. This process has numerous steps and requires more detailed instructions than can be given in this guidebook. Readers are encour- aged to engage outside experts for further guidance. 6.3 Environmental Reviews and Permitting Environmental reviews and permitting will be requisite activities in the planning process for any alternative fuel distribution program. Jurisdictions at the federal, state, and local levels require permits for those activities or facilities that they view as affecting the environment, safety, or equity of the surrounding population. Alternative fuel distribution programs affect each of these three components. In general terms, the main categories of interest in the environmental review and permitting process tend to be the following: • Water quality, including environmental impact on drinking and ground water, wastewater, and surface waters including storm water, coastal areas, wetlands, or floodplains • Air quality, including environmental impact of gaseous and other emissions • Impacts to historic landmarks, coastal regions, endangered species, or other environmental resources by facility construction, operation, maintenance, or access • Land quality, including solid waste disposal, hazardous waste handling and disposal, and spill prevention, reporting, and cleanup • Land use planning and zoning, including impacts to shared infrastructure such as roads and railways

72 Assessing opportunities for Alternative Fuel Distribution Programs 6.3.1 Environmental Review At the federal level, alternative fuel programs need to comply with the NEPA and applicable laws protecting sensitive environmental resources. NEPA outlines a process by which agencies are required to determine if their proposed actions have significant environmental effects. Depend- ing on a number of factors, including the severity of the environmental effects, a CATEX, EA, or EIS may be required (see FAA Order 1050.1E for more information). Environmental effects that should be analyzed may include growth-inducing effects related to changes in land use and population density, and related effects on air and water and other natural systems, including potential impacts to ecosystems that an action may cause. In particular, the environmental issues addressed in the Environmental Desk Reference for Airport Actions (FAA 2007), or Appendix A of Order 1050.1E, should be investigated during the NEPA process. This must occur thoroughly before the FAA makes a decision on approving an alternative fuel facility. At the state and local level, environmental review and permitting requirements and regula- tions vary to a high degree. Many states are developing review processes and integrated guidance materials on environmental review and permitting activities relative to infrastructure that may be applicable to alternative fuel programs (see Appendix C). Furthermore, the EPA maintains a database of state-specific regulatory information at http://www.epa.gov/lawsregs/states/index. html#state. Readers should consult this resource for guidance specific to their local conditions. 6.3.2 Environmental Permitting This section provides an overview of federal, state, and local permitting processes to identify the breadth of permitting requirements that might be expected in developing alternative fuel production, storage, and distribution infrastructure. This is not intended to be a comprehensive review as requirements and processes vary from jurisdiction to jurisdiction. There are various motivations for permitting, primarily to ensure protection of public health, safety, and environmental quality. Permitting requirements vary from state to state and have local nuances with respect to county, city, and other jurisdictional requirements—and they apply to the production of alternative fuels as they do to any other facility. Most of the existing guidance issued by jurisdictions pertains to biodiesel facilities. For exam- ple, the State of Washington has two publications pertaining to biodiesel permitting. One of them is a fact sheet that lists the permits, regulations, and tax benefits associated with a biodiesel plant (State of Washington 2010a). The other publication appears on the State of Washington’s Department of Ecology website (State of Washington 2010b). Table 10, taken from that website, lists the permits that a biodiesel manufacturer should consider; furthermore, the department notes that while these are “commonly required permits,” considerations “are not limited to” those listed in Table 10. The permitting process for biodiesel should be a reasonable approxima- tion for that of other alternative fuels. 6.3.3 Land Use and Zoning in the Vicinity of Airports Being a good neighbor is often a principle that airports adopt, as it fosters a mutually benefi- cial relationship between airport operators and surrounding developments and avoids poten- tially costly litigation. To avoid conflict with airport surroundings, land use zoning must be done carefully. Zoning rules and regulations vary considerably from one jurisdiction to another, and it is not practical to summarize them in this document. Airports should consult ACRP Report 27: Enhancing Airport Land Use Compatibility, Volume 1 (Ward et al. 2010) and the FAA Land Use

evaluation Framework Step c 73 Compatibility and Airports report (FAA 2001) for a deeper discussion of this topic. Nevertheless, there are a few general observations that can help airports evaluate alternative fuel programs with respect to zoning: • Obstacles to air navigation: The FAA requires that there be no object, man-made or natural outgrowth, that is 200 feet from the ground level of the airport and within a 3-nautical-mile radius of the established reference point of the airport. Other requirements are listed in FAR Part 77. • Noise assessment: If construction of alternative fuel facilities requires modifications to exist- ing airspace procedures, a proper EIS may be needed before the FAA can approve route changes when there is a significant noise impact on the affected population. A NEPA deter- mination is needed at obligated airports. See Section 6.3.1 for more information. Jurisdiction Type of Permit City and county Building Preliminary/final plat Grading Water system Shoreline Right of way Utility Site plan review Septic system Floodplain development Variance (e.g., zoning, shoreline) Outdoor burning State Department of Fish and Wildlife – Hydraulic project approval – Bald eagle management – Grass carp – Shooting preserve Department of Natural Resources – Forest practices – Aquatic lease – Burning (forest slash) – Reclamation Department of Ecology – Water rights – Well drilling – National Pollutant Discharge Elimination System (NPDES) – Water quality certification – Storm water – Underground storage tank certification – Dangerous waste Air Authority/Department of Ecology – New source review, for a business or industry – Notice of intent, for demolition projects Federal U.S. Army Corp of Engineers – Section 10 (navigable waters) – Section 404 (fill in waters) U.S. Coast Guard – Section 9 (bridges) National Marine Fisheries/U.S. Fish and Wildlife Endangered Species Act consultation Table 10. Examples of commonly required permits (State of Washington 2010b).

74 Assessing opportunities for Alternative Fuel Distribution Programs • Agricultural land near airports: The FAA recommends against using airport property for agricultural production because agricultural crops can attract wildlife during some phases of production (FAA 1997). If the airport requires agricultural crops as a means to produce income necessary for the viability of the airport, it needs to follow the crops distance guide- lines established in AC 150/5300-13, Appendix 17. Airports should be advised that the FAA may require a Wildlife Hazard Assessment (WHA) or a Wildlife Hazard Management Plan when specific triggering events occur on or near an airport, as specified in 14 CFR Part 139. Such events include an aircraft ingesting or striking wildlife or observation of wildlife of a size or in numbers capable of causing an aircraft strike or engine ingestion. The WHA must be conducted by biologists with the appropriate training and education as specified in AC 150/5200-36A. Agricultural land use is compatible with airport operations from a noise sen- sitivity perspective (FAA 2001). 6.3.4 Additional Notes on Permitting One significant risk with the permitting process is that it can stall a program’s implementa- tion or scuttle it entirely. Because of this risk, incorporating adequate lead time is absolutely necessary to meet all permitting requirements and to avoid delays in program coordination, planning, design, engineering, site preparation, and construction necessary for the development of alternative fuel infrastructure. Front-end planning with appropriate time buffers provides flexibility in schedule adherence. This section has emphasized the motivation, complexity, and uncertainty associated with permitting. Because each alternative fuel facility carries its own risks, the permitting process should be customized to each situation. Therefore, airports are advised to utilize a consultant with expertise in this matter.