CRATER LAKE KLAMATH REGIONAL AIRPORT

DRAFT ENVIRONMENTAL ASSESSMENT FOR THE CONSTRUCTION OF TAXIWAY J, CONNECTING TAXIWAYS, AND ASSOCIATED DRAINAGE IMPROVEMENTS CRATER LAKE KLAMATH REGIONAL AIRPORT Prepared for City of Klamath Falls, Oregon U.S. Department of Transportation Federal Aviation Administration As lead Federal Agency pursuant to the National Environmental Policy Act of 1969 Prepared by Mead & Hunt, Inc. 133 Aviation Boulevard, Suite 100 Santa Rosa, CA 95403 707 526 5010 meadhunt.com MARCH 2015 THIS ENVIRONMENTAL ASSESSMENT FOR CRATER LAKE KLAMATH REGIONAL AIRPORT BECOMES A FEDERAL DOCUMENT WHEN EVALUATED, SIGNED, AND DATED BY THE RESPONSIBLE FEDERAL AVIATION ADMINISTRATION (FAA) OFFICIAL. RESPONSIBLE FAA OFFICIAL DATE

Table of Contents Page Chapter 1 Introduction... 1 1.1 Overview... 1 1.2 Background... 1 Chapter 2 Project Description, Purpose, and Need... 5 2.1 Introduction... 5 2.2 Project Description... 5 2.3 Purpose and Need... 5 Chapter 3 Alternatives... 7 3.1 Defining the Alternatives... 7 3.2 Proposed Alternatives... 7 3.3 Alternatives Dismissed from Further Evaluation... 8 3.4 Permits, Licenses, Approval, and Reviews... 9 Chapter 4 Affected Environment... 12 4.1 Purpose of Chapter... 12 4.2 Detailed Project Description... 12 4.3 Affected Environment... 16 Chapter 5 Environmental Consequences and Mitigation... 21 5.1 Analytical Approach... 21 5.2 Environmental Resources that are Not Present or Unlikely to be Affected by the Proposed Project... 21 5.3 Environmental Resources Subject to Detailed Analysis... 22 Chapter 6 Principal Preparers... 35 Chapter 7 References... 37 Appendices A B C D E Agency Communications Construction Emission Calculations and Presume to Conform Limits Biological Assessment Cultural Resources Materials Public Outreach Draft Environmental Assessment i

CHAPTER 1 INTRODUCTION 1.1 Overview The City of Klamath Falls, Oregon, is the owner and operator of Crater Lake - Klamath Regional Airport (Airport). The City desires to construct Taxiway J and its associated exit and connector taxiways on the east side of the Airport. This project is being undertaken to enhance the safety of taxiing to or from the east side of the Airport. The City will apply for Airport Improvement Program grant funds administered by the Federal Aviation Administration (FAA). Development of a taxiway is listed as normally qualifying for a categorical exclusion in FAA Order 1050.1E, Environmental Impacts: Policies and Procedures. However, the presence of a federally listed endangered species, the Applegate s milk-vetch (Astragalus applegatei), within project s limits of construction makes the project ineligible for a categorical exclusion. Therefore, this Environmental Assessment (EA) has been prepared to comply with the requirements of the National Environmental Policy Act (NEPA). More specifically, this EA has been prepared pursuant to the requirements of Section 102(2)(c) of the National Environmental Policy Act of 1969 (NEPA), and Section 509(b)(5) of the Airport and Airway Improvement Act of 1982, as amended. The FAA is the lead federal agency to ensure compliance with NEPA for airport development actions. The EA has been prepared in accordance with FAA Order 1050.1E, Environmental Impacts: Policies and Procedures; and FAA Order 5050.4B, National Environmental Policy Act (NEPA) Implementing Instructions for Airport Actions. This EA is intended to identify and consider potential environmental impacts related to the proposed construction of Taxiway J and associated connecting taxiways. 1.2 Background 1.2.1 Description of Existing Airport The Airport is a public use, Federal Aviation Regulations (FAR) Part 139 airport (i.e., supports airline service) located within the city limits of the City of Klamath Falls, Oregon. The Airport encompasses 1,166 acres. It is sited on gently sloping terrain at an elevation of 4,095 feet above mean sea level (AMSL). Adjacent uses are predominantly agricultural in character with some rural residential uses. Further north, farms transition into suburban residences with commercial uses along the main roads. The Airport is located about five miles southeast of the city center of Klamath Falls (see Figure 1-1). The nearest other major community is Medford, Oregon, located about 60 miles to the west. The nearest highway, State Route 140, is located immediately north of the Airport. U.S. Highway 97 is located about three miles to the west. The Airport is bounded on the north by State Route 140, the west side by Spring Lake Road, the east side by the Burlington Northern Santa Fe Railroad, and on the south side by the Draft Environmental Assessment 1

CHAPTER 1 INTRODUCTION Lost River Diversion Channel (see Figure 1-2). Principal vehicle access to the Airport is from Joe Wright Road via either State Route 140 or U.S. Highway 97. The Airport is the principal airport serving Klamath County and south-central Oregon. It serves the City of Klamath Falls and the other smaller communities in the region. The Airport functions as a transportation facility for scheduled airline service, and business and recreational aircraft. The Airport is also home to the U.S. Forest Service s Kingsley Air Tanker Base, Klamath Falls Interagency Fire Center, and the Oregon Air National Guard. Figure 1-1 Location Map Environmental Assessment 2

CHAPTER 1 INTRODUCTION Figure 1-2 Vicinity Map The airfield consists of two runways in an X configuration (see Figure 1-2). The main runway, Runway 14-32, is 10,301 feet long and 150 feet wide. It is paved with a mixture of asphalt and Portland cement concrete. The crosswind runway, Runway 7-25, is 5,258 feet long by 100 feet wide. It is paved with asphalt. The Airport is currently designed to accommodate large airline and military aircraft. The designated critical aircraft for Runway 14-32 is the DC-10, a three-engine, wide-body jet airline aircraft. The critical aircraft for Runway 7-25 is the Q-200, a twin-engine turboprop airline aircraft. The airfield has a precision instrument approach (with an ILS) to Runway 32 and nonprecision instrument approach procedures utilizing GPS and the Klamath Falls VORTAC for Runway 14. The ILS provide the highest approach minimums with a ceiling of 800 feet and forward visibility of ¾ mile. 1.2.2 Previous Studies Taxiway J and its associated exit and connector taxiways was identified in the most recently prepared Airport Master Plan (2005). The taxiway project has not been the subject of prior environmental review. Environmental Assessment 3

CHAPTER 1 INTRODUCTION THIS PAGE INTENTIONALLY LEFT BLANK Environmental Assessment 4

CHAPTER 2 PROJECT DESCRIPTION, PURPOSE, AND NEED 2.1 Introduction The City of Klamath Falls, Oregon is the owner and operator of (Airport). The acts as sponsor for all FAA grants. The City desires to construct Taxiway J and associated exit taxiways. Taxiway J would be a full-length parallel taxiway serving the east side of the Airport s main runway (Runway 14-32). This project is being undertaken to improve the safety and efficiency of aircraft operations. 2.2 Project Description The Airport proposes to construct a parallel taxiway (Taxiway J) 400 feet east of Runway 14-32 (measured centerline to centerline). The taxiway would extend the full length of the runway (10,301 feet). Entrance taxiways would be connected to each end of the runway and three new exit taxiways would be constructed along its length. Additionally, a taxiway would be constructed to provide a direct connection between Taxiway J and an existing aircraft parking apron. The taxiway would be lighted and have FAA-compliant signage. The proposed layout for Taxiway J and its exit taxiway is shown on the currently approved Airport Layout Plan (ALP) included as Figure 1-3 in the introductory chapter. 2.3 Purpose and Need 2.3.1 Purpose The purpose of this project is to improve the safety of taxiing operations of aircraft using the east side of the Airport by reducing or eliminating the need to cross intermediate runways following landings or prior to departure. 2.3.2 Need The east side of the Airport is currently not served by a parallel taxiway. Aircraft taxiing to or from the east side for departure must often cross one or more intermediate runways. Each runway crossing presents the opportunity for a runway incursion. The project is needed to reduce the potential for runway incursions by reducing the number of runway crossings by taxiing aircraft. A full-length, parallel taxiway is recommended in FAA Advisory Circular 150/5300-13A, Airport Design and Engineering Brief No. 75: Incorporation of Runway Incursion Prevention into Taxiway and Apron Design. The specific needs of the project include: Elimination of the necessity of aircraft taxiing from the east side for a departure on Runway 32 to cross both Runways 14-32 and 7-25. Runway 32 is the runway most commonly used for departures. Draft Environmental Assessment 5

CHAPTER 2 NEED PROJECT DESCRIPTION, PURPOSE, AND Elimination of the necessity of aircraft taxiing from the east side for a departure on Runway 25 to cross Runway 14-32 twice. Runway 25 is the runway most commonly used when strong crosswinds occur. Elimination of the necessity of aircraft landing on Runway 7 to cross Runway 14-32 twice in order to reach the east side. Elimination of the necessity of aircraft landing on Runway 25 to cross runway 14-32 once in order to reach the east side. Elimination of the necessity of aircraft landing on Runway 14 to cross Runway 14-32 once in order to reach the east side. Additionally, aircraft landing on Runway 14 that do not exit before Taxiway F will also need to cross Runway 7-25 on their route to the east side. Aircraft currently based on the east side of the Airport include those associated with the U.S. Forest Service fire attack base and tenants of the three banks of hangars. Transient aircraft also use the two parking aprons on the east side. Environmental Assessment 6

CHAPTER 3 ALTERNATIVES 3.1 Defining the Alternatives As the Federal Lead Agency, FAA must comply with the policies and procedures of NEPA and other related environmental laws, regulations, and orders applicable to its actions. As described in FAA Order 5050.4B, NEPA Implementing Instructions for Airport Actions, FAA must identify the potential alternatives that are available to achieve the purpose and need for a proposed project, and present the basis used to make an informed decision regarding the selection of a preferred alternative (FAA, 2006a). Neither NEPA nor FAA regulations require a specific number of alternatives or a specific range of alternatives to be included in an Environmental Assessment (EA). However, an EA must consider the proposed action and the consequences of taking no action. For each alternative considered but eliminated from further study, a project Sponsor must briefly explain why the alternative was eliminated from further discussion (FAA, 2006a). Pursuant to FAA regulations set forth in Order 5050.4B, an alternatives discussion must include: Alternatives considered, including the Proposed Action and the No Action alternatives. A concise statement explaining why any initial alternative was not considered in detail. A statement identifying a preferred alternative, if one has been identified. Applicable laws, regulations, executive orders and associated permits, licenses, approvals, and reviews required to implement a project alternative. Each action s expected environmental impacts. Conceptual measures needed to mitigate those impacts. 3.2 Proposed Alternatives The purpose of examining alternatives is to ensure that an alternative that may enhance environmental quality or have a less detrimental effect is not prematurely dismissed from consideration. The Airport identified two alternatives that could be implemented to achieve the proposed project s purpose and need, but dismissed one of the alternatives from detailed evaluation. The Airport also evaluated a No Action alternative. Although the No Action alternative would not achieve the proposed purpose and need, NEPA requires project sponsors to consider a No Action alternative because it serves as a baseline against which the environmental effects of a proposed project can be compared. Sections 3.2.1 and 3.2.2 present a discussion of the alternatives that were retained for detailed analysis. Section 3.2.3 describes the alternatives that were dismissed from detailed analysis in the EA. Draft Environmental Assessment 7

CHAPTER 3 ALTERNATIVES 3.2.1 Preferred Alternative The Airport proposes to construct Taxiway J and associated exit and connector taxiways. Taxiway J would serve Runway 14-32 as a parallel taxiway on the runway s east side. Taxiway J would be constructed 400 feet east of Runway 14-32 (measured centerline to centerline). This is the minimum separation between the runway and taxiway required to meet FAA standards. The proposed action may result in the loss of up to 969 Applegate s milk-vetch (Astragalus applegatei), a federally listed endangered plant. The Proposed Action will improve the safety of taxiing operations of aircraft using the east side of the Airport by reducing or eliminating the need to cross intermediate runways following landings or prior to departure. Principal users of Taxiway J will be aircraft associated with the U.S. Forest Service fire attack base, tenants of the three banks of hangars located on the east side of the Airport, and transient aircraft using the east side aprons. This alignment of Taxiway J was used by the Air National Guard in configuring their munitions storage bunkers. The Inhabited Building Quantity Distance (IHQD) setback is designed to provide an acceptable level of safety for occupied structures, given the quantity and type of munitions stored in the bunkers. The IHQD line is set so that it is three feet from the proposed eastern edge of Taxiway J. This places occupants of aircraft on Taxiway J outside of the IHQD. The Preferred Alternative would provide for a permanent, cost-effective solution that fulfills the proposed project s purpose and need. 3.2.2 No Action Alternative Under the No Action alternative, Taxiway J and its associated exit and connector taxiways would not be constructed. Existing aircraft taxiing routes would remain in use. The No Action alternative would not meet the purpose and need, nor would it create any environmental impacts. 3.3 Alternatives Dismissed from Further Evaluation 3.3.1 Shift Alignment of Taxiway J to the East Modifying the location of the project is the only alternative identified that had the potential to reduce or eliminate impacts to the milk-vetch while meeting the project s purpose and need. Specifically, the Airport considered shifting Taxiway J further to the east as a possible means of reducing the number of Applegate s milk-vetch plants impacted by the project. Applegate s milk-vetch plant location data was used to assess the potential value of shifting the alignment of Taxiway J to the east. This data was collected in 2013 by U.S. Fish and Wildlife Service as part of periodic monitoring of the plant s status, and by WH Pacific as part of the preparation of this EA. This data indicated that Taxiway J would have to be shifted at least 100 feet further east to significantly reduce the number of milk-vetch plants affected by the project (see Figure 3-1). This alternative was initially dismissed because it would place aircraft on Taxiway J inside the Inhabited Building Quantity Distance (IHQD) line associated with the Air National Guard s (ANG) munitions Draft Environmental Assessment 8

CHAPTER 3 ALTERNATIVES storage bunkers. The IHQD setback is designed to provide an acceptable level of safety for occupied structures, given the quantity and type of munitions stored in the bunkers. Shifting Taxiway J 100 feet further east could only occur if the IHQD line was relocated so that the new taxiway alignment remained outside the IHQD line. This would require relocation of the ANG s munitions bunkers. Relocating the bunkers further east is problematic because it would shift the bunkers closer to residences associated with farms east of the Airport. It appears that a 100-foot shift would require acquisition of up to three residences, depending upon the configuration of the bunkers. A 100-foot shift might also require relocation of the BNSF rail line that forms the eastern boundary of the Airport. In addition to the anticipated need to eliminate the farm residences, there is also the potential that a 100- foot shift would require acquisition and abandonment of the associated farm. There is no readilyavailable funding source for relocation of the munitions bunkers. Based upon all of the factors noted above, the alternative of shifting the proposed alignment of Taxiway J further to the east was dismissed as being infeasible. 3.3.2 End-Around Taxiway End-around taxiways have been occasionally constructed at major hub airports (e.g. Dallas-Fort Worth) to improve safety and increase capacity. An end-around taxiway is one that loops around the end of a runway. This type of taxiway permits aircraft to taxi from one side of a runway to another without crossing it. An end-around taxiway is located at a sufficient distance to permit the runway to remain in operation while aircraft are using this taxiway. At this Airport, the end-around taxiway would have to be located about 2,300 feet north of the runway end. An end-around taxiway would at least partially satisfy all four needs that are to be addressed by this project. For aircraft landing on Runway 25, it would eliminate the need to cross Runway 14-32 in order to reach the east side. For landings on runway 7 it would reduce the crossings of Runway 14-32 to one. This alternative would reduce to one the crossings of Runway 14-32 required to taxi from the east side to Runway 25 for a crosswind departure. This runway is most commonly used when crosswinds occur. The alternative is judged to be impractical because it would require placing State Highway 140 (Southside Expressway) in a 1,200-foot long tunnel, relocation of an active rail line, relocation of six ball fields and a variety of secondary roads. The cost and complexity of these collateral elements of an endaround taxiway are judged to make this alternative infeasible. 3.4 Permits, Licenses, Approvals and Reviews As required under paragraph 405d(4) of FAA Order 1050.1E, a list of permits, licenses, approvals and reviews required for implementation of the Proposed Action is provided in Table 3-1. Draft Environmental Assessment 9

CHAPTER 3 ALTERNATIVES Table 3-1 List of Permits, Licenses, Approval, and Reviews Required for the Proposed Action Issuing Agency Federal Federal Aviation Administration Federal Aviation Administration U.S. Fish and Wildlife Service State Department of Agriculture Department of Environmental Quality Permit Name/Type Unconditional ALP approval to show Taxiway J as-built Approval of Airport Improvement funds for the project Federal Endangered Species Act Biological Opinion Listed Plant Permit General Permit No. 1200-C, Construction Storm Water (NPDES permit) Draft Environmental Assessment 10

CHAPTER 3 ALTERNATIVES Figure 3-1 Runway Alignment Alternatives Draft Environmental Assessment 11

CHAPTER 4 AFFECTED ENVIRONMENT 4.1 Purpose of Chapter The general location of the Airport and a broad description of the project are provided in the introductory chapter, Chapter 1. This chapter will provide a more detailed description of the project and background information on the Airport s environs. This information provides the context for the evaluation of impacts in Chapter 5, Environmental Consequences and Mitigation. 4.2 Detailed Project Description The Airport proposes to construct a taxiway parallel to and east of Runway 14-32 (Figure 4-1). This taxiway will be designated Taxiway J. Taxiway J will be 75 feet wide and 10,301 feet in length. It will be sited 400 feet east of the runway. Three new exit taxiways (75 feet wide by 292.5 feet long) will connect the parallel taxiway to the runway. Not all of these taxiways have been assigned formal names on the currently adopted Airport Layout Plan (ALP); therefore, for ease of discussion in this document, the three taxiways connecting Taxiway J to the runway are labeled Taxiways 1, 2, and 3. Additionally, the taxiway that will extend east of Taxiway J to connect to an existing aircraft parking apron (an apron being an aircraft parking area) is labeled Taxiway 4. This taxiway will be located about 1,000 feet from the northern end of Taxiway J. It will extend east from Taxiway J about 200 feet to the existing parking apron. Taxiway edge lights will be installed adjacent to the four taxiways. Internally illuminated guidance signs will be located adjacent to the taxiways at each taxiway intersection (see Figure 4-2). Construction access will be gained from the east side of the Airport via Brett Way (see Figure 4-3). The decommissioned runway will be used to provide access from Brett Way to the construction area. The existing entrance road and gate to this area cannot accommodate construction vehicles. A 20-foot wide opening is needed to accommodate construction vehicles and the existing gate is only about 12 feet wide. Additionally, the alignment of the paved area immediately inside the gate is too sharp for construction vehicles to make the turn onto the decommissioned runway. Therefore, a temporary gate will be installed immediately east of the existing gate. A 20-foot wide by 90-foot long gravel connector will be created to temporarily join Brett Way to the decommissioned runway. An opening in the fence will be made and a temporary 20-foot swing gate will be installed. Gravel will be placed to span the gap between Brett Way and the decommissioned runway. At the completion of the project, the gate and gravel will be removed and the fence fabric replaced. This route has been used for prior construction projects. Draft Environmental Assessment 12

CHAPTER 4 AFFECTED ENVIRONMENT Figure 4-1 Project Elements Draft Environmental Assessment 13

CHAPTER 4 AFFECTED ENVIRONMENT Figure 4-2 Typical Taxiway Light & Sign Layout Draft Environmental Assessment 14

CHAPTER 4 AFFECTED ENVIRONMENT Figure 4-3 Study Area/Area of Potential Effect Draft Environmental Assessment 15

CHAPTER 4 AFFECTED ENVIRONMENT The project site includes the footprint of Taxiway J, associated Taxiways 1 through 4, the associated drainage slopes that will be constructed adjacent to the taxiways, a construction staging area and the gravel connector route (Figure 4-3). The area paved by this project will be 19.3 acres; however, the total ground area disturbed by this project could be as large as 93 acres. The unpaved area would be disturbed by grading needed to prepare the site for paving and ensure proper drainage, trenching needed to place conduit for taxiway edge lights, lighted signs and potentially small drain pipes, and construction of a 90-foot long gravel access route. A formal schedule does not yet exist because the engineering design for the project has not been prepared. However, the project engineers expect the project duration to be between 150 and 180 days. The project design could begin as early as February 2015. Construction could possibly start the fall of 2015; however, the construction start date is dependent upon the issuance of FAA grant funds. It is possible that grant funds for construction would not become available until Fiscal Year 2016. If this occurs, construction could begin that summer and be completed by the fall of 2016. 4.3 Affected Environment 4.3.1 Land Uses The Airport lies within the incorporated limits of the City of Klamath Falls (City; see Figure 4-4). Most of the land surrounding the Airport falls within the jurisdiction of Klamath County (County). Land uses adjacent are predominantly agricultural. A small area of commercial and industrial uses lie adjacent to the Airport s northwest corner. Scattered rural residential uses lie east of the Airport; the nearest being about one-half mile from the Airport s property boundary. Suburban density residential uses start about one-third mile northeast of the Airport. An isolated residential subdivision lies two miles southwest of the Airport. The adopted land use plans for the City of Klamath Falls and Klamath County anticipate the current pattern of land uses to continue (see Figure 4-5). Agricultural uses will remain in the areas west, south, and east of the Airport. Commercial and industrial uses will expand in the area northwest of the Airport. Suburban density residential uses will expand in the areas northeast of the Airport. 4.3.2 Population and Economy The Airport is located within the City of Klamath Falls which has a current population of about 21,000. This makes the City the largest community within the County. If the urban area is included in the population 1, the Klamath Falls community is estimated to contain 42,000 people. This is about twothirds of the County s total population. The broad trend in the County s population over the last 50 years is one of slow growth; however, as can be seen in Table 4-1, there have been periodic small declines in population reflecting economic downturns. 1 City of Klamath Falls, History of Klamath Falls, accessed on September 27, 2014 at: http://ci.klamathfalls.or.us/visitors/history Draft Environmental Assessment 16

CHAPTER 4 AFFECTED ENVIRONMENT Figure 4-4 Existing Land Uses Draft Environmental Assessment 17

CHAPTER 4 AFFECTED ENVIRONMENT Figure 4-5 Planned Land Uses Draft Environmental Assessment 18

CHAPTER 4 AFFECTED ENVIRONMENT Table 4-1 Klamath County Population 2, 3 Year 1970 1970 1980 1990 2000 2010 2013 Population 47,475 50,021 59,117 57,702 63,775 66,380 65,910 Major employers in the Klamath Falls area include a mix of manufacturing, medical, government and service and retail sectors. One of the area s biggest employers, the Oregon Air National Guard, is located on the Airport. The Guard base at the airport is home to the 173rd Fighter Wing. The fighter wind is responsible for training air-to-air combat pilots. Table 4-2 Klamath Falls Area Major Employers 4 JELD-WEN Windows and Doors Windows and doors manufacturers 1,200 Sky Lakes Medical Center Health care services 1,040 Oregon Air National Guard Government air defense 1,019 Klamath County School District Education services for K-12 800 N.E.W. Corp Call center 700 Klamath County County government 575 Klamath Falls City Schools Education services for K-12 440 Wal-Mart General retailer 400 Oregon Institute of Technology Higher education 387 City of Klamath Falls City government 175 4.3.3 Applegate s Milk-Vetch The principal resource of concern in the proposed project is the Applegate s milk-vetch (Astragalus applegatei). This milk-vetch (see Figure 4-7) is an endangered species with a narrow distribution limited to six currently known locations, all within the County. At the time of listing in 1993, Applegate s milk-vetch was only known at two locales (USFWS 1993). These two sites included a tract with approximately 30,000 plants (Ewauna Flat) and a tract with 30 to 80 plants (Miller Island) (USFWS 1993). Since 1993 five additional populations of milk-vetch have been discovered including the population at the Airport, the Collins Site (10,000 plants), the Worden Site (9 plants), the Washburn Way Railroad Site (300 plants), and a private property site (13 plants). Also since 1993, the once Figure 4 7 Applegate's milk vetch Source: U.S. Fish and Wildlife Service 2 U.S. Bureau of the Census, Population of Counties by Decennial Census: 1900 to 1990, Compiled and edited by Richard L. Forstall, Population Division (March 27, 1995) 3 U.S. Bureau of the Census, State & County QuickFacts, accessed on September 27, 2014 at: http://quickfacts.census.gov/qfd/states/41/41035.html 4 Klamath County Economic Development Association, Community Profile, accessed on September 29 at: http://www.sobusi.com/profileskceda/kcedacountyprofile.pdf Draft Environmental Assessment 19

CHAPTER 4 AFFECTED ENVIRONMENT substantial population of 30,000 plants at the Ewauna Flat site has dwindled to approximately 2,200 plants. As such the populations at the Airport and the Collins Site currently represent the largest known populations of Applegate s milk-vetch. Most significantly, the Airport s population is the only one of these two to occur on public land. This is significant because Oregon Revised Statutes Chapter 561 and 564 grants the Oregon Department of Agriculture authority to protect threatened or endangered plant species found on public lands. None of the currently known populations of Applegate s milk-vetch occur on federal lands. Applegate s milk-vetch was first identified at the Airport during surveys conducted in the summer of 2007. The initial discovery of the species was isolated to the northeast corner of the facility and limited to several hundred plants. In 2008, following this initial discovery, further surveys and a complete census were conducted across the Airport and adjoining City-owned properties. As a result of these surveys and census the number of plants identified occurring on and around the Airport expanded to 21,049. A more recent survey, conducted during the summer of 2013 found 21,953 plants within the same area. In addition to these, 2,639 milk-vetch were identified in 2012 within a portion of the Airport left unsurveyed in 2013, bringing the estimated 2013 total of milk-vetch on and near the Airport to 24,000. The distribution of milk-vetch within the project site can be seen in Figure 3-1. 4.3.4 Other Related Actions This safety-related project is not directly linked to any currently-identified subsequent action. The majority of the east side of the Airport, which will be served by Taxiway J, cannot be developed as long as the Air National Guard s munitions bunkers remain in their present location. Draft Environmental Assessment 20

CHAPTER 5 ENVIRONMENTAL CONSEQUENCES AND MITIGATION 5.1 Analytical Approach FAA Order 5050.4B, NEPA Implementing Instructions for Environmental Actions (FAA, 2006a), and FAA Order 1050.1E, Environmental Impacts: Policies and Procedures (FAA, 2006b), provide FAA guidance for implementing NEPA. FAA Order 1050.1E identifies the potential environmental impact categories that should be considered in an environmental analysis. Not all projects are the same, and not all environmental resources identified for analysis are affected by every project. As a result, the contents of an Environmental Assessment (EA) may vary according to the proposed action. Pursuant to FAA Order 1050.1 E, an EA should: present detailed analysis, commensurate with the level of impact of the proposed action and alternatives, to determine whether any impacts will be significant. If the proposed action and its alternatives will not cause impacts within specific categories of environmental impacts, a brief statement describing the factual basis for the conclusion that the action is not likely to cause environmental impacts within these impact categories is sufficient. Subsequent FAA guidance set forth in January 10, 2011, further enunciates the need to provide concise analysis based on the presence and extent of resources associated with the proposed project and the nature of the project itself. In its memorandum, Guidance on Preparing Focused, Concise and Timely Environmental Assessments, FAA states that FAA Order 1050.1E lists all impact categories. However, it is not the intent for all categories to require detailed discussion of analysis. The EA should concentrate on areas where there may be significant environmental impacts, or where there are uncertainties that require evaluation. 5.2 Environmental Resources that are Not Present or Unlikely to be Affected by the Proposed Project As directed in FAA Order 5050.4B, NEPA Implementing Instructions for Environmental Actions (FAA, 2006a), this chapter succinctly describes only those environmental resources the proposed action and its reasonable alternatives, if any, are likely to affect The no action and proposed action would not affect the following resources for the reasons noted: Coastal resources Wild and scenic rivers Coastal Barriers/Coastal Zone Management Barrier islands occur along all coastlines of the United States. Coastal zones are those waters and their bordering areas in states along the coastlines of the Draft Environmental Assessment 21

CHAPTER 5 ENVIRONMENTAL CONSEQUENCES AND MITIGATION oceans, the Gulf of Mexico, and shorelines of the Great Lakes. The proposed project area is located in southern central Oregon, approximately 130 miles from the nearest part of the Pacific Ocean. The proposed project site is neither within a designated coastal zone nor within an area governed by a local coastal zone management plan. Wild and Scenic Rivers "Wild and scenic rivers are those rivers having remarkable scenic, recreational, geologic, fish, wildlife, historic, or cultural values. Federal agencies may not assist or, by loan, grant, or license or other authorizations, a water resources action that would have a direct or adverse effect on the values for which the river was designated. An inventory of designated rivers is contained in the National Rivers Inventory (NRI). The wild and scenic river nearest to the project site a portion of the Klamath River located approximately 15 miles west of the project area. 5.3 Environmental Resources Subject to Detailed Analysis 5.3.1 Air Quality 5.3.1.1 Threshold of Significance An air quality impact would be considered significant if it exceeded one or more of the National Ambient Air Quality Standards. The Oregon Department of Environmental Quality Air Quality serves the state through planning, guidance, source control and review, permitting, and regulation. This project is safetyrelated and will not change either the total volume of aircraft operations or the fleet mix (i.e., the types of aircraft). It would reduce taxiing distances for some aircraft. Therefore, operationally the project would have a minor positive impact on air quality. Construction impacts need to be assessed. The State of Oregon does not maintain thresholds for construction-related air quality impacts. Therefore, the U.S. EPA de minimis levels were used for this analysis. The de minimis levels are the threshold above which a conformity determination for a project must be performed. The de minimis thresholds as relevant to the Airport are as follows: PM2.5-100 tons per year (nonattainment) PM10-100 tons per year (maintenance) CO - 100 tons per year (maintenance) 5.3.1.2 Analysis The U.S. EPA NONROAD Model is the recommended model for measuring construction-related and other off-road air quality impacts. The model was used to obtain emission rates for the specific vehicles expected to be utilized during construction. The construction duration is expected to last for approximately 80 work days and 20 work nights. This can be further refined to approximately 882 hours of various equipment run times (see Appendix B). The total hours (run time) of each type of construction equipment were then multiplied by the emissions factors as provided in the EPA NONROAD model. For the entirety of the construction phase of the taxiway project, the emissions are estimated to be as follows: Draft Environmental Assessment 22

CHAPTER 5 ENVIRONMENTAL CONSEQUENCES AND MITIGATION PM2.5 - not calculated presumed to conform (see discussion below) PM10-0.057 tons (114.6 lbs.) CO - 0.325 tons (651.5 lbs.) PM2.5 was not calculated for two reasons: 1) NONROAD does not provide emission rates for PM2.5, and 2) the proposed project falls into a presumed to conform category for PM2.5. In the February 12, 2007 Federal Register notices, the Department of Transportation, Federal Aviation Administration (FAA) published the Federal presumed to Conform Actions under General Conformity. Section III of the notice contains presumed to conform project descriptions and justifications and Table III-1 (see Appendix B) contains presumed to conform limits for selected projects. Since the proposed project at the Airport is the construction of a taxiway, the column New Airfield Work (non-runway) is applicable. The presumed to conform category for new airfield work (non-runway) has a maximum project square foot area of 26,050,568. The taxiway project will consist of approximately 883,510 square feet, thus the project should fall under this presumed to conform category for PM2.5. Based upon the preceding analysis, it is concluded that no significant impacts for PM2.5, PM10, and CO would occur and no conformity determination is required; therefore, no mitigations are required. 5.3.2 Compatible Land Uses 5.3.2.1 Threshold of Significance Although factors other than noise are considered in assessing impacts to compatible land uses, noise impacts are the only factor for which thresholds of significance have been established. For most land uses a noise impact is considered significant when noise sensitive areas located at or above DNL 65 experiences a noise increase of at least 1.5 db when compared to the No Action alternative. A separate threshold of significance has not been established for natural parks, national wildlife refuges and historic sites; however, Order 5050.4B notes that the DNL 65 db threshold may not adequately address noise effects on visitors to these areas. In these cases the guidance is to consult with the agency with jurisdiction over the potentially affected area. Where a project would result in other impacts exceeding thresholds of significance which have land use ramifications (e.g., disruption of communities, relocation, or induced socioeconomic impacts), the effects on land use shall be analyzed in that context. 5.3.2.2 Analysis This project is safety-related and will not change either the total volume of aircraft operations or the fleet mix (i.e., the types of aircraft); therefore, the project will have no effect on the noise contours and mitigation of noise effects is not required. The sections evaluating potential socioeconomic and secondary impacts that follow conclude that the project would not significantly affect these environmental factors; therefore, it is concluded that this project will not create impacts on compatible land uses that require mitigation. Draft Environmental Assessment 23

CHAPTER 5 ENVIRONMENTAL CONSEQUENCES AND MITIGATION 5.3.3 Construction Impacts 5.3.3.1 Threshold of Significance A separate set of thresholds of significance for construction impacts do not exist. Rather, the thresholds associated with the resources that construction would affect are those that apply to this impact category. For the Taxiway J project, the relevant resources categories would be: Air quality Fish, wildlife, and plants Hazardous materials Historical, architectural, archaeological, and cultural Light emissions and visual effects Natural resources and energy supply Environmental health and safety risks Solid waste Water quality 5.3.3.2 Analysis Based upon the analysis presented in the sections addressing the resource categories noted above, this project would only have a significant effect on a resource described in the section on fish, wildlife, and plants. The affected resource is a federally endangered plant: Applegate s milk-vetch. Measures to avoid, reduce, and mitigate impacts to this plant are described below. 5.3.4 Department of Transportation Act Section 4(f) 5.3.4.1 Threshold of Significance This impact category addresses use of any publically owned land from a public park, recreation area, or wildlife and waterfowl refuge of national, state or local significance or land from an historic site of national, state or local significance as determined by the officials have jurisdiction. A significant impact to these uses would occur when the proposed project involves more than a minimal physical use of the property or is determined to be a constructive use substantially impairing the property where mitigation measures do not reduce the impact below the threshold of significance. Noise and air quality are the most common forms of potential constructive use. 5.3.4.2 Analysis This project will involve construction of taxiways located within the existing airfield operations area. The nearest park or recreational area is Keller Park which is located about two miles northeast of the project site. The nearest wildlife or waterfowl refuge is Bear Valley National Wildlife Refuge which is located about 10 miles southwest of the project site. The Oregon State Historic Preservation Office concurred that no significant cultural resources are known to exist within the project area. The project would not change noise or air quality impacts (except less than significant air quality impacts during construction) of the Airport. This indicates that there would not be any constructive impacts on any historic properties in the Airport s environs; therefore, it is concluded that no significant Section 4(f) impacts exist that require mitigation. Draft Environmental Assessment 24

CHAPTER 5 ENVIRONMENTAL CONSEQUENCES AND MITIGATION 5.3.5 Farmlands 5.3.5.1 Threshold of Significance A significant impact to farmlands is defined as a project that generates a combined score ranges between 200 and 260 on U.S Department of Agriculture s Form AD-1006, Farmland Conversion Impact Rating. 5.3.5.2 Analysis On February 28, 2014, Form AD-1006 for the Taxiway J project was submitted to the Natural Resource Conservation Service (NRCS). On March 4, 2014, staff from the Klamath Falls NRCS office indicated in an e-mail that: the taxiway construction will occur within an already developed airport area; that is, the property has not been farmed for years and will not be farmed again. Essentially, there is no reason for NRCS to assess the loss of farmland for federally funded projects under FPPA on this commercial or industrial property. 1 5.3.6 Fish, Wildlife and Plants 5.3.6.1 Threshold of Significance Order 1050.1E indicates that impacts to both federally listed (i.e., threatened or endangered) species and major impacts to non-listed species need to be considered. For federally listed species, a project would have significant impacts if the U.S. Fish and Wildlife Service or the National Marine Fisheries Service determines that it would likely jeopardize a species continued existence, or destroy or adversely affect a species designated critical habitat. For non-listed species, a specific threshold of significance has not been established. Rather, the FAA is directed to consider scientific literature on and information from agencies having expertise on the affected species. The key concern is whether the project would affect the sustainability of the species. 5.3.6.2 Analysis A Biological Assessment (BA; see Appendix C) was prepared in support of this Environmental Assessment. The BA indicated that only one species of concern would be affected: Applegate s milkvetch (Astragalus applegatei). Applegate s milk-vetch (milk-vetch) is a federally endangered plant. Project activities are currently expected to result in the direct elimination/removal of 969 individual milkvetch plants through grading, paving, and project construction activities. Mitigation options considered included the following: Establishment of on-site mitigation in the form of a conservation easement of other known onairport milk-vetch populations. Off-site mitigation in the form of a plant material salvage and transplantation. Payment in lieu of mitigation to the Oregon Department of Agriculture (ODA) for propagation, seed banking, and planting/transplanting research and implementation. 1 E-mail from David Trochlell, NRCS Resource Soil Scientist (March 4, 2014). Draft Environmental Assessment 25

CHAPTER 5 ENVIRONMENTAL CONSEQUENCES AND MITIGATION Implementation of rabbit control. Offsite mitigation in the form of purchase of private-party lands containing milk-vetch populations. Formalization of vegetation management program (mowing) to improve the probability of persistence of the species at the facility. Restoration of publically owned and milk-vetch colonized off-site properties. A combination of one or more of the above. To comply with the ODA-administered No Net Loss policy for actions on public lands and because FAA policy does not allow on-airport mitigation, the off-site purchase and preservation of private party lands was determined to be the preferred mitigation option for direct plant impacts. However, because the owners of suitable lands containing the species were unwilling to sell their properties, this option was abandoned. As a result of this complication, additional mitigation and land management activities were examined, which resulted in the identification of actions to mitigate and minimize impacts. In an agreement with ODA (dated February 17, 2015), the City agreed to fund specified tasks by ODA and undertake specified minimization efforts at the Airport (included in Appendix A). Mitigation actions include the following: The City will fund a two-year milk-vetch seed collection task as the initial step in a seed banking program. Seeds will be taken from five naturally occurring populations in the Klamath Basin. The goal will be to obtain an average of 5,000 seeds from each site to include sufficient genetic diversity in the collection. Given the differing number of plants at each site, more seeds will be collected at sites with more plants and fewer at sites with smaller populations. The City will fund preparation and documentation of each year s collection of seed for long-term storage. This funding will also include a one-time contribution to establish an endowment to support cryogenic storage of the seeds at the Rae Selling Berry Seed Bank at Portland State University. The City will fund a feasibility study to improve the production of milk-vetch seed through cultivation. The cultivation effort will be undertaken by the J. Herbert Stone Nursery. The Nursery is a Forest Service research facility in the Rogue Valley. The goal will be to produce 400 plants to support evaluation of seed production levels and any related biological issues. Any seeds produced with either be donated to the Rae Selling Berry Seed Bank or used in local restoration projects. The City has agreed to fund extension of the milk-vetch monitoring program at Euwana Flat Preserve through 2018. The goal is to develop a cultivation and transplantation protocol that would increase survival rates in outplanted milk-vetch plants. As a part of this program an additional 400 milk-vetch would be planted. Topsoil removed from project construction areas containing milk-vetch will be available for use by State and/or contracted nurseries (see item 1). This soil is anticipated to contain seed stock and mycorrhizal fungi necessary for successful propagation of the species and is valuable resource for propagation efforts. Additionally, minimization methods will be implemented as part of the project development. These will also serve to reduce impacts to existing plants, increase the likelihood of continued species persistence, Draft Environmental Assessment 26

CHAPTER 5 ENVIRONMENTAL CONSEQUENCES AND MITIGATION and limit mitigation needs. In the agreement the City agrees to fund or implement the following actions to minimize and avoid impacts: The Airport will implement control of rabbits within controlled lands containing milk-vetch. Prior observations of herbivory on milk-vetch by several rabbit species has been noted on the facility and rabbits are common there. Control is expected to improve successful reproduction and productivity by milk-vetch. Control will not require substantial or regular ground disturbance or significant pedestrian or vehicular traffic into vegetated areas. The Airport will continue to utilize a mowing regime and mowing equipment that allows successful seed production by milk-vetch and minimizes ground disturbance in vetch-colonized areas. Mowing in all milk-vetch occupied areas will be undertaken with decked blade mowers rather than flail mowers and mowing will be limited to a height that avoids cutting of milk-vetch site dependent, but approximately 6 inches or greater. An airport-wide milk-vetch survey will be conducted as part of the next and subsequent updates of the Airport Master Plan. This will provide ongoing documentation of the status of the plant on the Airport. Engineering design will minimize the grading and disturbance areas to avoid mapped plant occurrences. While new occurrences prior to construction may occur, avoiding known previous occurrences as practicable can reduce the ultimate number of impacted plants. During the growing season prior to construction, all milk-vetch plants within the construction limits and within a 100-foot buffer area around the construction limits will be flagged and counted. The location of plants will be mapped so that the data may be imported into construction design drawings. All flagged plants will be avoided as practicable. Avoidance will include equipment travel, stockpiling of material, or staging. Equipment will travel along existing paved corridors, areas surveyed and devoid of milk-vetch, and areas planned for grading and project development only. Staging and stockpiling areas will be established on existing pavement only (See Exhibit 1). The limits of construction will be defined by orange construction fencing or other barriers. The orange construction fencing may not be able to be used in areas near the runway because it will not meet FAA standards. The City will make a one-time contribution to ODA to fund administrative and management costs associated with issuance of the state permit and implementation of the mitigation and avoidance measures. ODA activities will include necessary contract preparation, review of documents, coordination with other agencies and associated meetings. In addition to the minimization measures in the ODA agreement, the City will also undertake the following minimization actions as part of construction: Only clean fill will be utilized on site to avoid introduction of noxious weeds or other invasive species. Vehicles and project utilized heavy equipment will be inspected and cleaned daily or as needed in designated staging areas to prevent introduction of foreign seed or vegetative material. The combination of the avoidance, minimization and mitigation measures will reduce impacts to the milkvetch below a level of significance. Consultations (initially informal and now formal) between the Airport Draft Environmental Assessment 27