NEPA Session 2 When to Start NEPA

Transcription

1 ATLANTA, GEORGIA 1

2 ATLANTA, GEORGIA NEPA Session 2 When to Start NEPA Emily Underhill, PE Division Director Development SW Florida International emunderhill@flylcpa.com Bill Willkie Principal Project Manager, CH2M HILL Bill.Willkie@ch2m.com

3 Topics Overview NEPA starts with a plan The planning & environmental process Transitions Durations Uncertainty What to do? Case Study: SW Florida International Airport 3

4 Overview NEPA Starts with a Plan NEPA applies only to federal actions: For most airport development, the federal action is approval of changes to an Airport Layout Plan (ALP), approval to spend Passenger Facility Charge (PFC) revenues, or issuance of Airport Improvement Program (AIP) grants. Airport sponsors define the project: Definition of physical development Identification of benefits Identification of operational characteristics Foundation for proposed action, purpose and need 4

5 Overview NEPA Starts with a Plan But what if it s not airport development? For non-aviation development the federal action is often the release of airport property acquired with Federal funds. FAA is required to consider the direct and indirect consequences of land releases. FAA requirements include: Sponsor retains sufficient control to protect aviation uses Environmental assessment of intended and reasonably foreseeable uses (zoning and land use regulations may establish what is reasonably foreseeable) NEPA document type will depend on foreseeable uses Difficulties arise when land would be made available for speculative development 5

6 6 The Planning & Environmental Process Transitions Typically, NEPA starts immediately after completion of planning process CatEx Airport Planning Process EA Outreach & Draft EA l Final EA FONSI EIS Scoping l Draft EIS l Final EIS ROD Note: Sponsor Lead FAA Lead

7 Immediate, Sequential Scenario typical approach Sponsor provides planning information and FAA decides if it is sufficient for completing NEPA Occurs when project need is solid and data supporting the need are rational and well-developed at the end of the planning process Allows a smooth, almost seamless transition from planning to the NEPA process Project funding and/or unconditional ALP approval typically linked to the NEPA process, helps develop an accurate planning grant (planning grants can t be amended) 7

8 8 The Planning & Environmental Process Transitions Sometimes demand for improvement lags behind planning Pre-NEPA Project Definition Master Planning Project Definition EIS NOI/Scoping l Draft EIS l Final EIS ROD Project Definition in NEPA Process Master Planning EIS Project Definition NOI/Scoping l Draft EIS l Final EIS ROD Note: Sponsor Lead FAA Lead

9 Delayed Project Implementation Scenario Some Time Approach Sponsor seeks FAA approval some time after planning completed Typically occurs when the sponsor identifies a need, but justification depends on traffic growth NEPA requires FAA to look at projects that are ripe for decision, consider: 3-year NEPA document shelf life 5-year planning horizon for short-term purposes Focus on facilities justified in the short-term 9

10 Delayed Project Implementation Scenario Some Time Approach May require updated data needed to develop an accurate planning grant (critical because planning grants can t be amended) Data considerations in this scenario include: Age of forecasts - does the sponsor s forecast meet the 10% / 15% TAF rule? Does the documentation still reflect the characteristics of the No Action alternative? Funding is normally linked to NEPA process, through project planning grants 10

11 11 The Planning & Environmental Process Transitions In rare occasions, demand is so immediate that NEPA starts during the planning process Airport Planning Process EA EIS Outreach & Draft EA l Final EA FONSI Scoping l Draft EIS l Final EIS ROD Note: Sponsor Lead FAA Lead

12 12 Concurrent Scenario the Rare Approach Sponsor and FAA agree to start the NEPA process before the sponsor completes its planning process Occurs when the project is urgently needed and justified when planning begins Planning issues not well developed = delays in NEPA or re-doing costly, complex analyses because planning principles change during NEPA process Can occur, but requires intensive amount of labor as planning and NEPA are coordinated, almost simultaneously More easily accomplished in an EA than in an EIS

13 13 The Planning & Environmental Process Typical Durations Master Plan EIS Master Plan: 2-3 years EIS: 3-6 years 1 year = 6-10 years Master Plan EA Master Plan: 2-3 years EA: 1-3 years = 3-6 years Focused Planning Study CatEx Planning CatEx < 1 year Note: Sponsor Lead FAA Lead

14 The Planning & Environmental Process Uncertainty 14

15 The Planning & Environmental Process Uncertainty 15

16 The Planning & Environmental Process Uncertainty 16

17 The Planning & Environmental Process Uncertainty 17

18 The Planning & Environmental Process What to Do? The following options apply primarily to capacity projects: Update forecast at the start of the NEPA process Conduct an optimum time to invest analysis Maintain dialogue with airlines or other relevant stakeholders Start the NEPA process earlier (the concurrent scenario) Start the NEPA process later (risks higher levels of delay in near term but reduces uncertainty about need) 18

19 19 Case Study: 30 Years of Planning and NEPA at RSW EIS approved for original RSW airport site Airport opened ALP - Draft EA Short Term FONSI Long Term EA/FONSI proposed actions ,000 acre mitigation park Master Plan/ALP ALP

20 Where are We? 20

21 I977 Site Selection-EIS 21

22 RSW ALP and Draft EA 1990 planning for midfield terminal starts Submitted EA/Master Plan for all new facilities Document was too immense for agency Took back document and split into a short-term EA (runway expansion) and a long-term EA (balance) 1992: Master Plan/Short-term EA/FONSI issued for 6/24 extension.

23 23 RSW Long Term EA FDOT State Land Acquisition Grant Voluntary Purchase of 7,400 Acres Unconditional ALP Approval FAA FONSI Issuance Decrease Project Scope/Impacts Increase Mitigation Establish Mitigation Park EPA, USFWS, USACOE Written Endorsements

24 24 RSW 1994 ALP Revisions Reduce Parallel RW Length from 12,000 to 9,100 Reduce Parallel RW Separation from 5,875 to 5,385 Decrease Estimated Wetland Impacts from 1,010 acres to 547 acres Reduce Land Required for airfield Development from 6,300 acres to 4,130 acres Reduce Project Cost Estimate by $88,500,000 (in 1994 Dollars) Established a 7,000 acre offsite mitigation park EA/FONSI APPROVED MARCH 10, 1994 ALP APPROVED!

25 25 Mitigation Park: A Visionary New Approach 1994 EA/FONSI approved mitigation for the new midfield terminal &future parallel runway. Located 5 miles from airport AOA to reduce wildlife hazards. Largest single mitigation area for one project site within SW Florida. LCPA responsible for maintenance of land in perpetuity. Regionally significant conservation project - provides connectivity between other conservation lands.

26 Mitigation Park: Flow-way Restoration 26

27 Mitigation Park: Farm Field Restoration 27

28 28 Mitigation Park: Created Marsh

29 29 Mitigation Park Awards 2004 Airport Council International (ACI) Environmental Excellence award for Mitigation Park 2008 Florida Airports Council Environmental Excellence Award for Mitigation Park 2009 Florida Native Plant Society Mitigation Award of Honor

30 Sticking to the Vision: It Works!!! 2004 ALP/Master Plan Update Updated the terminal building configuration Changed taxiway/ramp configuration No significant changes or additional impacts in relation to 1994 ALP 30

31 Sticking to the Vision: It Works!!! 2011 ALP/ Master Plan Update Updated the configuration of: ATCT location ARFF location Changes in taxiway/apron layout Parallel runway shift No significant changes and actually reduced impacts in relation to 2004 ALP 31

32 Questions?? 32