Guidelines for Gas & Oil Extraction Environment on Airport Property

1. Environmental Requirements For Extraction of Gas & Oil on Airport Property 35th Annual Airports Conference Edward Gabsewics, CEP April 3, 2012

2. Objective Provide consistent guidance to sponsors on environmental documentation needed to comply with requirements of all environmental laws

3. Overview See Chapter 3. FAA Review Process • Proposed ALP Changes trigger need for environmental review • As with other airport development, sponsor needs to consult with/assist FAA in complying with all environmental laws • Consult your Environmental Protection Specialist (EPS) early

4. Level of Environmental Review / NEPA Documentation Environmental Assessment likely • Scope and Nature of Proposed On-Airport Operations will dictate extent of environmental review and timeframe for FAA determination • Proposed ALP changes should identify overall infrastructure and type and location of gas & oil operations including individual well heads if known • Include as much detail as possible on well locations to avoid need for supplemental environmental reviews

5. Outline Entire Process • Exploration • Well Design/Site Prep • Drilling • Well Construction • H20 & Fracturing Fluid Prep & Storage • Hydraulic Fracturing • Collection, Handling, and Disposal of Flow-Back & Wastewater • Collection of Gas, Processing & Transmission • Well Closure • Site Reclamation

6. Environmental Risks • Each stage of process has associated environmental risks • Risks will vary depending on: - Scope & Nature of Operations - Geographic Location / Geologic Characteristics of Site • Must consider SOPs for each stage • Spill Response and Blowout Plans also need to be analyzed

7. What If… A drilling site or other related facility was not addressed in initial NEPA analysis? • A separate environmental analysis must be undertaken and documentation developed for each new drilling site or other facility Sponsor Action • Airport sponsor must notify FAA asap with proposed location of new well sites or other facilities not previously evaluated • Airport sponsor will need to hold up operations on new development until FAA completes environmental determination

8. Well Closure and Site Reclamation • Must be done in accord with state/local regulatory requirements • Upon closure and site abandonment, Sponsor submits changes to ALP (with reclamation requirements referenced) • NEPA document should have addressed reclamation…BUT… • If conditions at closure/reclamation have changed, FAA may need a new / Supplemental NEPA document

9. State of Environmental Concerns • USEPA studies on-going Nationally • USEPA critical of Pennsylvania regs on Marcellus Shale • Debates raging on Fracking impacts to Drinking Water Resources • State of New York still deliberating • Earthquake concerns • Bradford County, Pennsylvania highest number of wells…multi-faceted concerns

10. Conclusion • Early coordination with FAA on environmental requirements • Refer to FAA Eastern Region Airports Division Sponsor Guide (Updated 11/16/2010) while AC gets finalized • Remember…ALP changes trigger need to address Environmental / NEPA • Provide as much detail as possible to avoid delays

11. Questions Harrisburg ADO EPSs Ed Gabsewics & Susan McDonald Ed @ 717-730-2832 / Sue @ 717-730-2841