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Revised 1/14
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 5050.4B, "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 1050.1E 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, 5050.4B, Table 7.1.
2) 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.
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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.
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Complete the following information: 1. Project Location: Airport Name: Memphis-Shelby County Airport Authority Airport Address: 2491 Winchester Road, Memphis, TN 38116 City: Memphis County: Shelby State: Tennessee 2. Airport Sponsor Information: Point of Contact: James Hay Address: 2491 Winchester Road, Suite113 Telephone: 901.922.8224 Fax: 901.922.8211 E-mail: [email protected] 3. Evaluation Form Preparer Information: Point of Contact: James Hay Address: 2491 Winchester Road, Suite113 Telephone: 901.922.8224 Fax: 901.922.8211 E-mail: [email protected] 4. 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:
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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 quality-
based 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
5050.4B or 1050.1E, 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 1050.1E, Appendix A? Explain. (Note:
Noise sensitive land uses are defined in Table 1 of FAR Part 150). Yes ____ No X
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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, 2016. 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 150/5200-33, "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 No
Explain.
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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, 2016. 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 www.epa.gov/oar/oaqps/greenbk 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.
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(c) Is an air quality analysis needed with regard to indirect source review requirements or levels
of aircraft activity (See Order 1050.1E 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
51.853(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 2018.
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.
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EMISSIONS INVENTORY
Total Emissions by Year
Year CO Ozone Precursors de minimis
Thresholds NOx VOC
2017 21.45291 15.93298 33.0395 100
2018 10.77574 6.581295 23.79466 100
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 cost-
effective 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
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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.
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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 1050.1E, 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.
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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 email 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
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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 noise-
sensitive 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
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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
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 non-federal 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 5050.4B & 1050.1E, 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
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 meeting will be conducted in order to initiate and receive public comment. A copy of
this completed form will be made available during the public meeting.
Revised 1/14
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 Development Name, Title Memphis-Shelby County Airport Authority Affiliation
_________________________Signature
James Hay Director of
______________________________Siigngnature
H Di t f D
Revised 1/14
Note: This page to be completed by FAA only
14. FAA DECISION:
Having reviewed the above information, certified by the responsible airport official, it is the FAA
decision that the proposed project(s) of development warrants environmental processing as
indicated below.
The proposed development action has been found to qualify for a Short
Environmental Assessment.
The proposed development action exhibits conditions that require the preparation of
a detailed Environmental Assessment (EA).
The following additional documentation is necessary for FAA to perform a complete
environmental evaluation of the proposed project: ____________________________
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________
*Action Reviewed/Recommended by:
__________________________________________ ______________
(FAA Environmental Specialist) Date
*Approved: __________________________________________ _______________
(FAA Approving Official) Date
* The above FAA approval only signifies that the proposed development action(s), as described by the information
provided in this Evaluation Form, initially appears to qualify for the indicated environmental processing action. This
may be subject to change after more detailed information is made known to the FAA by further analysis, or though
additional federal, state, local or public input, etc.
MEMPHIS-SHELBY COUNTY AIRPORT AUTHORITY MEMPHIS, TENNESSEE
08-1260-01 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
MEMPHIS-SHELBY COUNTY AIRPORT AUTHORITY MEMPHIS, TENNESSEE
08-1260-01 DEICING PAD
APPENDIX A
STAKEHOLDER LETTERS
1
Nathan Luce
From: John McClurkan <[email protected]>Sent: Wednesday, December 17, 2014 4:26 PMTo: Nathan LuceSubject: Comments on MSCAA 08-1260-01
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: 615-837-5305 cell: 615-207-0955 fax: 615-837-5025
All emails and attachments sent and received from this email 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 email or attachment is subject to a specific exception in the public records act, emails 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
Nathan Luce
From: Stephanie Whitaker <[email protected]>Sent: Tuesday, December 16, 2014 3:17 PMTo: Nathan LuceSubject: MSCAA Project 08-1260-01
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 08‐1260‐01) 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 37243 Phone: (615) 532-4799 [email protected] http://www.tn.gov/environment/natural‐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 http://environment‐online.state.tn.us:8080/pls/enf_reports/f?p=9014:3:3875605994273657 We accept and encourage electronic document submittals. Please include a contact email with environmental review requests.
1
Nathan Luce
From: Herb Nicholson <[email protected]>Sent: Friday, December 19, 2014 1:10 PMTo: Nathan LuceCc: Ashley A. Holt; Lisa Hughey; Glen PughSubject: 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 38133 (901) 371‐3010 [email protected]
TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION MEMPHIS ENVIRONMENTAL FIELD OFFICE
8383 WOLF LAKE DRIVE BARTLETT, TN 38133-4119
PHONE (901) 371-3000 STATEWIDE 1-888-891-8332 FAX (901) 371-3170
December 29,2014
Mr. lames Hay Office: Memphis International Airport 2491 Winchester Rd., Suite 113 Memphis, TN 38116-3856
RE: Environmental Inquiry- MSCAA Project 08-1260-01 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) 371-3032.
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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