presented to: by: date: federal aviation administration environmental document preparation wetlands...

Presented to:

By:

Date:

Federal AviationAdministrationEnvironmental

Document Preparation

WETLANDS

BEST PRACTICES

33rd Annual Airports Conference

Marie Jenet, Environmental Specialist, NYADO

March 3, 2010

2 2Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

Areas Of Deficiency

• Impact Assessment• Alternatives• Clean Water Act Section 404 Permit• Mitigation• Hazardous Wildlife Attractant

3 3Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

Impact Assessment

• Jurisdictional Wetlands• Non-Jurisdictional Wetlands• State Regulated Wetlands

• All Wetlands Are Natural Resources That Must Be Assessed Regardless Of Permit Requirements

4 4Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

Impact Assessment• Airport Actions Affect Wetlands If

– Require Structure in Wetlands– Require Dredging, Filling or Draining of Wetlands– Require Disturbing the Water Table of Wetlands– INDIRECTLY AFFECT Wetlands

• Remember To Assess All Wetland Impacts, Especially Temporary And Construction Related Impacts

5 5Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

Alternatives

• A Practicable Alternative Is One That Is Possible After Considering– Safety Aspects– Project Objectives– Accepted Standards (Design, Engineering,

Environmental, Economic)

• An Alternative Must Be Pursued If – It Achieves Project Purpose and Need – Avoids or Minimizes Wetlands Impacts

6 6Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

Alternatives

• Additional Cost Alone Does Not Make An Alternative Impractical

• The Cost May Be Recognized As Necessary And Justified To Meet National Wetland Policy Objectives

• Long Term Costs Associated With Wetlands Mitigation Are Considered

7 7Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

CWA Section 404 And State Permits

• Permit Issuance Is Not Needed To Complete The Environmental Document

• Document Must Contain Permit Status Including Pre-Application Meeting Information

• FAA Must Have Reasonable Assurance The Permit Requirements Can Be Met

8 8Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

CWA Section 404 And State Permits

• Lack Of Coordination Leads To

– Delay in Environmental Determinations– Expiration of Environmental Determinations– Delay or Possible Loss of Funding– Delay in Project Implementation

• Overall Losses in Time, Energy, and Money

9 9Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

Mitigation

• An Option ONLY When Wetland Losses Are Unavoidable

• Sequence– Replacement– Enhancement– Wetland Banking

• All Mitigation Options Are Expensive

10 10Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

Mitigation

• Need To Identify Availability Of Possible Mitigation Sites In The Document

• Need Assurance From The Corps That Mitigation Option Is Viable

• If Banking Is Suitable, Include A Copy Of The Banking Agreement

11 11Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

Mitigation • Banking Agreement

– Verify Bank Meets Defined Success Criteria

– Identify Number of Credits to be Withdrawn

– Verify Purchase of Credits Will Satisfy Mitigation Requirements

– Verify Mitigation Will Not Create Wildlife Hazards to Aviation

12 12Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

Hazardous Wildlife Attractants• FAA Recommends Against Land Use

Practices Within Defined Siting Criteria That Attract Or Sustain Hazardous Wildlife

(See AC150/5200-33)

• This Includes Wetland Mitigation

• Exceptions To Locating Mitigation Within The Siting Criteria Are Rare.

13 13Federal AviationAdministration

Environmental Document Preparation – Wetlands Best Practices33rd Annual Airports Conference - March 3, 2010

Wetlands Best Practices• Early Consultation With The Involved

Agencies (FWS,NMFS, EPA, State) Helps Identify Options For Dealing With Wetland Issues

• Better Consideration Of The Common Areas Of Deficiency Will Lead To The Proper Preparation Of The Wetlands Portion Of The Environmental Document