FAA MEM-ADO, SOUTHERN REGION AIRPORTS DIVISION ENVIRONMENTAL EVALUATION FORM FOR SHORT ENVIRONMENTAL ASSESSMENTS

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2 FAA MEM-ADO, SOUTHERN REGION AIRPORTS DIVISION ENVIRONMENTAL EVALUATION FORM FOR SHORT ENVIRONMENTAL ASSESSMENTS The Short Form Environmental Assessment (EA), is based upon the guidance in Federal Aviation Administration (FAA) Order B, "National Environmental Policy Act, Implementing Instructions for Airport Projects" or subsequent revisions, which incorporates the Council on Environmental Quality's (CEQ) regulations for implementing the National Environmental Policy Act (NEPA), as well as the US Department of Transportation environmental regulations (including FAA Order E or subsequent revisions), and many other federal statutes and regulations designed to protect the Nation's natural, historic, cultural, and archeological resources. This version of the short form EA should be used only for projects at federally obligated airports that fall within the boundaries of the Memphis Airports District Office (MEM-ADO). The Short Form EA is intended to be used when a project cannot be categorically excluded (CATEX) from formal environmental assessment, but when the environmental impacts of the proposed project are expected to be insignificant and a detailed EA would not be appropriate. Accordingly, this form is intended to meet the intent of a short EA while satisfying the regulatory requirements of an EA. Proper completion of the Short Form EA would allow the FAA to determine whether the proposed airport development project can be processed with a short EA, or whether a more detailed EA must be prepared. The MEM-ADO normally intends to use a properly completed Short Form EA to support a Finding of No Significant Impact (FONSI). Applicability The Short Form EA should be used if the sponsor s proposed project meets the following two (2) criteria: 1) The proposed project is a normally categorically excluded action that may include extraordinary circumstances Table 6-3; paragraph 702.a. or the airport action is one that normally requires an EA but involvement with, or impacts to, the extraordinary circumstances are not notable in number or degree of impact, and that any significant impacts can be mitigated below the level of significance, B, Table ) The proposed project must fall under one of the following categories of Federal Airports Program actions noted with an asterisk (*): (a) Approval of an airport location (new airport). *(b) Approval of a project on an airport layout plan (ALP). *(c) Approval of federal funding for airport development. *(d) Requests for conveyance of government land. *(e) Approval of release of airport land. *(f) Approval of the use of passenger facility charges (PFC). *(g) Approval of development or construction on a federally obligated airport. Revised 1/14

3 Do any of these listed Federal Airports program action(s), 2(b) - (g), apply to your project? Yes X No** If yes, list them here (there can be more than one). 2(b) Approval of a project on an airport layout plan (ALP). 2(c) Approval of federal funding for airport development. 2(g) Approval of development or construction on a federally obligated airport. If no, see (**) below. ** If the proposed project does not meet 1) or 2) above, i.e., one or more answers to the questions resulted in a (**), do not complete this Form. Rather, contact the Environmental Protection Specialist at the Memphis Airports District Office for additional guidance. Instructions Prior to preparing any NEPA documentation, including the Short Form EA, the MEM-ADO encourages you to contact the Environmental Protection Specialist or Program Manager to ensure that the Short Form EA is the proper Form for your proposed action. Completed forms without prior MEM-ADO concurrence may result in approval delays or rejected NEPA documentation. To complete the Form, the preparer should describe the proposed project and provide information on any potential impacts of the proposed project. Accordingly, it will be necessary for the preparer to have knowledge of the environmental features of the airport. In addition, while the preparer should have knowledge of the airport and associated features, correspondence with federal, state, and local regulatory agencies should be completed, when appropriate, to ensure that protected environmental resources are identified in the study area. In cases where regulatory agency coordination is appropriate, the preparer should submit a project description and drawing to the Environmental Protection Specialist for concurrence prior to submitting the project proposal to outside agencies. Correspondence from federal, state, and local agencies, project plans or maps, or secondary environmental studies, should be included as an appendix to this form. It is important to note that in addition to fulfilling the requirements of NEPA through this evaluation process, the FAA is responsible for ensuring that airport development projects comply with the many laws and orders administered by the agencies protecting environmental resources. The Form is not meant to be a stand-alone document. Rather, it is intended to be used in conjunction with applicable Orders, laws, and guidance documents, and in consultation with the appropriate resource agencies. Revised 1/14

4 Complete the following information: 1. Project Location: Airport Name: Memphis-Shelby County Airport Authority Airport Address: 2491 Winchester Road, Memphis, TN City: Memphis County: Shelby State: Tennessee 2. Airport Sponsor Information: Point of Contact: James Hay Address: 2491 Winchester Road, Suite113 Telephone: Fax: Evaluation Form Preparer Information: Point of Contact: James Hay Address: 2491 Winchester Road, Suite113 Telephone: Fax: Proposed Development Action (describe ALL associated projects that are involved): The proposed action features two deicing pads at the southern end of the airport, a glycol collection system, taxiway construction between the deicing pads, and converting Louis Carruthers Drive from a public road to an airport road for airport vehicles only. The road will be relocated by approximately 50 feet to the east to allow for the construction of the deicing pads. A gate will be constructed on the road to prevent public access. The overall size of the proposed development is approximately 65 acres. Please refer to Appendix B for a graphic depiction of the proposed action. 5. Describe the Purpose of and Need for the Project: The existing deicing pads are located on taxiways Alpha, Juliet, November and Yankee. Refer to Appendix B for a graphical depiction of the locations of these pads. Once the new consolidated deicing pads are constructed, the Alpha and Yankee pads will remain available on an as-needed basis; the Juliet and November pads will be incorporated into the consolidated pad. The new deicing pads will primarily be used to prepare aircraft departing to the north in winter conditions. The consolidated pads will be used as a single point of deicing treatment in order to reduce efforts associated with glycol collection. It will also greatly simplify future conveyance, storage, and treatment depending upon Tennessee Department of Environment and Conservation (TDEC) decisions as such. The southern location was strategically placed on the airfield to facilitate more ordered and efficient aircraft movements. This will allow aircraft to receive deicing treatment closer to the runways for north flow, thereby minimizing the taxiing time between treatment and takeoff. Additionally, the new crossfield taxiways will permit aircraft to taxi between the south ends of Runway 18R-36L and Runway 18C-36C. 6. Alternatives to the Project: Describe any other reasonable actions that may feasibly substitute for the proposed project, and include a description of the No Action alternative. If there are no feasible or reasonable alternatives to the proposed project, explain why: Revised 1/14

5 The following alternatives were evaluated based upon operational needs of the airport and airlines, construction considerations, robustness, compliance risk, and land availability. Alt #1: Midfield Pad Alternative 1 considers adding a midfield pad, south of the Terminal building. The proposed midfield pad is sited south of taxiways Tango and Papa so that it would not interfere with the future concourse expansion plans, but its current planned location will require closure, remediation, and demolition of the fuel farm and/or demolition of 2 airport operated businesses. Although this layout does not require closure of Louis Carruthers Drive, it does not allow aircraft to taxi between the south ends of Runway 18R-36L and Runway 18C-36C. Because of the above listed shortcomings, this alternative was not deemed practical and therefore was not chosen as the preferred layout. Alt #2: Southfield Pad (Rotated) Alternative 2 considers adding a southfield pad connecting the existing Juliet and November deicing pads. This alternative requires closure of Louis Carruthers Drive, but allows aircraft to taxi between the south ends of Runway 18R-36L and Runway 18C-36C on the southfield pad. Instead of deicing positions along TWs Julie and November, the deicing positions would be located between the new crossfield taxiways. However, this layout hinders the flexibility of aircraft movements making it difficult for them to maneuver into the designated parking positions. No Action Alt: Currently, there is not a designated point of deicing treatment for north departure operations and no crossfield taxiway system to allow aircraft to taxi between the south ends of Runway 18R-36L and Runway 18C-36C. Runway 18L-36R is of limited use to arriving aircraft when the Yankee deicing pad is in use due to the proximity of the taxiway and runway. Additionally, MSCAA and FedEx have been in discussions with TDEC and future water qualitybased effluent limits could be imposed to control the release of deicer impacted stormwater from MEM. If mandated, it will be difficult to meet the TDEC future regulations under the no action alternative. Explanation 7. Describe the affected environment of the project area (terrain features, level of urbanization, sensitive populations, etc). Attach a map or drawing of the area with the location(s) of the proposed action(s) identified. Attachment? Yes X No The proposed project is on Airport property and will therefore have no impacts on terrain features, level of urbanization, sensitive populations, etc. See Site Plan in Appendix B for the location of the planned project. 8. Environmental Consequences Special Impact Categories (refer to corresponding sections in B or E, or subsequent revisions, for more information and direction to complete each category, including discussions of Thresholds of Significance Table 7-1). (1) NOISE 1) Does the proposal require a noise analysis per Order E, Appendix A? Explain. (Note: Noise sensitive land uses are defined in Table 1 of FAR Part 150). Yes No X Revised 1/14

6 Aircraft activity, flight schedules, flight patterns, and fleet mix are not expected to be impacted by the project. Furthermore, there are no noise-sensitive areas in the project s immediate vicinity and the project is not anticipated to affect the airport s noise contours. 2) If yes, determine whether the proposed project is likely to have a significant impact on noise levels over noise sensitive areas within the DNL 65 dba noise contour. (2) COMPATIBLE LAND USE (a) Would the proposed project result in other (besides noise) impacts exceeding thresholds of significance that have land use ramifications, such as disruption of communities, relocation of residences or businesses, or impact natural resource areas? Explain. The proposed project area is located on Airport property within the Airport Operations Area (AOA). Therefore, there would be no disruption of communities or relocation of residences. There are two airport related operational businesses located along Louis Caruthers Drive, Gate Gourmet and Delta s Ground Service Equipment operation, who are currently under lease agreements with the Airport Authority. Both businesses have been notified in writing that their lease will not be renewed after their lease expires on October 1, The Airport Authority is working closely with these businesses to get them relocated to an area that will accommodate their needs. They have been given the opportunity to lease space in the old cargo building or the Cargo East facility. Based on preliminary negotiations it is reasonably foreseeable that Gate Gourmet will be relocated to the lease space in the old cargo area, and Delta will remain at their current location. If Delta chooses to stay, employee parking will be accommodated off of Swinnea Road, airfield access will be via the Cargo Central vehicle gate, and the route to their facilities will be via the perimeter roads and across a future non-movement area crossing of the new deicing pads. See attached Delta GSE & Gate Gourmet sketch in Appendix B. The only affected public business is a U.S. Post Office, which will be closed prior to this project. The Post Office is currently under a lease agreement with the Airport Authority, and the Authority will not renew the lease with the Post Office and has notified U.S. Postal Service (USPS) of such intentions. The Airport will coordinate carefully with the USPS to manage community expectations. Correspondence with TDEC Division of Natural Areas is attached in Appendix A. (b) Would the proposed project be located near or create a wildlife hazard as defined in FAA Advisory Circular 150/ , "Wildlife Hazards on and Near Airports"? Explain. The proposed project is not located near a wildlife hazard nor would it create a wildlife hazard. The MEM Wildlife Hazard Management Team along with the assistance of the contracted USDA biologist will continue to implement the FAA approved Wildlife Hazard Management Plan (WHMP) throughout the duration of the project. Correspondence with the US Fish & Wildlife is attached in Appendix A. (3) SOCIAL IMPACTS (a) Would the proposed project cause relocation of any homes or businesses? Yes X Explain. Revised 1/14 No

7 There will be no relocation of homes. The Post Office will be closed as mentioned above. Whether to relocate the Post Office will be determined by the USPS and the Airport can provide a new site location if needed. (b) If yes, describe the availability of adequate relocation facilities Relocation sites are available on Airport property if requested by the Postal Service. (c) Would the proposed project cause an alteration in surface traffic patterns, or cause a noticeable increase in surface traffic congestion? Explain. Local traffic will not be noticeably increased due to airport construction traffic. (4) INDUCED SOCIOECONOMIC IMPACTS Would the proposed project cause induced, or secondary, socioeconomic impacts to surrounding communities, such as change business and economic activity in a community; impact public service demands; induce shifts in population movement and growth, etc.? Yes X No Explain Impacts are not expected because the proposed action would impact localized conditions only. Because the proposed project has negligible environmental impacts as disclosed in this Short Form EA, the cumulative impact of the project, when added to the other past, present, and future actions, is collectively negligible. As necessary, mitigation procedures would be implemented to minimize potential adverse impacts that would occur during construction. The Post Office next to the airport is currently under a lease agreement with the Airport Authority through October 31, The Post Service has standard procedures to follow when an office location permanently closes, as described in the Code of Federal Regulations associated with Title 39 (39 CFR part 241). This process can take several months to complete, so the post office will be acting soon on exploring alternate locations in preparation of the lease expiration. Since their lease will be expired prior to construction of the deicing facility, this project will not negatively impact the Postal Service operations. As discussed above, the Airport will assist the Post Office as needed. (5) AIR QUALITY (a) Does the proposed project have the potential to increase airside or landside capacity, including an increase in capacity to handle surface vehicles? Explain The project will feature new pavement, but pavement is being constructed to better accommodate deicing operations and no additional demand is expected. (b) Identify whether the project area is in a non-attainment or maintenance area for any of the criteria air pollutants having National Ambient Air Quality Standards (NAAQS) established under the Clean Air Act Amendments (CAAA), and identify which pollutant(s) apply. If the proposed project is in an attainment area, no further air quality analysis is needed; skip to item (6). See EPA Green Book at for current attainment areas. The project is located in a nonattainment area for 8-hour ozone (marginal) and a maintenance area for carbon monoxide. An air quality analysis has been conducted and can be seen below. Revised 1/14

8 (c) Is an air quality analysis needed with regard to indirect source review requirements or levels of aircraft activity (See Order E and the 1997 FAA Handbook "Air Quality Procedures for Civilian Airports and Air Force Bases")? Explain. If yes, comply with state requirements. See narrative below. (d)(1) Would the proposed action be an exempted action, as defined in 40 C.F.R Part (c)(2) of the General Conformity Rule? If exempt, skip to item (6). List exemption claimed. Yes No X (d)(2) Would the increase in the emission level of the regulated air pollutants for which the project area is in non-attainment or maintenance exceed the de minimis standards? Yes No X (d)(3) If no, would the proposed project cause a violation of any NAAQS, delay the attainment of any NAAQS, or worsen any existing NAAQS violation? Explain. See narrative below. (d)(4) Would the proposed project conform to the State Implementation Plan (SIP) approved by the state air quality resource agency? Explain, and provide supporting documentation. No. See the following narrative. The proposed action includes construction in Shelby County, Tennessee which has been defined by the US Environmental Protection Agency (EPA) as a nonattainment area for 8-hour ozone (marginal) and a maintenance area for carbon monoxide. The action is not listed in Federal Register Volume 72, Number 145, as an exemption or presumed to conform, and is therefore subject to a General Conformity applicability analysis. Since the proposed action would not alter aircraft demand or enhance airfield capacity, applicability analysis was completed for construction activities only. The Airport Construction Emissions Inventory Tool (ACEIT), Version 1, was used to complete the applicability analysis. Due to the fact that final construction plans were not available at the time this document was prepared, general assumptions were used to estimate construction quantities and equipment usage. The emissions inventory was based on a two year construction schedule with construction activities beginning in the spring months of 2017 and concluding in the fall of The results of the emissions inventory are shown in the table below. As can be seen in the table, the projected emissions are below de minimis levels for 8-hour ozone, measured by ozone precursor pollutants nitrogen oxides (NOx) and volatile organic compounds (VOC), and carbon monoxide (CO) for both years of construction. Revised 1/14

9 EMISSIONS INVENTORY Total Emissions by Year Year CO Ozone Precursors de minimis NOx VOC Thresholds Units: Short Ton The above table demonstrates that the proposed action would not equal or exceed the applicable General Conformity de minimis thresholds as established by the Clean Air Act. Therefore, additional air quality assessment efforts are not warranted. A detailed emissions inventory report is on file with the FAA Memphis Airports District Office. Correspondence with the Shelby County Health Department Pollution Control is attached in Appendix A. (6) WATER QUALITY Describe the potential of the proposed project to impact water quality, including ground water, surface water bodies, any public water supply systems, etc. Provide documentation of consultation with agencies having jurisdiction over such water bodies as applicable. Current TDEC permit requires MSCAA and FedEx to conduct instream monitoring to model impacts to our receiving streams and provide corrective action alternatives to improve water quality. This project will allow us to centralize our deicing activities, making it more costeffective to meet our potential water quality standards in future permits. The proposed action would add approximately 65 acres of impervious surface to the airport. Impacts to water quality regarding groundwater and public water supply systems are not anticipated. Any water quality impact to surface water bodies (i.e. receiving streams) would be advantageous due to the fact that Hurricane Creek would no longer be receiving the bulk of the glycol runoff. Also, collection opportunities from the new pads would allow for additional containment/collection diverting runoff from Days Creek and ultimately Nonconnah Creek. The only onsite water body under the jurisdiction of TDEC is Hurricane Creek. Since this project would greatly reduce aircraft glycol runoff into Hurricane Creek, it would improve overall water quality in relation to deicing activities at MEM. In the post-construction conditions, the project will actually improve water quality by providing the Airport with the capability of capturing glycol-impacted runoff before it enters local water bodies. (7) DEPARTMENT OF TRANSPORTATION SECTION 303/4(f) Does the proposed project require the use of any publicly owned land from a public park, recreation area, or wildlife or waterfowl refuge of national, state, or local significance, or land of an historic site of national, state, or local significance? Provide justification for your Revised 1/14

10 response. Include concurrence of appropriate officials having jurisdiction over such land regarding the use determination. There are no publicly owned lands within or near the project area. Therefore, no direct or constructive impacts to Section 4(f) would result from the proposed project. (8) HISTORIC, ARCHITECTURAL, ARCHEOLOGICAL, AND CULTURAL RESOURCES (a) Describe any impact the proposed project might have on any properties in or eligible for inclusion in the National Register of Historic Places. Provide justification for your response, and include a record of your consultation with the State Historic Preservation Officer (SHPO), if applicable (attach correspondence with SHPO). Our review of the National Register of Historic Places database shows the nearest recorded historic property as Graceland; approximately 2.79 miles northwest of the project site. There will be no impacts to this historic site. See attached SHPO letter and NRHP Map in Appendices A and B, respectively. Our review of the Tennessee Historical Commission database shows zero records found within the project area. See attached Tennessee Historical Commission Map in Appendix B. (b) Describe whether there is reason to believe that significant scientific, prehistoric, historic, archeological, or paleontological resources would be lost or destroyed as a result of the proposed project. Include a record of consultation with persons or organizations with relevant expertise, including the SHPO, if applicable. Based on site investigation, knowledge and review of previous development, and consultation with the SHPO, there is no reason to believe that significant scientific, prehistoric, historic, archeological, or paleontological resources would be lost or destroyed as a result of the proposed project. (9) BIOTIC COMMUNITIES Describe the potential of the proposed project to directly or indirectly impact plant communities and/or the displacement of wildlife. This answer should also reference Section 6, Water Quality, if jurisdictional water bodies are present. The project site location contains both pervious and impervious areas that are periodically maintained by mowing. Furthermore, there are no wetlands or forested areas located on the Airport Property that would attract wildlife. The project would result in altering close to 65 acres of habitat that is considered to be common grassland. Flora and fauna species in this area are also considered common. Many species impacted by the project will be capable of utilizing habitat in areas adjacent to the project site. (10) FEDERAL and STATE-LISTED ENDANGERED AND THREATENED SPECIES Would the proposed project impact any federally- or state-listed or proposed endangered or threatened species of flora and fauna, or impact critical habitat? Explain, and discuss and attach records of consultation efforts with jurisdictional agencies, if applicable. Revised 1/14

11 Impacts are not expected because based on site inspection there are no known occurrences or habitat for federally or state listed species. In addition, our review of the TN Department of Environment & Conservation database, indicates there are no state-listed species in the project area. Correspondence with the US Fish & Wildlife is attached in Appendix A. (11) WETLANDS Does the proposed project involve the modification of delineated wetlands (Delineations must be performed by a person certified in wetlands delineation)? Provide documentation of consultation with agencies having jurisdiction over wetlands and include wetland inventory maps when appropriate. The National Wetland Inventory maps do not have any wetlands recorded on or near the project site. Site inspections revealed no evidence of hydrology consistent with wetlands or other water resources. Correspondence with the USACE and TDEC Water Resources is attached in Appendix A. (12) FLOODPLAINS (a) Would the proposed project be located in, or would it encroach upon, any 100-year floodplains, as designated by the Federal Emergency Management Agency (FEMA)? Yes No X (b) Would the proposed project be located in a 500-year floodplain, as designated by FEMA? Yes No X (c) If yes, is the proposed project considered a "critical action", as defined in the Water Resources Council Floodplain Management Guidelines? (see FR Vol. 43, No. 29, 2/10/78) Yes No (d) You must attach the corresponding FEMA Flood Insurance Rate Map (FIRM) or other documentation showing the project area. Map attached? Yes X No If no, why not? (e) If the proposed project would cause an encroachment of a base floodplain (the base floodplain is the 100-year floodplain for non-critical actions and the 500-year floodplain for critical actions), what measures would be taken to provide an opportunity for early public review, in accordance with Order E, Appendix A, Section 9.2.c? (13) COASTAL ZONE MANAGEMENT PROGRAM (a) Would the proposed project occur in, or affect, a coastal zone, as defined by a state's Coastal Zone Management Plan (CZMP)? Explain. Revised 1/14

12 Tennessee is not a coastal state and therefore is not regulated by the Coastal Zone Management Program. (b) If yes, is the project consistent with the State's CZMP? Explain. If applicable, attach the sponsor's consistency certification and the state's concurrence of that certification. Early coordination is recommended. (14) COASTAL BARRIERS Is the location of the proposed project within the Coastal Barrier Resources System, as delineated by the US Fish and Wildlife Service (FWS) or FEMA coastal barrier maps? Explain. Based on research of FEMA documents, the proposed project does not lie within the Coastal Barrier Resources System. (15) WILD AND SCENIC RIVERS Would the proposed project affect any portion of the free-flowing characteristics of a Wild and Scenic River or a Study River, or any adjacent areas that are part of such rivers, listed on the Wild and Scenic Rivers Inventory? Consult the (regional) National Parks Service (NPS), U.S. Forest Service (FS), or other appropriate federal authority for information. Early consultation is recommended. According to the NRI database accessed on the U.S. Department of the Interior, National Park Service website, no NRI rivers or river segments designated as part of the National Wild and Scenic River System occur within Shelby County. Correspondence with the TDEC Water Resources is attached in Appendix A. (16) FARMLAND (a) Would the proposed project involve the use of federal financial assistance or conversion of federal government land? Explain The proposed project area lies within Airport property and no farm land conversion would take place. See attached correspondence from Tennessee Department of Agriculture. (b) If yes would it convert farmland protected by the Farmland Protection Policy Act (FPPA) (prime or unique farmland) to non-agricultural uses? Yes No (c) If yes, determine the extent of project-related farmland impacts by completing (and submitting to the Natural Resources Conservation Service) the "Farmland Conversion Impact Rating Form" (NRCS Form AD 1006). Coordinate with the state or local agricultural authorities. Explain your response, and attach the Form AD 1006, if applicable. (17) ENERGY SUPPLY AND NATURAL RESOURCES What effect would the proposed project have on energy or other natural resource consumption? Would demand exceed supply? Explain. Letters from local public utilities and suppliers Revised 1/14

13 regarding their abilities to provide energy and resources needed for large projects may be necessary. The proposed action would not result in consumption of resources in short supply. Correspondence with the TDEC Division of Natural Areas is attached in Appendix A. (18) LIGHT EMISSIONS Would the proposed project have the potential for airport-related lighting impacts on nearby residents? Explain, and, if necessary, provide a map depicting the location of residences in the airport vicinity in relation to the proposed lighting system. The proposed project is on Airport property and will not include lighting that would negatively impact nearby properties. Furthermore, it would not change the visual setting of the area which is currently an airport setting. The project will include taxiway edge lighting and directional lighted taxiway signage, but will be consistent with the surrounding environment setting. (19) SOLID WASTE Would the proposed project generate solid waste? Yes No X If yes, are local disposal facilities capable of handling the additional volumes of waste resulting from the project? Explain. The proposed project is not expected to generate solid waste materials. If solid waste is generated during construction, the proper measures will be taken to dispose of the waste. Correspondence with the TDEC Division of Solid Waste Management and the TDEC UST is attached in Appendix A. (20) CONSTRUCTION IMPACTS Would construction of the proposed project: 1) increase ambient noise levels due to equipment operation; 2) degrade local air quality due to dust, equipment exhausts and burning debris; 3) deteriorate water quality when erosion and pollutant runoff occur; 4) or disrupt off-site and local traffic patterns? Explain. 1) The construction activities could result in minor short-term impacts to noise due to the use of heavy equipment operation, but would be kept to a minimum by employing appropriate best management practices (BMPs). As mentioned in Section 1 of this document, there are no noisesensitive areas in the project s immediate vicinity and the project is not anticipated to affect the airport s noise contours. 2) The construction activities could result in minor short-term impacts to local air quality but would be mitigated through appropriate BMPs. Section 5 of this document demonstrates that the proposed action would not equal or exceed the applicable General Conformity de minimis thresholds as established by the Clean Air Act. 3) The construction activities could result in minor short-term impacts to water quality, but would be mitigated through appropriate BMPs as defined in the MEM Storm Water Pollution Prevention Plan (SWPPP). As mentioned in Section 6 of this document, impacts to water quality regarding groundwater and public water supply systems are not anticipated. Any water Revised 1/14

14 quality impact to surface water bodies (i.e. receiving streams) would be advantageous due to the fact that Hurricane Creek would no longer be receiving the bulk of the glycol runoff. 4) The construction activities could result in minor disruption off-site and local traffic patterns, but it would be very minimal and of short duration. (21) OTHER CONSIDERATIONS (a) Is the proposed project likely to be highly controversial on environmental grounds? Explain. The project will be similar to other previously-completed on-airport construction projects. There are no known concerns from public or government agencies, and controversy is unlikely. In November 2014, MSCAA contacted the appropriate governing agencies and shared information concerning the proposed project, and all agencies indicated no objection. No impact letters are attached in Appendix A. (b) Is the proposed project likely to be inconsistent with any federal, state or local law or administrative determination relating to the environment? Explain. The proposed project area is located on Airport property within the Airport Operations Area (AOA). Therefore, the project is compatible with the surrounding land uses, and is consistent with future plans, goals, policy, zoning, and local controls. (c) Is the proposed project reasonably consistent with plans, goals, policies, or controls that have been adopted for the area in which the airport is located? Explain On-airport construction is consistent with the above-stated interests. (22) HAZARDOUS SITES/MATERIALS Would the proposed project require the use of land that may contain hazardous substances or may be contaminated? Explain your response and describe how such land was evaluated for hazardous substance contamination. Early consultation with appropriate expertise agencies (e.g., US Environmental Protection Agency (EPA), EPA-certified state and local governments) is recommended. There are no known hazardous materials or hazardous waste sites that would be impacted by the proposed project, nor would the proposed project generate hazardous materials. Correspondence with the TDEC Division of Solid Waste Management and the TDEC UST is attached in Appendix A. (23) PERMITS List all required permits for the proposed project. Indicate whether any difficulties are anticipated in obtaining the required permits. A NPDES Stormwater Construction Permit would be needed for the proposed action. No difficulties are expected in obtaining the permit. Revised 1/14

15 NOTE: Even though the airport sponsor has/shall obtain one or more permits from the appropriate federal, state, and/or local agencies for the proposed project, initiation of such project shall NOT be approved until FAA has issued its environmental determination. (24) ENVIRONMENTAL JUSTICE Would the proposed project impact minority and/or low-income populations? Consider human health, social, economic, and environmental issues in your evaluation. Explain. Construction will be limited to on-airport property and therefore would not displace any residences of minority and/or low income populations. The project will provide potential for new jobs during the construction, which could have a positive impact on the local community. (25) CUMULATIVE IMPACTS When considered together with other past, present, and reasonably foreseeable future development projects on or off the airport, federal or non-federal, would the proposed project produce a cumulative effect on any of the environmental impact categories above? You should consider projects that are connected, cumulative and similar (common timing and geography). Provide a list of such projects considered. For purposes of this Evaluation Form, generally use 3 years for past projects and 5 years for future foreseeable projects. Because the proposed project has negligible environmental impacts as disclosed in this Short Form EA, the cumulative impact of the project, when added to the other past, present, and future actions, is collectively negligible. There are no other known or anticipated large federal or nonfederal projects located within the area that would produce a cumulative effect on the environmental impacts to the project area. As necessary, mitigation procedures would be implemented to minimize potential adverse impacts that would occur during construction. 10. MITIGATION (a) Describe those mitigation measures to be taken to avoid creation of significant impacts to a particular resource as a result of the proposed project, and include a discussion of any impacts that cannot be mitigated, or that cannot be mitigated below the threshold of significance (See B & E, Appendix A). No mitigation required. (b) Provide a description of the resources that are in or adjacent to the project area that must be avoided during construction. Note: The mitigation measures should be incorporated into the project s design documents. There are no known resources or other protected areas within or adjacent to the proposed project area. Revised 1/14

16 11. PUBLIC INVOLVEMENT Describe what efforts would be made to involve the public with this proposed project. Discuss the appropriateness of holding public meetings and/or public hearings, making the draft document available for public comment, or the preparation of a public involvement plan, etc. A public notice was issued, a public meeting was conducted on December 15, 2015 at the Airport Project Center, and no comments were received. See the attached legal notice and memo from Kimley Horn in Appendix C for further details. Revised 1/14

17 12. PREPARER CERTIFICATION I certify that the information I have provided above is, to the best of my knowledge, correct. September 23, 2015 Signature Date James Hay, Director of Development Name, Title Memphis-Shelby County Airport Authority Affiliation 13. AIPORT SPONSOR CERTIFICATION I certify that the information I have provided above is, to the best of my knowledge, correct. I also recognize and agree that no construction activity, including but not limited to site preparation, demolition, or land disturbance, shall proceed for the above proposed project(s) until FAA issues a final environmental decision for the proposed project(s), and until compliance with all other applicable FAA approval actions (e.g., ALP approval, airspace approval, grant approval) has occurred. September 23, 2015 Signature Date James Hay, Director of fdevelopment Name, Title Memphis-Shelby County Airport Authority Affiliation Revised 1/14

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19 MEMPHIS-SHELBY COUNTY AIRPORT AUTHORITY MEMPHIS, TENNESSEE DEICING PAD APPENDICES Appendix A Stakeholder Letters State Historic Preservation Office (SHPO) - Tennessee Historical Commission U.S. Fish and Wildlife Service (FWS) Tennessee Department of Agriculture United States Army Corps of Engineers (USACE) Tennessee Department of Environment & Conservation (TDEC) Division of Water Resources Shelby County Health Department Pollution Control Division TDEC Division of Natural Areas TDEC Division of Solid Waste Management TDEC Division of Underground Storage Tanks (UST) Appendix B Maps Existing Deicing Pads Site Map Delta GSE & Gate Gourmet NRHP Map TN Historic Commission Map Federal Emergency Management Agency (FEMA) Flood Map Quadrangle Map Appendix C Public Involvement Public Meeting Legal Notice Kimley Horn Memo Discussion of SFEA Meeting

20 MEMPHIS-SHELBY COUNTY AIRPORT AUTHORITY MEMPHIS, TENNESSEE DEICING PAD APPENDIX A STAKEHOLDER LETTERS

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25 Nathan Luce From: John McClurkan Sent: Wednesday, December 17, :26 PM To: Nathan Luce Subject: Comments on MSCAA Mr. Luce: A review of the above referenced construction project has been performed. Since this project will be constructed on land within the airport footprint, and no agricultural lands or agribusinesses will be involved or affected, the department sees no impact to agriculture and has no comments to offer on the project. Please let me know if you have questions or need further assistance. Thank you for the opportunity to comment. John McClurkan Tennessee Dept of Agriculture ofc: cell: fax: All s and attachments sent and received from this address related to the official business of the Tennessee Department of Agriculture are subject to the Tennessee Public Records Act. Unless the content of an or attachment is subject to a specific exception in the public records act, s and attachments sent to and from this agency should be presumed to be open to public inspection and maintained pursuant to applicable retention requirements. 1

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32 Nathan Luce From: Stephanie Whitaker Sent: Tuesday, December 16, :17 PM To: Nathan Luce Subject: MSCAA Project Hi Nathan Sorry you had to call me to get a response from us. The Natural Heritage Program appreciates the opportunity to provide comments on the Memphis Shelby County Airport Authority (MSCAA) (project ) proposed construction of a deicing pad project at Memphis International Airport. Our Division has reviewed the proposed action and based on the information provided and information currently within our rare species database, we do not anticipate any impacts to rare species and have no comments on the proposed actions. Happy Holidays Stephanie Whitaker Data Manager TDEC Division of Natural Areas Natural Heritage Program William R. Snodgrass Tennessee Tower 312 Rosa L. Parks Avenue, 2 Floor MAP Nashville, TN Phone: (615) stephanie.whitaker@tn.gov areas/natural heritage inventory program.shtml Please keep in mind that not all of Tennessee has been surveyed and that a lack of records for any particular area should not be construed to mean that rare species necessarily are absent. Rare species data lists by county, quadrangle, watershed, and MS4 boundaries can be obtained at We accept and encourage electronic document submittals. Please include a contact with environmental review requests. 1

33 Nathan Luce From: Sent: To: Cc: Subject: Herb Nicholson Friday, December 19, :10 PM Nathan Luce Ashley A. Holt; Lisa Hughey; Glen Pugh MSCAA Deicing Pad Construction Project Nathan DSWM staff from the Memphis Environmental Field Office has completed a review of a letter (dated November 14, 2014) regarding the proposed construction of a deicing pad at the Memphis International Airport. Based on information contained in the letter, we have no comments regarding the project at this time. Herb Nicholson, P.G., CHMM Manager, Solid Waste Program Division of Solid Waste Management, TDEC Memphis Environmental Field Office 8383 Wolf Lake Drive Bartlett, TN (901) Herb.Nicholson@tn.gov 1

34 TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION MEMPHIS ENVIRONMENTAL FIELD OFFICE 8383 WOLF LAKE DRIVE BARTLETT, TN PHONE (901) STATEWIDE FAX (901) December 29,2014 Mr. lames Hay Office: Memphis International Airport 2491 Winchester Rd., Suite 113 Memphis, TN RE: Environmental Inquiry- MSCAA Project Glycol Management Program - CiviVStructural Design Phase Memphis International Airport Dear Mr. Hay: The Division of Underground Storage Tanks (Division) has reviewed the November 14, 2014 environmental inquiry for the referenced location. A review of our records indicates that there are no known issues in the designated area relative to the Division. If you have any questions about this letter, please do not hesitate to contact me at (901) Sincerely, ~~IJL!lfA Division of Underground Storage Tanks c: Phil Chambers - Knoxville Environmental Field Office Ernestine Ellis-Nashville Central Office Memphis Environmental Field Office file Nathan Luce, P.E. - Memphis International Airport, 2491 Winchester Rd., Suite 113, Memphis, TN 38116

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43 MEMPHIS-SHELBY COUNTY AIRPORT AUTHORITY MEMPHIS, TENNESSEE DEICING PAD APPENDIX C PUBLIC INVOLVEMENT

44 PUBLIC MEETING Legal Notice MSCAA Project Number Glycol Management Program The Federal Aviation Administration (FAA) is reviewing a Draft Environmental Assessment (EA) for proposed development at the Memphis International Airport in Memphis, TN. The proposed development features designing consolidated deicing pads at specific locations on the airfield. The purpose of the EA is to address how the proposed action would potentially impact economic, social, and environmental resources. The Draft EA can be reviewed at the following locations: FAA, Memphis Airports District Office, 2600 Thousand Oaks Boulevard, Suite 2250, Memphis, TN 38118; Hours: Monday through Friday, 8:00 AM to 3:30 PM (CT). OR MSCAA, Development Office, 2491 Winchester Road, Memphis, TN 38116; Hours: Monday through Friday, 8:00 AM to 3:30 PM (CT). Members of the public may issue comments on the EA within 30 days of this notice, or request a public hearing within 15 days of this notice, by contacting the following FAA or Airport representatives. Aaron Braswell Environmental Protection Specialist FAA - Memphis Airports District Office (901) OR Jason Hull Project Engineer MSCAA- Development Division ( In an effort to formally present this EA and discuss the proposed Glycol Management project (MSCAA Project No ), MSCAA will conduct a public meeting. This meeting will be conducted by the Development Division of the Memphis-Shelby County Airport Authority (MSCAA). This meeting will be held at the Airport Project Center, 4225 Airways Blvd, Memphis, TN 38116, on December 10, 2015 from 5:30pm until 7:30pm. This meeting is open to the public and all interested parties are encouraged to attend. MEMPHIS-SHELBY COUNTY AIRPORT AUTHORITY By Scott A. Brockman, President & CEO

45 MEMORANDUM To: From: Jason Hull, Aaron Braswell David Sparkes Date: 12/18/2015 Kimley-Horn and Associates, Inc. Subject: Discussion of Short Form EA (SFEA) Meeting On December 15, 2015, a public meeting was held at the Airport Project Center for the Glycol Management Program at the Memphis International Airport. Below is a summary of the meeting: Attendees included the following: Terry Blue (MSCAA) James Hay (MSCAA) Nathan Luce (MSCAA) Jason Hull (MSCAA) David Sparkes (Kimley-Horn) Koty Brown (Kimley-Horn) David Webb (Parsons) The meeting was held from 5pm to 7pm, as advertised. No members of the public attended the meeting. No public responses were sent to the Airport or Kimley-Horn through or phone. The SFEA document was available for public review for 30 days before the meeting. The SFEA document was posted on the airports website, at the Terminal Building and the Airport Project Center. The advertisement for the meeting was published in the following: 1. Tri-State Defender 2. LaPrensa Latina 3. Daily News END OF MEMO kimley-horn.com 6625 Lenox Park Drive, Suite 117, Memphis, TN