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This document provides essential best practices for preparing environmental documents related to wetlands at airports. Presented by Marie Jenet, Environmental Specialist at NYADO during the 33rd Annual Airports Conference, it emphasizes comprehensive impact assessments, the importance of alternatives, and Clean Water Act compliance (Section 404 permits). It highlights potential deficiencies in wetland evaluation, mitigation options, and the need for early agency consultation. Understanding these aspects will facilitate proper wetland management and compliance while optimizing environmental and economic outcomes.
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Environmental Document Preparation WETLANDS BEST PRACTICES 33rd Annual Airports Conference Marie Jenet, Environmental Specialist, NYADO March 3, 2010
Areas Of Deficiency • Impact Assessment • Alternatives • Clean Water Act Section 404 Permit • Mitigation • Hazardous Wildlife Attractant
Impact Assessment • Jurisdictional Wetlands • Non-Jurisdictional Wetlands • State Regulated Wetlands • All Wetlands Are Natural Resources That Must Be Assessed Regardless Of Permit Requirements
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
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
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
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
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
Mitigation • An Option ONLY When Wetland Losses Are Unavoidable • Sequence • Replacement • Enhancement • Wetland Banking • All Mitigation Options Are Expensive
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
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
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.
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
