Environmental Document Preparation

1. Environmental Document Preparation WETLANDS BEST PRACTICES 33rd Annual Airports Conference Marie Jenet, Environmental Specialist, NYADO March 3, 2010

2. Areas Of Deficiency • Impact Assessment • Alternatives • Clean Water Act Section 404 Permit • Mitigation • Hazardous Wildlife Attractant

3. Impact Assessment • Jurisdictional Wetlands • Non-Jurisdictional Wetlands • State Regulated Wetlands • All Wetlands Are Natural Resources That Must Be Assessed Regardless Of Permit Requirements

4. 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. 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. 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. 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. 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. Mitigation • An Option ONLY When Wetland Losses Are Unavoidable • Sequence • Replacement • Enhancement • Wetland Banking • All Mitigation Options Are Expensive

10. 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. Mitigation • Banking Agreement • Verify Bank Meets Defined Success Criteria • Identify Number of Credits to be Withdrawn • Verify Purchase of Credits Will Satisfy Mitigation Requirements • Verify Mitigation Will Not Create Wildlife Hazards to Aviation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. 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. 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