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Wetland Mitigation, Volume 2, A Guidebook for Airports (2019)

Chapter: Chapter 8 - Public Outreach and Stakeholder Involvement

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Suggested Citation:"Chapter 8 - Public Outreach and Stakeholder Involvement." National Academies of Sciences, Engineering, and Medicine. 2019. Wetland Mitigation, Volume 2, A Guidebook for Airports. Washington, DC: The National Academies Press. doi: 10.17226/25486.
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Suggested Citation:"Chapter 8 - Public Outreach and Stakeholder Involvement." National Academies of Sciences, Engineering, and Medicine. 2019. Wetland Mitigation, Volume 2, A Guidebook for Airports. Washington, DC: The National Academies Press. doi: 10.17226/25486.
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Suggested Citation:"Chapter 8 - Public Outreach and Stakeholder Involvement." National Academies of Sciences, Engineering, and Medicine. 2019. Wetland Mitigation, Volume 2, A Guidebook for Airports. Washington, DC: The National Academies Press. doi: 10.17226/25486.
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Suggested Citation:"Chapter 8 - Public Outreach and Stakeholder Involvement." National Academies of Sciences, Engineering, and Medicine. 2019. Wetland Mitigation, Volume 2, A Guidebook for Airports. Washington, DC: The National Academies Press. doi: 10.17226/25486.
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Suggested Citation:"Chapter 8 - Public Outreach and Stakeholder Involvement." National Academies of Sciences, Engineering, and Medicine. 2019. Wetland Mitigation, Volume 2, A Guidebook for Airports. Washington, DC: The National Academies Press. doi: 10.17226/25486.
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Suggested Citation:"Chapter 8 - Public Outreach and Stakeholder Involvement." National Academies of Sciences, Engineering, and Medicine. 2019. Wetland Mitigation, Volume 2, A Guidebook for Airports. Washington, DC: The National Academies Press. doi: 10.17226/25486.
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Suggested Citation:"Chapter 8 - Public Outreach and Stakeholder Involvement." National Academies of Sciences, Engineering, and Medicine. 2019. Wetland Mitigation, Volume 2, A Guidebook for Airports. Washington, DC: The National Academies Press. doi: 10.17226/25486.
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Suggested Citation:"Chapter 8 - Public Outreach and Stakeholder Involvement." National Academies of Sciences, Engineering, and Medicine. 2019. Wetland Mitigation, Volume 2, A Guidebook for Airports. Washington, DC: The National Academies Press. doi: 10.17226/25486.
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Suggested Citation:"Chapter 8 - Public Outreach and Stakeholder Involvement." National Academies of Sciences, Engineering, and Medicine. 2019. Wetland Mitigation, Volume 2, A Guidebook for Airports. Washington, DC: The National Academies Press. doi: 10.17226/25486.
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Suggested Citation:"Chapter 8 - Public Outreach and Stakeholder Involvement." National Academies of Sciences, Engineering, and Medicine. 2019. Wetland Mitigation, Volume 2, A Guidebook for Airports. Washington, DC: The National Academies Press. doi: 10.17226/25486.
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73 8.1 Introduction Public outreach, also referred to as community involvement or public involvement, is the process of informing, engaging, and collaborating with those who could be affected by a pro- posed project or action. Chapter 8 focuses on the public outreach and stakeholder involvement for airport projects that involve potential impacts to jurisdictional wetlands and waters of the U.S. The chapter summarizes: • Pertinent regulations and background associated with the FAA and the USACE, which are the primary federal agencies involved in airport projects and wetlands, and their obligations to perform public involvement pursuant to NEPA; • Guidance for early stakeholder outreach and identification; • Tools and resources for identifying and communicating with stakeholders; • Guidance for engaging stakeholders during scoping to gain input on project design and mitigation; and • The benefits of stakeholder involvement and collaboration as illustrated by case studies. 8.2 Regulatory Background: NEPA NEPA is our nation’s basic national charter for environmental protection. Codified in Title 14, Sections 1500 to 1508 of the Code of Federal Regulations (CFR), NEPA establishes policy, sets goals for carrying out the policy, and informs federal agencies about what they must do to comply with the Act. NEPA procedures must ensure that environmental information is made available to public officials and citizens before project decisions are made and actions are taken (14 CFR Part 1500.1). In many cases, airport projects that affect jurisdictional wetlands and waters of the U.S. will also affect other resources, and an airport opera- tor or the FAA will be responsible for preparing a NEPA document and undertaking stakeholder involvement. In other cases, a project may not be subject to an FAA NEPA process, and the USACE would serve as the lead federal agency responsible for permitting or project authoriza- tion and necessary responsible public outreach. Much of this chapter addresses stakeholder involvement within an overall NEPA context for primarily two reasons: NEPA governs the stakeholder involvement that would be undertaken by either the FAA or the USACE, and airport C H A P T E R 8 Public Outreach and Stakeholder Involvement According to CEQ regulations, a federal agency must initiate the NEPA process “at the earliest possible time” and “consult early with appropriate state and local agencies and Indian tribes and with interested private persons and organizations . . .” (40 CFR 1501.2d[2][3]) A stakeholder is a person (or group) who is responsible for making or implementing a management action, who will be significantly affected by the action, or who can aid or prevent its implementation.

74 Wetland Mitigation, Volume 2: A Guidebook for Airports operators and the FAA are frequently required to address wetland impacts and mitigation as part of a larger environmental compliance effort, such as an EA or EIS, that requires a NEPA document to be prepared. Although the federal statutes and regulations provide general guidelines for implementing the NEPA process, including public involvement and outreach, federal agencies have great flex- ibility in developing specific strategies to fulfill the federal statutes, and both the FAA and the USACE have developed their own public outreach approach and framework. 8.2.1 Federal Aviation Administration Any project that requires FAA approval (or action), such as the modification of an Airport Layout Plan (ALP), the construction of a new facility on airport property, or any project with federal funding, is subject to NEPA. The FAA implements NEPA through Order 1050.1F and Order 5050.4B. Both orders provide guidance for conducting environmental reviews and for achieving the minimum public involvement required by NEPA. In addition to NEPA, the FAA’s commitment to community involvement is articulated in its 1995 Community Involvement Policy Statement (FAA n.d.): The public has a right to know about our projects and to participate in our decision-making process. To ensure that FAA actions serve the collective public interest, all stakeholders will have an opportunity to be heard. Our goals are: • To provide active, early, and continuous public involvement; • To provide reasonable public access to information; • To provide the public an opportunity to comment prior to key deci- sions; and • To solicit and consider public input on plans, proposals, alternatives, impacts, mitigation, and final decisions. Although the guidance is intended for FAA staff specifically, airport sponsors also find it useful. 8.2.2 United States Army Corps of Engineers As a federal agency, the USACE is also subject to NEPA, and its implementing regulations are codified in Title 33 of the CFR, Section 325, Appendix B, NEPA Implementation Procedures for the Regulatory Program. Public involvement plays a central role in the USACE regulatory program. The USACE considers the results of a public interest review when deciding whether to issue or deny a permit. The public interest review includes an analysis of the foreseeable impacts of the proposed project on public interest factors. These factors include general environmental concerns, wetlands, eco- nomics, fish and wildlife values, land use, floodplain values, and the needs and welfare of the people (USACE, n.d.). Table 8-1 contains a summary of the USACE public involvement requirements associated with Section 404 of the CWA. When an individual permit is needed, the USACE is responsible for initiating all public out- reach, receiving public comments, and reviewing comments on behalf of project applicants. If The FAA prepared specific guidance pertaining to community involvement in its 2016 FAA Community Involvement Manual (FAA 2016), available at: • https://www.faa.gov/about/office_org/ headquarters_offices/apl/environ_ policy_guidance/guidance/media/ faa_cim.pdf.

Public Outreach and Stakeholder Involvement 75 an airport sponsor undertakes a NEPA application, the USACE will participate in the applicant/ airport sponsor’s public outreach activities and the applicant’s agency scoping efforts. 8.3 Early Stakeholder Outreach Regardless of the project, its proposed mitigation, or the agency responsible for conducting public outreach, the NEPA regulations are clear: Project sponsors must reach out to stakeholders early. However, the way an airport sponsor initiates stakeholder involvement will vary slightly based on the type of project involved: • If the airport is responsible for preparing a NEPA document such as an EA, stakeholder out- reach and identification must be initiated through the “project scoping” efforts associated with the preparation of the NEPA document. • If a NEPA document is not required, but the project requires a Section 404 permit from the USACE, an airport sponsor should identify potential stakeholders as part of the USACE pre- application process, so that the USACE can include those potential stakeholders in its public notification process. According to the CEQ regulations implementing NEPA, a federal agency must initiate the NEPA process “at the earliest possible time” and “consult early with appropriate state and local agencies Permit Application/Authorization Public Involvement Requirements Letter of Permission (LOP) Applies to minor work that should not have individual or cumulative impacts on environmental values and should not have appreciable opposition. -The USACE provides for an abbreviated coordination process for LOPs that considers input from resource agencies and property owners in the immediate vicinity of a proposed project. -Recommended pre-application consultation occurs among applicant, the USACE district, and interested resource agencies (federal, state, or local agencies). (This is similar to the FAA agency scoping meeting described below.) Individual Permits -Recommended pre-application consultation among applicant, USACE district, and interested resource agencies (federal, state or local agencies). -Applicant submits permit application. -The USACE initiates public notice within 15 days of receipt of a complete application to solicit comments from the public, adjacent property owners, interested groups and federal, state, and local agencies. -The USACE initiates 15- to 30-day public notice comment response period (duration depends on nature of activity) -The USACE provides applicant with an opportunity to respond to public comments received. -The USACE conducts a public hearing (if necessary). -The USACE performs a public interest review and evaluates Section 404(b)(1) guidelines. -The USACE approves or disapproves the permit application. General Permits -Public notice, comment, interest reviews, and hearings are completed when the general permit is issued by the USACE every 5 years. Those items are not required to verify individual actions or projects that fit within the general permit once it is authorized. -If project qualifies for a general permit, it will not require public notice, comment, interest reviews, or hearings at the time of application/issuance. Source: USACE Louisville District. n.d. Permit Processing Information. Available at: http://www.lrl.usace.army.mil/Portals/64/docs/regulatory/Permitting/PermittingProcessInformation.pdf Table 8-1. USACE permit review and public involvement process.

76 Wetland Mitigation, Volume 2: A Guidebook for Airports and Indian tribes and with interested private persons and organiza- tions . . .” (40 CFR 1501.2d[2][3]). 8.3.1 Public Scoping for NEPA Documents If a NEPA document is required for a project that will affect wetlands or jurisdictional waters of the U.S., such as an EA or EIS, public scoping occurs prior to the development of a NEPA document for two reasons: • To alert agencies and other stakeholders of an upcoming project early on and • To gain input to help frame the forthcoming NEPA analysis. The FAA has long recognized that early public involvement allows valuable information to be factored into subsequent project planning. Early scoping efforts can allow the FAA and project sponsors to: • Identify and engage the right stakeholders for meaningful input; • Identify, consider, and address concerns or conflicts before the final project design and subsequent mitigation have been determined; • Prevent misunderstandings by the public and dispel project-related rumors; and • Gain a better understanding of the community, local environment, and the value that the community places on its resources. Scoping is conducted to identify the breadth and potential signifi- cance of issues to be addressed when evaluating a proposed action. By collaborating early, a lead agency (FAA) or project sponsor (airport) can help ensure that the analysis adequately addresses those issues of impor- tance to affected stakeholders and interested parties. A public scoping meeting is frequently held prior to the development of a NEPA docu- ment that includes potentially affected public agencies, jurisdictions, airport neighbors, and other stakeholders. (A scoping meeting is similar to the pre-application consultation recommended by the USACE.) Early scoping activities, such as pre-planning a data review and dis- cussion with identified stakeholders, can help to define the planning area, identify potentially overlooked stakeholders, and help to solicit opinions and advice on how to proceed with planning and mitigation (USEPA 2013). 8.3.2 The Role of the FAA and Federal Agency Consultation The FAA is responsible for coordination with other federal agen- cies as part of the NEPA process. Other federal agencies include, but are not limited to, the USACE, the USFWS, the Department of the Interior/State Historic Preservation Officer, Native Ameri- can tribal representatives, and others. The input and data obtained during public scoping often serves as the foundation of the formal, federal, agency-to-agency consultation processes that occur during the development of an EA or EIS and the subsequent permit review processes. USACE Outreach Terms Pre-application Consultation – One or more meetings with an applicant, Corps District staff, and interested resource agencies (federal, state, or local). The consultation includes informal discus- sion to identify jurisdictions, practicable alternatives, NEPA procedures and documents, and mitigation. Public Interest Review – Evaluation of a proposed activity to determine if the issuance of a permit is in the public interest. Public Notice – The primary method of advising interested public agencies and private parties of a proposed activity and to solicit comments and information necessary to evaluate the probable project impacts on the public interest. Public Hearing – A meeting held to acquire additional information associated with a permit application. Traditionally Underserved Stakeholders Public involvement must include everyone and address a full range of community interests. Traditionally underserved stakeholders are those who have experienced barriers to public participation and decision- making processes based on cultural, linguistic, and economic differences, or other barriers. Traditionally under- served stakeholders include individuals from minority, tribal, and low-income groups. Federal agencies must reach out to traditionally underserved com- munities so that they may participate in public outreach activities.

Public Outreach and Stakeholder Involvement 77 Airport operators who use federal funds or require federal approvals must work with the FAA to fulfill NEPA requirements and support federal agency consultation. For example, airport operators are responsible for preparing CatExs or EAs to support proposed projects, but the FAA must approve those documents. When an EIS is required, the FAA must prepare the EIS with support from the airport operator as requested. The FAA is responsible for consulting with federal agencies, such as the USACE, when permits are required, and reviews proposed mitigation strategies and measures during the NEPA process to make sure that they are consistent with aircraft operations, but the airport operator or project applicant is responsible for obtaining and fulfilling permit requirements. 8.3.3 Public Scoping to Support Section 404 Permits and Authorizations As shown in Table 8-1, public outreach is central to the USACE’s process for granting a letter of permission or permit. The USACE issues public notices to alert stakeholders of a proposed project when an individual permit is necessary. The public notice is used to solicit comments and information to evaluate the project’s foreseeable impacts on the public interest. Any stakeholder may request that the USACE hold a public hearing to gain additional information for evaluating the permit application. If an airport sponsor is preparing a NEPA document for a proposed project that will require a Section 404 permit, the USACE will often participate in a scoping meeting or use the information obtained during scoping efforts for the NEPA document to evaluate the permit application. 8.4 Identifying Stakeholders Those who could be affected by or have an interest in a proposed project—those who have a stake in the project—are known as stakeholders: “A stakeholder is a person (or group) who is responsible for making or implementing a management action, who will be significantly affected by the action, or who can aid or prevent its implementation. . . . Engaging and involv- ing stakeholders means recruiting stakeholder group members and using their strengths and knowledge . . .” (USEPA 2013, p.1). The number and type(s) of stakeholders associated with a proposed project vary sig- nificantly based on the type of project, its location, and the nature and extent of its poten- tial impacts. At a minimum, stakeholders include agencies with jurisdiction over the land or resources involved and those who might be affected directly by a proposed project. Table 8-2 identifies some of the potential stakeholders associated with airport projects requiring wetland mitigation. Since stakeholders include both those involved in making decisions and those affected by decisions, the stakeholders, their roles, and level of involvement will vary according to the size and nature of a project. Table 8-3 presents specific questions or tips to help identify the most appropriate stakeholders for a specific project. These questions can be used to develop a list of potential stakeholders that could be involved in project scoping or mitiga- tion planning. 8.5 Engaging Stakeholders After potential stakeholders have been identified, the airport sponsor must determine the best way to involve stakeholders in project planning and mitigation design.

Type of Stakeholder Potential Agency/Stakeholder Airport Operators Agencies or jurisdictions that operate an airport or communities in which airports reside: - State Transportation Agencies, - Airport Commissions or Districts, - Counties, and - Cities Federal Agencies Agencies that may have jurisdiction over wetlands and waters of the U.S., listed species that may occur in wetlands or waters, or other agencies who have jurisdiction over resources that could be affected by projects involving wetlands and proposed mitigation sites: - FAA, - NMFS, - Tribal Historic Preservation Office/Tribal Representatives, - USACE, - USEPA, - U.S. Department of the Interior/SHPO, and - USFWS (federally listed species and their critical habitats). State Agencies State agencies that have jurisdiction over wetlands and waters, or other agencies, state-listed species that may occur in state-regulated wetlands or waters, and other agencies who have jurisdiction over other resources that could be affected by projects involving wetlands and proposed mitigation sites: - SHPO, - State Water Resources Agencies (wetlands/waters under state jurisdiction), and - State Wildlife Management Agencies (state-listed species and their critical habitats). Local Agencies Local agencies that may have a role in resource policy and management: - City/County Planning and Development Departments, - City/County Departments of Public Works, and - Environmental Review/Permitting Departments. Airport Neighbors - Neighborhood Associations and Committees, - Adjacent or Affected Landowners and Tenants (including businesses), and - Airport Tenants who may be affected by a project or proposed mitigation Special-purpose Groups - Land Trusts, - Watershed Preservation/Restoration Groups, - Habitat Conservation Groups, and - Wildlife Advocates (e.g., Audubon Society, species-specific interest groups, etc.). Source: Mead & Hunt and the FAA Community Involvement Manual (Federal Aviation Administration 2016). Table 8-2. Types of stakeholders. Topic/Consideration Questions/Concerns Identify Geographic Features - What geographic features, resources, and landmarks might your project affect (wetlands, waters of the U.S., species that inhabit jurisdictional resources or adjacent habitat)? - Are there ongoing challenges associated with those features and resources (e.g., watershed restoration, habitat for a specific species)? Identify Applicable Agency Stakeholders - What federal, state and local agencies or organizations might have an interest in the resource (for example, Coastal Commission, Department of Public Works, Conservation Districts, etc.)? - What agencies are responsible for making a decision or issuing an approval for the proposed project and its mitigation? Consider Political Boundaries, Jurisdictions, and Your Neighborhood - What are the political boundaries/jurisdictions associated with your project site and its resources? - Does the airport or project include multiple jurisdictions? - Does the airport routinely work with a neighbor’s committee, citizen’s advisory group, or homeowners’ association? Identify Attitudes and Perceptions - What are the attitudes or perceptions about the airport and its proposed improvements? - What are the attitudes and perceptions about the resources, features, or landmarks that could be affected by the proposed project? - Is there known controversy over the use of local resources (for example, pro- development vs. no-growth constituencies, etc.)? Review Previous Airport Projects or Other Projects Affecting Wetlands and Jurisdictional Waters - What projects or activities have affected wetlands and jurisdictional waters in the past? - What tools or barriers have prevented them from being affected? - Identify controversy associated with previous projects, who was involved in the conflict/controversy and its resolution or outcome. Source: USEPA 2013. Table 8-3. Helpful questions to identify stakeholders.

Public Outreach and Stakeholder Involvement 79 A scoping meeting is usually the most expedient method for identifying specific project- related issues and concerns. The primary goal of the scoping meeting is to present the proposed project and to build partnerships for further consultation throughout project development and mitigation planning. Table 8-4 presents important topics that a project sponsor should address with stakeholders during a scoping meeting. 8.5.1 Stakeholder Follow-up Early scoping meetings provide project sponsors with an opportunity to describe their project to all stakeholders at once, answer questions early on, identify potential conflicts, and gain input for subsequent project design and review. (See Figure 8-1.) However, follow-up is important. Not all stakeholders will have the same understanding of a resource, regulatory frameworks, or the specific challenges associated with wetland mitigation and aviation safety. Targeted outreach to specific stakeholders may be necessary through small groups or one-on-one meetings. 8.5.2 Documentation Public involvement is required under NEPA, and all stakeholder meetings (meeting notices, agendas, materials, and notes) should be documented. Careful documentation can be used to demonstrate that diverse viewpoints were considered during project and mitigation General Topic Specific Items Project Background - Describe the proposed project, purpose and need. - Provide preliminary design. - Identify outstanding data or other unknowns. Regulatory Background - Identify regulatory agencies. - Review applicable regulations. Project Impacts to Wetlands and Waters of the U.S. - Note potential project-related impacts identified to date. - Identify potential cumulative impacts. Known Resources in the Project Area - Identify known resources in the project area that could be affected by the proposed project. Examples of resources include, but are not limited to: o Protected or listed plant and animal species o Wildlife conservation areas o Cultural or archaeological resources o Public parks Mitigation Needs - Characterize project-related mitigation needs. - Characterize mitigation needs for the resource as a whole or for a broader geographic area. Mitigation Planning Goals - Identify regulatory goals for the resource. - Identify community goals for the resource (social or economic concerns). - Identify other mitigation restoration efforts (recent or ongoing). Special Concerns Associated with Aviation Safety, Wetlands, and Mitigation - Identify known wildlife hazards posed by wetlands and standing water. - Identify types of mitigation to avoid or reduce wildlife hazards (underground storage, bird balls, etc.). - Describe the Memorandum of Understanding among federal agencies to cooperate to prevent wildlife hazards at airports. Stakeholder Roles and Expectations - Provide input to project design to avoid or minimize impacts. - Provide input to mitigation planning. - Identify timeframe for stakeholder involvement and activities. - Identify methods for communicating with stakeholders. - Describe the anticipated outcome of stakeholder involvement (e.g., refined design, collaborative mitigation plan, etc.). Source: USEPA 2013. Table 8-4. Recommended content for stakeholder meetings involving wetlands and jurisdictional waters.

80 Wetland Mitigation, Volume 2: A Guidebook for Airports planning, even if those viewpoints were not incorporated into the final project description or mitigation design. 8.6 Benefits of Stakeholder Involvement The diverse perspectives presented through stakeholder involvement can lead to long-lasting benefits to airport operators, regulatory agencies, and their communities. 8.6.1 Enhanced Safety Airport operators understand that wetlands can attract wildlife hazards such as waterfowl and flocking birds. FAA guidance in AC 150/5200-33 warns airport operators against constructing wildlife attractants within 10,000 feet of aircraft movement areas at airports that support jet air- craft and within 5 miles of approach/departure corridors. Such guidance is contrary to wetland mitigation goals that promote on-site or nearby mitigation whenever possible and within the same watershed. The mitigation planning associated with each case study presented in Chapter 9 and described in the following paragraphs identified the potential conflict between wetland mitigation goals and wildlife hazard management. Each airport operator provided outreach to and worked with agency stakeholders to explain potential conflicts specific to aviation and identify an acceptable location for project-related mitigation in accordance with FAA’s separation criteria or to provide site-specific mitigation designs that would fulfill functional wetland values without compromis- ing aviation safety. • Airport operators at La Crosse Airport (Case Study No. 2), Nut Tree Airport (Case Study No. 4), and Pullman-Moscow Airport (Case Study No. 5) worked with regulatory agencies to establish off-site mitigation areas in distant locations in accordance with FAA guidance. • Wetland mitigation for improvements to the Manchester-Boston Regional Airport (Case Study No. 3) included the construction of an adjacent wetland restoration/creation site and the establishment of a conservation easement on adjacent property. The NHDES allows the airport operator to perform ongoing maintenance in the restoration/creation site so that trees can be removed when they create obstructions to navigable airspace. Figure 8-1. Public involvement. Early scoping meetings contribute to project success. Photo courtesy of Mead & Hunt.

Public Outreach and Stakeholder Involvement 81 8.6.2 Regional Benefits Airport-agency outreach can yield results that extend beyond the project and benefit the greater community and region, as well as contribute to the overall health of wetland resources and habitats. The City of Jacksonville’s Master Plan approach to redevelopment of the former Cecil Field Naval Air Station led to the creation of an approximately 6,000-acre on-site natural corridor area that provides statewide environmental benefits (Case Study 1 in Chapter 9). The City of Jacksonville’s collaboration with numerous stakeholders facilitated agency consensus during the development of a Corridor Management Plan as compensation for conceptual impacts associated with long-range site redevelopment. The Corridor Management Plan provided numerous regional and statewide benefits and fur- thered the goals of several stakeholders—accomplished only by working together. In addition to providing programmatic and streamlined mitigation for subsequent master plan development, the project affirmed the interest of all stakeholders in preserving, enhancing, or restoring intact wetland and upland systems. In addition to preserving unique and relatively undisturbed wet- lands and upland forests, the stakeholders worked together to achieve consensus on a manage- ment plan that provides connections to other resources (Jennings State Forest, Brannan Field Mitigation Park, and Camp Blanding) and offers passive, resource-based recreation opportuni- ties for the community. 8.6.3 Economic Benefits/Cost Savings Early stakeholder involvement and collaborative solutions can result in tangible, economic benefits. Solano County’s Nut Tree Airport was challenged by tall eucalyptus trees that pen- etrated the airport’s transitional surface (see Case Study No. 4 in Chapter 9). To address these obstructions, the County needed to remove approximately 1,750 non-native eucalyptus trees from riparian areas located near the runway or face operational limitations up to and includ- ing airport closure by the California Department of Transportation’s (Caltrans’s) Division of Aeronautics. The County was required to obtain a Streambed Alteration Agreement from the Califor- nia Department of Fish and Wildlife (CDFW) prior to tree removal. Although the trees were located above the mean high-water mark and were composed almost entirely of non-native eucalyptus trees, state resource managers with CDFW considered the trees to be located within a riparian forest, and the project required mitigation in the form of riparian planting with native species. Mitigation seemed daunting as the small airport did not have sufficient area for on-airport mitigation, local mitigation banks did not offer riparian credits, and the cost to purchase land, design, and construct would be cost prohibitive (greater than $3 million). The County reached out to diverse stakeholders such the Solano County Water Agency (SCWA) (a local water provider), regulatory agencies, and the Lower Putah Creek Council (a grassroots watershed restoration group). Working together, the airport and its stakehold- ers identified a feasible, cost-effective solution that furthered the goals of several stakeholders. Solano County agreed to pay for the planting and irrigation of more than 2,500 trees of native species in a previously identified restoration area that SCWA owned through a partnership with the Lower Putah Creek Council. The CDFW supported the Lower Putah Creek Council’s ongo- ing restoration efforts and agreed to accept the alternative in-lieu-fee mitigation as compensa- tory mitigation and authorized the Streambed Alteration Agreement required for obstruction removal at the airport. The County fulfilled its mitigation requirements for $150,000, a fraction of the cost associated with wetland construction.

82 Wetland Mitigation, Volume 2: A Guidebook for Airports 8.7 Many Stakeholders, Many Goals Public involvement involves numerous stakeholders, some of which have competing goals or interests. Although public involvement does not guarantee an outcome that will satisfy everyone, early and ongo- ing stakeholder involvement for all projects—not just those involving wetlands or other environmental resources—can provide opportuni- ties to educate agencies, communities, and other stakeholders; build consensus; and prevent misunderstandings. Moreover, decisions that consider input from a variety of diverse stakeholders and perspectives are more likely to receive broader community acceptance and avoid unanticipated controversy. As FAA guidance suggests, effective stake- holder involvement can help to build long-term relationships among diverse stakeholders and provide an improved understanding of com- munity concerns, improved transparency between airports and their communities, and better decisions (FAA 2016). 8.8 Summary Public outreach is a critical component for identifying potential project- related impacts to jurisdictional wetlands and waters of the U.S., and both the FAA and USACE are required to perform public involvement pursuant to NEPA. NEPA makes clear that project sponsors must reach out to stakeholders early so that they have an opportunity to provide meaningful input during the development of project alternatives, impact evaluation, and mitigation planning. Identifying wetland mitigation strategies is especially challenging in an airport environ- ment; numerous agencies and stakeholders are frequently involved, and not all mitigation strategies are applicable in an aviation environment. For example, USACE wetland preserva- tion and mitigation goals do not always coincide with aircraft operations and FAA policy. Public outreach and early stakeholder involvement are critical for identifying and address- ing the challenges associated with these potentially diverse goals. Through early stakeholder involvement, airport operators can gain valuable input from diverse perspectives to help identify solutions that enhance safety, offer regional environmental benefits, and provide economic benefits/cost savings. Although public involvement cannot guarantee that every- one will be satisfied with project outcomes, stakeholder engagement can help the broader community understand and accept project-related decisions and help project sponsors avoid unanticipated controversy. For additional information about stake- holder engagement (airports, wetlands, and watersheds): • FAA Community Involvement Manual (2016). Available at: https://www.faa. gov/about/office_org/headquarters_ offices/apl/environ_policy_guidance/ guidance/media/faa_cim.pdf. • Getting in Step: Engaging Stakeholders in Your Watershed, Second Edition. Available at: https://cfpub.epa.gov/ npstbx/files/stakeholderguide.pdf. • Public Involvement Techniques for Transportation Decision-making, 2015 Update. Available at: https://www. fhwa.dot.gov/planning/public_ involvement/publications/pi_ techniques/.

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ACRP Research Report 198: Wetland Mitigation, Volume 2, A Guidebook for Airports explores how to mitigate potential impacts to wetlands from airport construction, expansion, and safety improvements.

The report addresses a broad range of issues, including:

• Concerns over the creation of potential wildlife hazards;

• Existing requirements, which may or may not be conflicting;

• Impact to existing and future airport development;

• Airport considerations of cost and logistics in developing mitigation and related life-cycle obligations; and

• Environmental benefits.

Airport improvements often result in the unavoidable loss of wetlands, as many airports are located in or adjacent to wetlands. In addition, the size and scale of airports and supporting infrastructure is extensive, which has made it difficult to completely avoid impacting wetlands.

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