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