Monday, September 16, 2013

UPDATE: 16 September 2013 from Leslie Grey FAA


I wanted to let you know about an important update to the environmental process for the Kodiak Airport Runway Safety Area improvements.  Late last week, the FAA Alaskan Regional Administrator signed the Record of Decision (ROD) on the Final Environmental Impact Statement (FEIS) for the Runway Safety Area Project.  The ROD represents the formal approval required to proceed with the project.  Funds are currently being programmed for design and construction.  Notices that let the public know the ROD is available will be published in the Kodiak and Anchorage papers as well the Federal Register.  Copies of the ROD will be available within the next week at:  

  • The project website:
  • A. Holmes Memorial Library, 319 Lower Mill Bay Road, Kodiak, AK 99615
  • FAA Airports Division office in downtown Anchorage at 222 W. 7th Avenue.  Please call or email me before you visit, so I can coordinate

The ROD explains why the project was approved and includes a description of the final mitigation package, which has been expanded since the release of the FEIS. After a request from the Sun’aq Tribe, the FAA worked with the Tribe to further address possible impacts from the proposed project on the Buskin River fishery.  Through the resulting government-to-government coordination meetings, the FAA came up with a solution to address effects on the traditional subsistence practices of tribal members and other individuals using the fishery for harvest. The FAA decided that a five-year post-construction monitoring effort should be conducted to document the change in habitat and species usage around the mouth of the Buskin River.  This monitoring will be in addition to the mitigation described previously, including:
  • Paying a $2 million in-lieu fee payment to purchase high-value intertidal, estuarine and/or coastal habitat in the Kodiak Archipelago Islands area for preservation.  
  • Providing the Alaska Department of Fish & Game with $200,000 to fund additional subsistence management programs on the Buskin River for four years.
With the finalized mitigation plan and a signed ROD in place, the proposed project can proceed with design and go to construction (expected to begin next year).  This is the milestone we have been working toward and I can’t thank you enough for your participation and help in this process. As always, if you have any questions, please feel free to contact me by phone at 907-271-5453, email at  Kind regards, Leslie

Leslie A. Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Wednesday, May 22, 2013

UPDATE: 22 May 2013 - Mitigation Issues

Mitigation Draft Stakeholder Message No. 1 of 2

Good Afternoon!

Where oh where is summer?  I sure hope it arrives soon, I'm certainly ready for it!  In the meantime, a lot has happened with the Kodiak Airport Runway Safety Area (RSA) projects since my last e-mail, and I want to update you on a few items.  

As I wrote about in a previous e-mail, we have been developing a mitigation plan for the unavoidable adverse impacts that could result from the project.  The Federal Aviation Administration (FAA) and Alaska Department of Transportation & Public Facilities (ADOT&PF) have been working with agencies, tribes and other interested parties on how to best mitigate these impacts from the proposed projects.  

Mitigation is a fairly complex and lengthy topic. Instead of trying to cover all of the details in a single message, I think breaking the topic up into two parts works best.  This letter will focus on providing background on mitigation and how it applies to this project.  In my next letter, I will continue with specific information on how we developed the specific mitigation plan for this project.

What is mitigation?
One of the definitions I believe best describes the full range of options for mitigation is from the Council on Environmental Quality.  Generally, “mitigation” can be provided in many forms, including:
1.        Avoiding the impact altogether by not taking a certain action or parts of an action.
2.        Minimizing impacts by limiting the degree or magnitude of the action and its implementation.
3.        Rectifying the impact by repairing, rehabilitating or restoring the affected environment.
4.        Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action.
5.        Compensating for the impact by replacing or providing substitute resources or environments.

The descriptions above are “textbook” definitions. To connect these definitions to this project, here are some examples of mitigation measures that we have already incorporated into this project:

Avoiding: By selecting Runway 18/36 Alternative 7 as the preferred alternative for the RSA improvement, we avoided placement of any fill material near the mouth of the Buskin River.

Minimizing: Incorporating engineered materials arresting system (EMAS) for Runway 07/25 will allow us to reduce the amount of fill we would place in Womens Bay.

Rectifying the impact:  The Environmental Impact Statement (EIS) identifies several Best Management Practices that will be used to help restore the affected environment as much as possible.  One example of this is re-vegetating affected areas with native seed after construction is completed.

Compensating: This type of mitigation is usually reserved for unavoidable environmental impacts that cannot be avoided or lessened through other means.  

What unavoidable impacts need to be mitigated?
Even with the measures included to avoid, minimize, and repair the environmental impacts, there are still impacts that would be unavoidable.  The EIS identifies some unavoidable environmental impacts, including:
1.        Fill into marine waters resulting in a loss of “waters of the U.S.” (i.e. waters under the jurisdiction of the Army Corps of Engineers)
2.        Impacts to the Alaska Maritime National Wildlife Refuge
3.        Impacts to Essential Fish Habitat, including salmonids, which are covered under the Magnusson-Stevens Fisheries Conservation Act
4.        Negative effects on subsistence users, including minority and low-income populations as well as Alaska Native traditional and customary subsistence practices.

How can these unavoidable impacts be mitigated?
A “compensatory mitigation plan” describes the measures that will be taken to counteract impacts. The RSA Projects’ compensatory mitigation plan is currently under development.

The U.S. Army Corps of Engineers (ACOE) and the U.S. Environmental Protection Agency (EPA) have jointly issued the Compensatory Mitigation Rule. This Rule provides guidance on developing mitigation for projects, like this one, that require placement of fill into Waters of the U.S. The RSA Projects’ compensatory mitigation plan must comply with these rules for the ACOE to issue a permit that would allow fill to be placed into Womens Bay.

What are the objectives of the compensatory mitigation plan?
Simply stated, the objectives of the mitigation plan are to reduce the total severity of the projects’ adverse impacts.  To achieve those objectives, the mitigation plan’s goals include:
·        Improving or replacing habitat functions and values related to anadromous fisheries, migratory birds, and marine resources and habitats.
·        Replacing lost or affected subsistence opportunities and resources by providing access to or preservation of areas with subsistence resource values that have reasonable access from the Kodiak area (The Kodiak area is defined as Kodiak Island and Afognak Island).
·        Complying with the Compensatory Mitigation Rule

What mitigation types are examined under the Compensatory Mitigation Rule?
The Compensatory Mitigation Rule organizes several types of preferred mitigation options into a hierarchy: To follow the Rule, a permittee (in this case ADOT&PF) must attempt to mitigate its project in the following order:

This first preference requires the use of mitigation banks.  A mitigation bank is a wetland, stream, or other aquatic resource area that has been restored, established, enhanced, or preserved for the purpose of providing compensation for unavoidable environmental impacts.  

This type of mitigation is a type of “third-party” mitigation, where the permittee (ADOT&PF) pays a third-party by buying “credits” which are calculated based on the amount and type of resources affected.  The third-party uses the funds from these credits (combined with credits from other compensatory mitigation) to enhance, restore, or preserve the same types of resources that were affected through the existing mitigation bank.  A mitigation bank needs to be federally approved, and there are no federally approved mitigation banks in the Kodiak area (Kodiak Island or Afognak Island).  

Since mitigation banks cannot be used, the second preference is in-lieu fee programs. In-lieu fee programs occur when a permittee (ADOT&PF) provides funds to a third-party sponsor (generally a public agency or a non-profit).  The third-party sponsor then uses these funds to purchase lands that help enhance, restore or preserve the types of resources affected by the project within a local area (in this case Kodiak Island or Afognak Island).  

If approved mitigation banks or in-lieu fee programs are not available, the rule allows permittee-responsible mitigation, which in this case would mean ADOT&PF would complete a project restoration, establishment, enhancement, or preservation project of an area, instead of providing funds to a third-party.  For permittee-responsible projects, the Rule prefers the mitigation project to be “on-site” and “in-kind,” meaning the project would need to be near the RSA projects and mitigate for the same impacts described in the EIS.  In this case, ADOT&PF would also need to maintain the site permanently.

What‘s next?
We’re continuing to work on the compensatory mitigation plan, which I will update you on in my next letter, likely at the end of June or early July.  As always, if you have any questions or comments on the mitigation process or the Final EIS, please don’t hesitate to contact me at or by phone at (907)271-2851.

Sincerely, Leslie

Leslie A. Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Monday, February 25, 2013

Update 25 February 2013

Good Morning!

Wow, it is already the end of February, where does the time go?  It's time for an update on what we have been working on over the past month.  There’s a lot going on concurrently right now, so I’ll break up my update by subject to more easily highlight what’s happening.  

While the Kodiak Airport EIS includes several measures to avoid and minimize impacts, we are continuing our work on developing and refining a mitigation plan to mitigate those significant environmental impacts that are unavoidable.  As a quick recap of impacts detailed in the EIS, the preferred RSA alternatives would not completely avoid long-term environmental adverse impacts to wetlands (0.1 acres), waters of the US (17.8 acres), the Alaska Maritime National Wildlife Refuge (17.8 acres), and subsistence.

As part of developing the appropriate mitigation, we have upcoming agency and tribal coordination meetings in Kodiak and Anchorage the week of March 4th.  We will be discussing potential mitigation measures to develop a reasonable compensatory mitigation package for identified significant impacts.  We are still developing the details of the plan, but I will send everyone an update as the mitigation measures continue to get flushed out.  

Alaska National Interest Lands Conservation Act (ANILCA)
In my last message, I mentioned that we would be scheduling ANILCA Title XI hearings to receive comments on the potential impacts on those lands protected by ANILCA, such as the Alaska Maritime National Wildlife Refuge.  ANILCA requires that we will hold a hearing in both Kodiak and Washington D.C.  Based on our current schedule, the hearings should be held around mid-March.  I’ll send a message out once we officially have those hearings on the calendar.

Since our last update, the FAA has determined that an ANILCA Section 810 Subsistence evaluation will be prepared for the project.  Section 810 applies to projects that could affect subsistence resources on federal lands and because the proposed projects affect subsistence resources, FAA is preparing an 810 Evaluation for the preferred alternatives.  This evaluation will be released publically for review and comment.  As with Title XI, Section 810 also requires public hearings and we plan to hold the hearings for the 810 Evaluation at the same time as the Title XI ANILCA hearings.  

We will also provide a comment period for both Title XI and the Section 810 Evaluation, likely during the month of March.  The comment period will last approximately one month.  Again, once we have these dates cemented, we’ll get the word out.  The team will also place advertisements in local news sources for the hearing times, locations, and comment periods.

Final EIS Release
The team is busily developing responses to all comments received on the Draft EIS.  As mentioned in my last update, responses to all comments will be included in the Final EIS, along with any necessary changes to the document itself based on the comments.  As a reminder, we uploaded all the comments received on the Draft EIS onto the website, so if you have not already gotten a chance to open them up and are interested in what was submitted, take a look.  The link is provided below.

The Final EIS is scheduled to be released later this summer.  As usual, I’ll provide updates as we go.

As always, thank you for your interest in this project.  As we move forward on this project, I will continue to keep you updated with our progress.  But in the meantime, please let me know if you have any questions.  You can always reach me at 907-271-5453 or via email at

Best Regards, Leslie

Leslie A. Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Tuesday, February 12, 2013

FAA Update 1/23/13

Hello and Happy New Year! I hope all of you are off to a great start in 2013.  First and foremost, I want you to know how much I appreciate your participation in the whole EIS process, and most recently for the review and comment and public hearing of the Draft EIS.
We received all comments by the due date on December 18 and are starting the process of responding them.  All comments received will get a response and will be available in the Final EIS.  We will be working on this for the next few months.  
For anyone interested in seeing all the comments received, as well as the testimony from the public hearing, we have uploaded them to the project website.
In addition to working on the response to comments, the team is working on the compensatory mitigation plan.  The Kodiak Airport DEIS includes several measures to avoid and minimize impacts, but the preferred RSA alternatives would not completely avoid long-term environmental adverse impacts.  As a result, we are coordinating with others to determine the appropriate compensatory mitigation for these impacts.  We will continue to provide updates on both the status of the comment resolutions and the compensatory mitigation process as we move forward.
Finally, because the EIS alternatives involve fill into the Alaska Maritime National Wildlife Refuge an Alaska National Interests Land Conservation Act (ANILCA) Title XI application is required including public hearings in Kodiak and Washington D.C.  We are planning to have the hearings in late February/early March.  As we solidify these hearing details, I will most certainly get the information out to everyone.
That’s all for now, as always, please don’t hesitate to contact me by phone (907) 271-5453 or email:  
Best regards, Leslie

Leslie A. Grey
Environmental Protection Specialist

FAA - Alaskan Region, Airports Division


Wednesday, November 28, 2012

Public Meeting Thursday Dec 6, 5 pm, Convention Center

Good afternoon,

Two weeks ago we convened meetings in Anchorage and Kodiak to talk about the Draft EIS for proposed runway safety area improvements at Kodiak Airport. I’d like to thank those of you who participated. We had some good discussions, and I really appreciate all of the constructive feedback.  We’ll do our best to respond fully to your questions and comments.

If you were unable to attend, or are just interested in reviewing some of the information covered during those meetings, I’ve had the PowerPoint presentation we used posted on the project website at On that page, scroll down to “Project Reference Documents” and the presentation, in PDF form, is titled “Draft EIS Stakeholder Meetings November 2012.”

I’d also like to remind you that we have scheduled another round of consultations and meetings with tribes, agencies, and other stakeholders next week in Kodiak. If you would like us to meet with you or others in your organization, and haven’t already been contacted, please let me know and we’ll get in touch right away.

There are two events I just know you want to make sure are on your calendar. First, the public hearing for the Draft EIS will be Thursday night, December 6, at the Kodiak Convention Center. An open house with workshop stations will kick things off at 5:00 pm, and the formal hearing for public testimony will begin at 6:00 pm. Secondly, December 18 is the deadline for FAA to receive your comments on the Draft EIS. You can get those to me one of two ways, by 1) mail, to the address below or 2) e-mail, to my address at<>

Thanks, and see you soon!  Leslie

Leslie A. Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Saturday, November 3, 2012

Draft Preferred Alternatives – Kodiak Airport DEIS

The preferred alternatives for both runways look pretty good; the FAA seems to have heard the concerns of Kodiak residents in determining their choices.  We urge you to read through the EIS and comment in favor of these preferred alternatives.
Copies of the Draft EIS are now on shelves and on-line for review at the following locations:

 *   Federal Aviation Administration, Airports Division, 222 W. 7th Avenue #14, Anchorage, AK 99513-7504
 *   A. Holmes Memorial Library, 319 Lower Mill Bay Road, Kodiak, AK 99615
 *   On the website at:
Draft Preferred Alternatives – Kodiak Airport DEIS

Of the alternatives described above, the FAA has identified a preferred RSA-improvement alternative for runways 07/25 and 18/36. These Preferred Alternatives are illustrated in Figure 3 (see page 2). The Preferred Alternatives were selected based upon their ability to meet the project purpose and need while minimizing the anticipated environmental impacts.

For Runway 07/25, Alternative 2 was chosen as the Preferred Alternative because it would require the smallest fill footprint, therefore minimizing the environmental impacts compared to Alternative 3.

For Runway 18/36, Alternative 7 was chosen because it represented the only alternative that avoided placing fill in the sensitive Buskin River area and associated freshwater plume, which was identified as an important resource and a major concern for both the community and relevant agencies. Runway 18/36 Alternative 7 also minimizes fill toward the Buskin River State Recreation site. The best available information was used in identifying these Preferred Alternatives.

Wednesday, October 24, 2012

Draft EIS for the Kodiak Airport Runway Safety Area Improvements is officially on the street for review

Hi Everyone,

I just wanted to send you a short note letting you know that the Draft EIS for the Kodiak Airport Runway Safety Area Improvements is officially on the street for review starting today (Friday, October 19th).  Copies of the Draft EIS are now on shelves and on-line for review at the following locations:

 *   Federal Aviation Administration, Airports Division, 222 W. 7th Avenue #14, Anchorage, AK 99513-7504
 *   A. Holmes Memorial Library, 319 Lower Mill Bay Road, Kodiak, AK 99615
 *   On the website at:

Meetings with agencies, tribes and stakeholders are currently being arranged for mid-November.  The public information meeting and public hearing are set for Thursday, December 6, 2012 from 5:00 p.m. to 8:00 p.m. at Kodiak Harbor Conference Center, 211 East Rezanof Drive, Kodiak, AK.  We'll provide more details on this as we get closer.  

The comment period is now through December 18, 2012.  In addition to being able to submit comments at the hearing, if you prefer, you may also submit written comments any time during the comment period at the locations below:

 *   To my email:<>
 *   Written to my mailing address:
    *   Leslie Grey, AAL-614
    *   FAA, Airports Division Office
    *   222 W. 7th Ave, #14
    *   Anchorage, AK 99513
 *   On the website:

We have been working on this project a very long time and I appreciate your continued interest and patience with us and the project. We value your participation and your comments..

As always, please don't hesitate to call me if you have any questions and I look forward to seeing you in November/December.  Best regards,  Leslie

Leslie A. Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Thursday, October 11, 2012

EIS Update 11 October 2012

Hi Everyone,

I just wanted to send a short note alerting you to the status of the Draft EIS for the proposed Kodiak Airport RSA Improvements and our plans for the remainder of the year. I expect to distribute the DEIS in mid- to late-October, initiating a 60-day comment period that would end in mid- to late-December. I’ve tentatively set aside the week of December 3 for meetings in Kodiak and Anchorage with the public, tribes, agencies and other stakeholders. Depending on interest, I may also schedule meetings in mid-November with those of you who might be interested in a presentation and discussion about what is in the EIS: conclusions and findings, decisions to be made, other processes and permitting activities underway and so forth. I realize most of you would not have had a chance to fully read through the EIS by that time, but it may answer some early questions and help you get a sense of where we are headed. Then, by the December meetings you may have more specific questions, comments and topics for discussion.

Would you please let me know within the next week of any major conflicts with our tentative schedule for December? In the past there have been regional fisheries meetings in Anchorage in early December, and if possible I would like to avoid competing events that could prevent a lot of you from participating. I’m sure we won’t be able to accommodate everyone, but we’ll do what we can.

I’m really pleased to be close to the finish, at least for this phase of the work.  Please let me know if you have any immediate questions or schedule concerns, and I’ll be back in touch shortly with the DEIS.  

Best regards, Leslie

Leslie A. Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Wednesday, August 8, 2012

Kodiak Airport EIS Project Update 08 August 2012

Kodiak Airport EIS Project Update

For some time, the FAA has been preparing an environmental impact statement considering impacts associated with runway safety area improvements at Kodiak Airport. I think it is safe to say, at least on behalf of the FAA and consultants, that we are more than ready for the Draft EIS to be published for everyone to see. We aren’t quite finished; but we are very close. Our environmental analyses are undergoing review here in Anchorage and at FAA headquarters, and I think those will be the last hurdles before starting the public review portion of the work. My current goal is to publish a Draft EIS, including an ANILCA Title XI application and preliminary analysis, sometime this fall and most likely in October. We will provide 60 days for everyone to
review the Draft EIS and submit comments, and hold at least one public hearing for the Draft EIS in Kodiak during the review period. We will also hold public hearings concerning the ANILCA application in both Alaska and Washington, D.C.

I will keep you informed as we get closer to release of the Draft EIS. In the meantime, let me know if you have questions, comments or concerns. My phone number is 271-5453 or you can email

Best regards, Leslie Grey

Leslie A. Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Monday, July 2, 2012

UPDATE: 2 July 2012 from Leslie Grey

Hello All,

I know all of you are familiar with the Kodiak Airport environmental impact statement (EIS):  Why we are engaged in that process, how we’ve developed alternatives, and the many environmental and cultural concerns associated with some of the options to improve runway safety areas (RSAs).  I’d like to use this Project Update to introduce you to another process evaluation we are conducting concurrent with the EIS to comply with the Alaska National Interest Lands Conservation Act, or ANILCA.

What is ANILCA?
When Congress passed ANILCA as Public Law 96-487 in 1980, more than 100 million acres of federal lands in Alaska were converted into “conservation system units”.  Conservation system units are public lands in Alaska that have been given special designations because of their natural or cultural resources, or other attributes.  Wilderness areas and national monuments in Alaska are conservation system units, as are national wildlife refuges.  Congress recognized that Alaskans, particularly those living in remote areas, depend on utilities and means of transportation that must often extend across great distances. Air travel is often the only option. To meet the transportation needs unique to Alaska, including socioeconomic and public safety needs, Congress included some exceptions in ANILCA that establish a decision-making process to allow Alaskans to develop transportation and utility systems in conservation system units.
What exception in ANILCA may be relevant to the Kodiak Airport?
One portion of ANILCA, commonly referred to by its place in the law, “Title XI,” addresses whether and how transportation and utility systems can access and cross so-called “conservation system units.”  The submerged lands around the Kodiak Airport are within a conservation system unit, the Alaska Maritime National Wildlife Refuge. The Alaska Maritime National Wildlife Refuge, encompassing much of the Aleutian Chain and more than 2,500 islands, cliffs, headlands and other lands and marine waters from the Chukchi Sea to Southeastern Alaska, qualifies under ANILCA as a conservation system unit.  In fact, the Maritime Refuge was established by ANILCA when 11 existing refuges were combined with other lands and waters to form the largest unit within the National Wildlife Refuge system.
Does ANILCA Title XI Apply to the Kodiak RSA Improvement Projects?

Yes, Title XI of ANILCA applies to the proposed RSA improvements, and here’s why.  First, the runway safety areas are considered parts of a transportation system, in this case the Kodiak Airport that provides access for people and freight to and from Kodiak Island.  Second, the RSA improvements would cross into a conservation system unit, as the submerged lands offshore from the Airport in Chiniak Bay are within the boundaries of the Maritime Refuge.  
So ANILCA Title XI Applies to the RSA Improvement Projects - What’s the Catch?
Really, there is no catch, but it does add another layer of review and different approvals for the RSA projects to be constructed and used. The applicant (ADOT&PF) must submit a transportation and utility systems application to federal agencies with jurisdiction (i.e. permitting authority), where without the permit, the transportation and utility systems cannot be established or operated.  I guess there is a twist, though. Normally, for the Maritime Refuge, the U.S. Fish and Wildlife Service would be that agency with primary jurisdiction.  However, the portions of the Maritime Refuge immediately offshore from the Airport were withdrawn for defense purposes, in various installments through Executive Orders and Public Law Orders, starting about 1940.  I’ll save the details of those actions for the EIS, but the end result is that the U.S. Coast Guard also has jurisdiction over the Refuge lands that would be accessed by the RSA improvements and would also have to decide whether to approve or deny a right of way permit.  The U.S. Fish and Wildlife Service still have an important role to play, however, since they have management responsibility for lands within the Refuge and also resources within the Refuge (including some marine mammals, migratory birds, and threatened or endangered species). In addition, the FAA, as lead agency of the EIS and the agency that would fund the RSA improvements, also would be involved in the Title XI decision-making process.  All federal permitting agencies will be required to review the application for completeness, develop a decision on the application with detailed findings, and if appropriate, identify appropriate conservation measures to protect those resources.  

What are the Steps to Conform with ANILCA Title XI?

For the RSA improvement projects to be allowed in the Maritime Refuge, a number of findings and statements must be made by the agencies tasked with decision-making responsibilities.  For example, they must find there is no economically feasible or prudent alternative to routing the transportation system into the Refuge, and if there is not, whether there are other routes that would result in fewer or less severe impacts to the Refuge.  The agencies must also make detailed findings concerning the short and long term social, economic and environmental impacts of national, State or local significance, including impacts on fish and wildlife and their habitat and on rural, traditional lifestyles. If these and other findings sound familiar they should, because all are consistent with the types of analysis and conclusions that must be included within an environmental impact statement.    
Therefore, concurrent with the Kodiak Airport Draft EIS, Alaska DOT&PF will be submitting an application to the Coast Guard, USFWS, USACOE and FAA under ANILCA Title XI. Supporting documentation for the application will consist of the Draft EIS, prepared by FAA and addressing all of the information needed by the agencies with permitting authority to evaluate the application and develop the necessary findings and statements.  

Summary and Schedule

For some time FAA has been preparing an environmental impact statement considering impacts associated with runway safety area improvements at Kodiak Airport.  Our analysis of possible impacts caused by the proposed RSA improvements is almost complete, and I hope to publish for agency and public review a Draft EIS, including the ANILCA Title XI application and preliminary analysis, sometime later this summer.  The FAA will be providing the public, agencies, and tribes and other interested parties 60 days to review the DEIS.  The FAA, Coast Guard, USACOE and USFWS will review the Title XI application, and inform ADOT&PF in writing whether it contains the information required for evaluation under ANILCA (ANILCA § 1104 (d)).  During our EIS public comment period, we will also hold public hearings concerning the ANILCA application in both Alaska and Washington DC.  
I hope this introduction to ANILCA Title XI has been informative.  Please don’t hesitate to send an e-mail ( or call me at 907-271-5453.  Best regards, Leslie

Leslie A. Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Friday, May 25, 2012

UPDATE 25 May 2012 from Leslie Grey, FAA

Good Morning,

In keeping with our recent practice, I’m sending you this monthly update for the Kodiak Airport EIS.  We skipped April because we had face-to-face meetings with some agencies.  I much prefer those in-person conversations, but since we don’t have the time and budget to meet very often I’ll get back on schedule with our regular update.

As you are aware, it is typical although not required for federal agencies to identify a preferred alternative in draft NEPA analyses, for both environmental assessments and environmental impact statements.  There are many reasons why identification of a preferred alternative can be helpful, to the agencies and public, but for projects involving complicated alternatives or sensitive environmental resources the preference isn’t always easy to determine.  That is the case for proposed runway safety area improvements at Kodiak Airport. FAA and our consulting team needed to work through many challenging issues, including constraints on aviation operations at Kodiak.  Further, we realized (with help from many of you) that the environmental analysis for some resources needed to be more rigorous.

I’m pleased to report that we are now in a position to identify what FAA intends to include in the Draft EIS as preferred alternatives for runway safety area improvements to Runways 07/25 and 18/36.  They are:

·        Runway 07/25 - Alternative 2. This alternative would improve runway safety area on the primary, east-west runway by placing fill into marine waters east of Runway end 25.  A 600-foot long RSA would be constructed that includes an EMAS (engineered materials arresting system) bed measuring 340 feet long by 170 feet.  The EMAS would provide a 70-knot stopping capability for the B737-400, design aircraft.

·        Runway 18/36 – Alternative 7.  This alternative would improve runway safety areas on both ends of the north-south Runway 18/36.  At the north, Runway end 18, no additional disturbance would occur beyond the current airport boundary but an EMAS bed measuring about 155 feet long by 170 feet wide, offering a 40-knot stopping capability for the B737-400 would be installed on the existing pavement.  At the south, Runway end 36 the runway would be shifted about 240 feet further south, and a 360-foot RSA would be constructed for a combined 600 linear feet of new fill beyond the existing runway threshold.
The preferred alternatives and other build alternatives that will be evaluated in the Draft EIS are shown in the figure Kodiak RSA Alternatives Comparison on the EIS web site at
Now that we have preferred alternatives we can move forward with some final work necessary to the environmental evaluations and compliance with other state and federal laws.  For example, we recently met with USFWS and NOAA Fisheries to re-initiate consultation required by the Endangered Species Act.  FAA will be submitting draft biological assessments to both of these agencies concurrent with publication of the Draft EIS.  Similarly, concurrent with the Draft EIS ADOT&PF will be submitting to the U.S. Coast Guard and USFWS an application for an ANILCA Title X permit.  The Draft EIS will serve as the requisite NEPA documentation supporting their application.
We still have much other work to be completed, including further consultation and coordination with many of you, but I fully expect the Draft EIS will be released to the public later this summer.  As I mentioned in the last project update, FAA will provide 60 days for everyone to review the Draft EIS and submit comments, and at least one public hearing will be held in Kodiak during the review period.
I will keep you informed as we get closer to release of the Draft EIS.  In the meantime, let me know if you have questions, comments or concerns.   My phone number is 271-5453 or you can email  

Best regards, Leslie

Leslie A. Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Saturday, April 7, 2012

Kodiak Airport EIS Deadlines, etc Update 31 March 2012

We are fast approaching some important deadlines for the proposed runway safety area
improvements at Kodiak Airport EIS, the first of which will be publication of a draft
environmental impact statement (EIS). I’ll use this update to let you know our schedule for
the coming months and years. To put the schedule in context, I’ll start with a quick overview
of what goes into an EIS and our status within that process. The last paragraph refers to the
law necessitating our analysis of these proposed actions and the statutory commitment for
completing RSA improvements at Kodiak and other airports across the U.S.
The Steps of an EIS
I know that many of you are very familiar with the National Environmental Policy Act (NEPA)
and the procedures established by the Council on Environmental Quality (CEQ) to conform
with NEPA’s purpose, which essentially is to help public officials make informed decisions
with full understanding of possible environmental consequences. The process of meeting
that purpose also helps to make sure appropriate actions are taken to protect, restore, and
enhance the environment.
A mechanism outlined in the CEQ regulations to achieve those goals is preparation of an
EIS. Once a federal agency establishes that an EIS is needed, a notice of intent is published
announcing the decision and soliciting feedback from the public, agencies, tribes, and other
parties. This scoping process helps to define the range of actions, alternatives, and impacts
to be considered in the EIS. After the agency completes its analysis of potential
environmental impacts, the conclusions are published in a Draft EIS and another opportunity
for public is initiated. In a few relatively rare instances a draft is adopted as final, but in most
cases the federal agency will revise at least some aspect of the analysis and publish a Final
EIS that includes responses to comments made on the Draft. After a period of at least 30
days during which the Final EIS is available for public consideration, the federal agency can
make a decision concerning the actions that triggered the EIS. Our website for the project
includes a simple diagram of the main elements of an EIS and opportunities for public
involvement during that process (
Where is Kodiak Airport EIS in this Process?
On February 15, 2007, the Federal Aviation Administration (FAA) published a notice of intent
to prepare an EIS that would assess the impacts resulting from improvements to runway
safety areas (RSA) on two runways (18/36 and 7/25) at Kodiak Airport. During the ensuing
5+ years, FAA and our EIS Consultant Team have compiled information documenting
existing environmental conditions on and around the Airport; put together a range of
alternatives to improve RSAs on two of the Airport runways; and conducted analyses of
possible environmental, cultural, economic and social impacts. A preliminary draft EIS was
prepared and distributed late 2010 to Kodiak-area Tribes and state and federal agencies that
generated substantial discussion and valuable feedback concerning, in particular, the
alternatives being considered, methods of impact analysis, and some of our conclusions.
We’ve also begun to develop the documentation needed for compliance with a variety of
state and federal laws, in the event that a decision is reached to improve RSAs on one or
both of the runways. These efforts are driven in part by two factors. One, our schedule for
completion of the EIS and possible construction of the RSAs is very ambitious (see below).
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So we don’t have the luxury of waiting for an FAA decision to begin, for example, consultation
with National Marine Fisheries Service and U.S. Fish and Wildlife Service concerning
compliance with the Endangered Species Act. Second, FAA believes that consultation
processes are best done concurrent with NEPA analysis. Not only does this help integrate
NEPA with unique requirements of special purpose laws, but it results in more efficient and
streamlined government coordination and decision-making.
What is the Schedule for the Remainder of the EIS?
We are now working to complete a Draft EIS for public and agency review, and I hope to
release it in mid-summer of 2012. FAA will make it available at easily accessible locations in
Kodiak as well as at the FAA and Alaska Department of Transportation & Public Facilities
offices in Anchorage, and on the project website ( Hard copies
and CDs of the Draft EIS will be mailed to agency, tribal and other governmental contacts, as
well as those organizations and individuals who have expressed interest in receiving it.
In addition to opportunities to submit comments via mail and online, at least one public
hearing will also be conducted in Kodiak to receive additional verbal or written public
comments. I and members of my team will work hard to meet with as many people as we can
to explain the contents and conclusions in the Draft EIS, answer questions, and listen to
concerns. Summer can be a busy time for people in Kodiak, so we will extend our normal
public comment period to a full 60 days.
Once the public comment period is over we will begin preparing a Final EIS. Comments on
the Draft EIS can strongly influence the Final EIS and FAA’s ultimate decision concerning the
proposed RSA improvements, so we will carefully consider and respond to all of them. We’ll
make sure that substantive comments are attached to the Final EIS and posted on the project
website. FAA’s goal is to make decisions about RSA projects for Runways 18/36 and 7/25
no later than spring of next year.
What Happens After the Decision?
Construction of the proposed projects would take two to three years. If FAA were to approve
the RSA projects in early 2013 some components of the work could begin the same year, but
a number of factors would influence the construction start time. There are permits,
authorizations, consultations and other actions that would be needed before construction
could begin. Permits may include restrictions of various types that would dictate when
construction could occur and for how long. For instance, stipulations could be imposed to
protect natural resources, such as seasonal prohibitions to protect wildlife species of concern.
The construction work would also be designed to minimize impacts on commercial and
military aircraft operations.
Does the Schedule Above Have to be Met?
Yes! By passage of Public Law 109-115 Congress has directed that, not later than
December 31, 2015, the owner or operator of an airport such as Kodiak’s shall improve the
runway safety areas to comply with applicable FAA design standards. In other words, FAA
does not have the ability or authority to shift the deadline. Considering the approvals and
permits that could be needed, and the extended construction period that may be required to
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complete work on the runway ends, our efforts to complete the EIS and prepare and
complete a Record of Decision necessarily have to be aggressive.
I hope to be seeing some of you in the near future to talk more about the Draft EIS analysis,
and some of the consultation needs to comply with special purpose laws such as the
Endangered Species Act, Marine Mammal Protection Act, ANILCA and so forth. In the
meantime, let me know if you have questions, comments or concerns. My phone number is
271-5453 or you can email
Leslie Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Friday, April 6, 2012

Kodiak Airport EIS Project Update Message – February 2012

Kodiak Airport EIS Project Update Message – February 2012
You’ll recall from the update I sent in January that a runway safety area (RSA) is an area
surrounding the runway that reduces the risk of damage to an aircraft if it deviates from the
runway. The size of a RSA typically depends on the largest and heaviest aircraft regularly
operating on that runway. Two of the runways at Kodiak Airport, 18/36 and 07/25, do not
meet RSA design standards for those aircraft. The traditional runway safety area consists of
graded areas at the runway ends and along the sides of the runway to offer aircraft protection
in the event of an overrun or veeroff during takeoff or landing. To meet the FAA’s
dimensional standards for RSAs at Kodiak Airport, sufficient fill would have to be placed at
the north (toward the Buskin River) and south (into Womens Bay) ends of Runway 18/36 and
the east end of Runway 7/25 (into Chiniak Bay) to create a graded surface that measures
500 feet wide by 1,000 feet long.
FAA is considering alternatives for Kodiak Airport that could lessen environmental impacts
caused by the fill and large disturbance areas associated with a conventional RSA
construction on the runway ends. One option is the use of Engineered Materials Arresting
System, or EMAS. The Preliminary Draft EIS distributed to agencies and tribes late in 2010
included one alternative incorporating EMAS. Engineering and operational analysis since
that time confirms that it may be a feasible technology for both runways, and I expect the
Draft EIS will consider alternatives incorporating EMAS on the north, south, and east runways
ends. I’ll use this update to provide some explanation of how EMAS works, where it has
been used, and some of the benefits and potential drawbacks of this technology.
What is EMAS?
A conventional runway safety area provides a substantial additional amount of land for an
aircraft to slow down and stop; for runways 18/36 and 7/25 at Kodiak Airport, the requirement
would be 1,000 feet beyond the runway ends. However, at many airports it may not be
practicable to build enough safety area at the runway ends to meet FAA standards. Existing
roads or railroads, natural features such as water bodies and large terrain changes, or
environmentally sensitive areas are among the reasons why it may not be prudent to
construct a conventional RSA. The FAA began conducting research in the 1990s to come up
with an alternative way to stop aircraft without requiring as much land as a conventional RSA.
Working in concert with the University of Dayton, the Port Authority of New York and New
Jersey, and the Engineered Arresting Systems Corporation (ESCO) of Logan Township, NJ,
a new technology, EMAS, emerged to safely arrest overrunning aircraft.
EMAS consists of a number of pre-cast, crushable, and energy-absorbing cellular cement
blocks installed at the end of a runway. The material in these blocks may be thought of as
something similar to pumice, a type of very light volcanic rock with lots of holes and
airspaces. An aircraft that hasn’t stopped by the runway end encounters “lead-in” blocks that
begin to crush under the movement and force of the wheels. The material in the EMAS is
designed to slow an aircraft by increasing the resistance, or friction, of the wheels as the
material gets crushed. The landing gear of the aircraft sinks into the “pumice-like” material
and the aircraft slows down as it gets further into the EMAS. How quickly the EMAS slows an
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aircraft is dependent on a number of factors including the weight of the aircraft and entry
speed, landing gear configuration, and even tire pressure.
Nice Theory, but does EMAS Really Work?
Currently, EMAS is installed at 63 runway ends at 42 airports in the United States, and on
five more runway ends at three airports outside the U.S. By the end of 2011, there had been
eight incidents where EMAS safely stopped overrunning aircraft carrying a total of 235 crew
and passengers, including incidents at JFK Airport in Queens, New York; Key West Airport in
Florida; and Downtown Greenville Airport, South Carolina. Obviously, EMAS can help
protect human health and safety, and it has worked with relatively little damage to the aircraft.
But it is also important to remember that EMAS really represents a component of runway
safety area that was used because of physical or environmental constraints unique to a
particular runway. A successful aircraft arrest by EMAS illustrates the value of FAA’s runway
safety area program, and there are many similar examples where conventional RSA has
provided the additional land needed for an aircraft carrying crew and passengers to come to
a complete stop, with little damage. If you are interested in more information about incidents
involving EMAS or locations where it has been installed, you might consider looking at FAAs
most recent fact sheet at
Could EMAS be Used at Kodiak Airport?
FAA has determined that a properly designed EMAS will provide a level of overrun safety
generally equivalent to a standard runway safety area. And, as we know from the past 10+
years of experience, the technology works. Typically, FAA and Airport Sponsors (the owners
and operators of airports) consider installing EMAS on runway ends where space is limited
and a standard RSA is not feasible. EMAS may also deserve consideration in other
situations, even where standard runway safety area is considered practicable. For example,
because EMAS requires a smaller disturbance footprint than conventional RSA, its use could
lessen damage to sensitive environmental resources beyond runway ends. Some of these
reasons apply to Kodiak Airport.
A conventional RSA for Runways 18/36 and 7/25 would be 500 feet wide and extend 1,000
feet from the runway ends. To provide an equivalent level of safety at Kodiak Airport, an
EMAS would have to be capable of stopping a Boeing 737-400 (the “design” aircraft) that is
still traveling at a speed of 70-knots when it exits the runway. The EMAS required to achieve
this performance would be about 340 feet long and 170 feet wide. However, for runways like
Kodiak’s that have instrument approaches or visual guidance lighting, there must still be at
least 600 feet of RSA to protect aircraft landing short of the runway. To meet all of these
requirements, the final design would consist of 260 feet of conventional, graded RSA
immediately after the runway end, followed by 340 feet of EMAS for a total RSA length of 600
feet. Although the EMAS itself would only be about 170-feet wide (slightly wider than the
runway) it would be surrounded by traditional RSA out to the standard 500-foot width. The
net footprint for a RSA incorporating EMAS that meets FAA standards for the design aircraft
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would therefore be 600 feet long by 500 feet wide. (If that is all a little confusing, don’t worry,
we are developing figures for the Draft EIS that should be easy to follow!)
Other Important Considerations for Kodiak
Although EMAS may have appeal for some applications, it also has some potential
drawbacks. EMAS can be more expensive to construct and maintain than a traditional RSA.
Each EMAS is designed according to the specific needs of the airport and runway at which it
will be installed. The cellular concrete blocks, coatings, and other materials all have to be
shipped to the airport from the manufacturing facility in New Jersey. Further, EMAS will have
a limited design life (currently 10 to 20 years) and may have to be replaced, at another
substantial cost. Blocks that are damaged during routine airport functions or as a result of
aircraft arrest would need to be manufactured and replaced.
EMAS also has maintenance and care requirements that don’t apply to a conventional RSA.
For example, special equipment designed for use on EMAS is needed to drive on the
arresting bed, or to clear snow without fear of damaging individual blocks or system integrity.
A system of sealants, coatings, and outer layers protect the cellular concrete from
environmental conditions such as rain and ultraviolet radiation. Older versions of EMAS
needed periodic re-painting, although the manufacturer asserts that the improved plastic seal
coating for newer models should eliminate the need for painting and sealing.
An issue we have discussed with respect to Alaska airports concerns the practicality of using
EMAS in more challenging climates or environmental settings. Kodiak Airport exhibits some
of these factors including cold temperatures, frequent freeze/thaw cycles and a relatively wet
environment, especially at the runway ends exposed to waves and salt spray. In particular,
FAA Order 5200.9 acknowledges that local climate conditions consisting of “extreme cold
location with high flooding potential might limit the effectiveness and/or durability of an EMAS
installation.” Runways at Kodiak Airport, particularly runway end 25, can be exposed to high
waves that wash onto land. The strong energy behind wave action can carry rocks and other
materials that could damage the surface. A common concern for coastal airports has been
that salt water could have an especially corrosive effect on materials, coatings and sealants.
FAA and Airport Sponsors, among others, had also been uncertain as to how EMAS would
perform in locations with extremely cold temperatures, prompting research funding to the
Corps of Engineers Cold Regions Research and Engineering Laboratory to assess the
durability of EMAS in cold climates.
ESCO has responded to concerns about the resilience and durability of earlier EMAS
versions by developing the so-called 3rd generation product, known as “EMASMAX.”
According to the manufacturer, this version improves on earlier systems with better protection
against moisture penetration and jet blast protection, among other enhancements.
Regardless of specific climactic or environmental conditions, it is clear that frequent
inspection and regular maintenance are important factors to a viable, long-lasting EMAS.
(For the purpose of this update, “EMAS” refers to any version of the arresting system.)
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EMAS is currently being used at one location in Alaska, installed on Runway end 27 at
Cordova in 2007. As you know, Cordova has experienced a particularly difficult winter, with
heavy precipitation. At this time, we don’t know if or how the extreme weather and
tremendous snow loads have affected integrity of the Cordova EMAS. I know ADOT&PF, the
Cordova Airport “Sponsor”, is particularly keen to find out if there have been problems. I’ll let
you know when more information with this local-to-Alaska EMAS application becomes
One interesting question, certainly applicable to Kodiak Airport and raised during our
meetings in November 2011, concerns the ability of EMAS to withstand a ground-shaking
event. Put another way, what magnitude of seismic event (i.e., earthquake) could an EMAS
handle – in terms of materials integrity, seam adhesion, sealant durability and so forth –
without requiring repair or replacement? I’m not aware of any testing has been conducted to
specifically answer this question. In practice, immediately following an earthquake a Sponsor
would quickly inspect all airport facilities to determine if they are in acceptable condition to
resume service. However, damage to an RSA, or an EMAS installed as part of the safety
area, should not prevent normal aviation operations from resuming, although it would then be
important to replace any damaged components of the EMAS as soon as possible after an
In fact, this scenario is very much similar to the sequence of events after an aircraft overrun
into EMAS. An aircraft arrested in EMAS would be removed from the airfield as soon as
possible after immediate response activities have concluded; typically, this happens within a
couple of days or even hours after the accident. At that point, FAA will issue an official notice
to airman of the change in conditions at the airport, but service on the applicable runway
returns to normal relatively quickly.
EMAS represents a safety technology for aircraft overruns that can be comparable to
traditional, grade and fill runway safety area. The potential benefits of EMAS, particularly by
lessening adverse impacts on marine habitat and wildlife, have led FAA to conclude it should
be a component of some RSA alternatives to be evaluated in the EIS. We will work hard to
make sure the EIS provides a reasoned analysis of the benefits and drawbacks associated
with installation and care of an EMAS at Kodiak Airport.
Thanks so much for your interest in the project. I hope these updates are informative, but
don’t hesitate to let me know if you have questions, comments or concerns. My phone
number is 271-5453 or you can email
Leslie Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Monday, January 30, 2012

30 January 2012: Runway Safety Areas Explanation

Hello Again!
In December I sent out an update that provided some answers to questions
raised during our November meetings, with a focus on the Kodiak Airport
runways: their dimensions and orientation, and how often they are used by
the different aircraft types, including commercial jets, turboprops, and
Coast Guard planes.  This update builds on that earlier message by making
the connection between runway use – particularly the type of aircraft
regularly using a runway – and the applicable runway safety area (RSA)
standards. I will also compare the standard RSA dimensions with what
currently exists at Kodiak Airport.
What is a Runway Safety Area?
In the Advisory Circular Airport Design (#150-5300-13; 1989), FAA has
described the RSA as
      “A defined surface surrounding the runway prepared or suitable for
      reducing the risk of damage to airplanes in the event of an
      undershoot, overshoot, or excursion from the runway.”
I’ll supplement that description a little.  By “defined” we mean the RSA
has published dimensions of width, as measured from the runway centerline
to both sides, and length, or the distance of safety area beyond the runway
end.  (We usually give these dimensions in feet).  So, not only is there
RSA at the runway ends, designed to offer aircraft undershoot or overshoot
protection, but it also is found parallel to and along the sides of the
runway.  This lateral safety area provides protection in case an aircraft
veers off during landing or takeoff.  Our analysis of Kodiak Airport RSAs
tends to focus on the runway ends, but each of the alternatives for Runway
18/36 also includes improvement to lateral safety area on the east side of
the runway near the Runway 36 end.  The attached, simple schematic from the
Airport Design Advisory Circular should help to illustrate the concept.
A way to establish that an RSA is “prepared or suitable for reducing the
risk of damage…” is by requiring it to be capable, under normal (dry)
conditions, of supporting aircraft that deviate from the runway without
causing structural damage to the aircraft or injury to its occupants.  RSAs
make airports and flying safer, and reduce the potential for an aircraft to
be damaged if a landing or takeoff has problems.  RSAs also make it easier
to get firefighting and rescue personnel and equipment to the scene of the
accident if an aircraft does deviate from the runway.
How are RSA Dimensions Determined?
The minimum size for a particular RSA (known as the Design Standard) can
vary depending on the type of aircraft expected to use the runway.
Generally speaking, the largest and heaviest aircraft regularly operating
on a runway dictates the RSA size.  At Kodiak Airport this aircraft is the
Boeing 737-400, operated by Alaska Airlines.  The Boeing 737-400 falls
within wingspan category Group III, which is based on primarily on an
aircraft’s wingspan and tail height,  and approach category of C, a
classification based on an aircraft’s speed when approaching a runway for
landing.  (In case you were wondering, all of the B737-series aircraft
using or potentially using Kodiak Airport, such as the B737-200 or newer
-700/800/900 series, fall within the same design categories and would
require the same RSA dimensions.)
What are the RSA Standards for Kodiak Airport Runways?
The RSA design standards for the Boeing 737-400 are
      Q 600 feet of approach (i.e., undershoot) protection on each end,
      Q 1,000 feet of overrun protection on each end, and
      Q 250 feet of lateral protection on either side of the runway
         centerline, for the length of the runway.  This equates to a
         500-foot wide lateral RSA.
Since most runways support arrivals and departures in each direction, the
600 feet of approach protection is incorporated in the 1,000 feet of
overrun protection.  The net result, for a runway regularly serviced by the
B737-400, is a 500-foot wide rectangular area centered upon the runway and
extending 1,000 feet beyond each runway end.
The description above is for what we might term a “traditional” runway
safety area.  Another option that requires a smaller footprint and still
complies with FAA’s design standards is to use Engineered Materials
Arresting System (EMAS).   I’ll have more information on EMAS in another
project update.
While RSA design standards are based on the largest and heaviest aircraft
regularly operating on a runway, smaller aircraft use the Kodiak Airport
and do not require the same RSA areas.  The Dash-8, flown by Era Aviation
several times a day into the airport, is also a group III category aircraft
based on wingspan, but it falls into approach category A because it has a
slower approach speed for landings.  Accordingly, the RSA design standard
for the Dash 8 is smaller than for the 737 aircraft:  300 ft wide by 600
long.  As I discussed in the last project update, both the Dash-8 and the
B737-400 regularly use Runways 07/25 and 18/36.  However, the required RSA
dimensions for those runways are based upon the design standard for the
larger aircraft, the B737-400.
Why is FAA Considering Expansion of the Kodiak Airport RSAs?
Public Law 109-115 states that not later than December 31, 2015, the owner
or operator of an airport certificated under 49 U.S.C. 44706 (such as the
Kodiak Airport) shall improve the airport's runway safety areas to comply
with the FAA design standards required by 14 Code of Federal Regulations
Part 139.  In other words, the RSAs at Kodiak Airport must meet the FAA’s
design standards, contained in FAA Advisory Circular 150/5300-13, by the
end of 2015.  The following information describes the extent of RSA
shortcoming on the runways ends at Kodiak Airport.
      Runway 07/25, the (almost) east-west runways
      Q Runway 07  Landings on this runway are from the west and
         departures are toward the east.  Although the RSA undershoot
         protection on Runway 7 meets FAA standards, the proximity of
         Barometer Mountain precludes virtually any landings by larger
         commercial aircraft.  Overrun standards are not met as there is no
         RSA on the east runway end.
      Q Runway 25  This runway is the opposite of Runway 07; landings are
         from the east and departures would be toward the west.  There is
         no RSA to provide undershoot protection for aircraft approaching
         over the water from the east, nor is there RSA on the west runway
         end to provide overrun protection.
      Runway 18/36, the north-south runways
      Q Runway 18  Aircraft approach this runway for landings from the
         north, over the Buskin River estuary, and take off to the south.
         There is no RSA on the north runway end to provide undershoot
         protection, nor is there RSA on the south end of the runway,
         toward the Coast Guard station, for overrun protection.
      Q Runway 36  Since this runway is oriented 180 degrees from Runway
         18, the directions of operation are reversed.  Aircraft approach
         Runway 36 from the south and depart to the north.  As with Runway
         18, there is no RSA on either runway end for overrun or undershoot
      Runway 11/29   These runways accommodate operations from and to the
      southeast, marine end of the runway or the northwest, interior of
      Kodiak Island. The runway safety area in place around Runway 11/29 is
      300 feet wide for the length of the runway and extends 600 feet
      beyond the ends of the runway.  This RSA meets the design standards
      for smaller commercial and larger general aviation aircraft, and no
      further improvement is required.
Federal law requires that RSAs at airports such as Kodiak comply with FAA
design standards.  Further, the owner or operator of such airports –
ADOT&PF is the operator at Kodiak – must meet those standards not later
than December 31, 2015.  Two of the runways at Kodiak Airport, 18/36 and
07/25, do not meet design standards for the largest aircraft regularly
using those runways.  FAA has initiated an environmental impact statement
to evaluate the effects of improving those RSAs.
I hope this information is useful.  Thanks again for continuing to stay
involved in this project.  Please don’t hesitate to call (271-5453) or
write ( if you have questions, comments or concerns.
Regards,  Leslie
(See attached file: RSA Schematic.pdf)
Leslie A. Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Sunday, January 22, 2012

Kodiak Botanist Comments on FAA Rare Plant Survey Species Report

Stacy Studebaker, noted Kodiak botanist and author of Wildflowers and Other Plant Life of the Kodiak Archipelago, submitted the following comments to the FAA concerning the Rare Plant Survey Species Report.  As you will read, the report has major problems.

Dear Leslie,

Thank you for sending me the Rare Plant Survey Species Report.  I have read it over and have the following comments:

1)  The first aerial photo on page 6 does not specify the location within the study area. Buskin River?

2)  The photo of the sessile-leaf scurvy grass on page 4, figure 1, shows the plants mostly in fruit and not in flower even though it as labeled as being in flower.

3)  The photo on page 5, figure 2 is labeled "sessile-leaf scurvy grass and oriental popcorn flower in Woman's Bay".
     I don't see either species in this photo but instead, Spergularia canadensis (Canadian Scurvygrass) is poking up out of the shallow water.
     This is a common intertidal species within the study area but it is not listed on the species list on Table 1, page 3.

4)  Plagiobothrys is misspelled throughout the report as Plagiobothryus.

5)  This report appears to have been quickly put together. Given the misidentified plants in the photo on page 5, the accuracy of their findings in Woman's Bay is questionable. Did they really find Cochlearia sessilifolia and Plagiobothrys orientalis there? There is no photo documentation of Plagiobothrys in the report to show that they actually found it or correctly identified it.

With this report, what kind of "management" decisions can be made? The authors really did not add anything to the information that Carolyn Parker and I already supplied. There is nothing in the report that says that these rare plants would or would not be impacted by the various alternatives in the PDEIS.

Stacy Studebaker

Wednesday, January 18, 2012

UPDATE 18 January 2012

We have completed the Alaska Rare Plant Species Survey Report in support of
the analysis being done for the Kodiak Airport Environmental Impact
Statement.  This work adds to previous findings concerning the presence of
sensitive plant species in the Buskin River drainage just north of the
airport.  The report documents the results of the plant surveys conducted
by FAA's consultants last August, not only in the Buskin River estuary, but
also in estuarine habitats of drainages entering Women's Bay.
The report has been posted on the project website at  If you have any
questions about the report or other aspects of the EIS, please don’t
hesitate to e-mail or call me at 271-5453.  Leslie
Leslie A. Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division

Wednesday, December 21, 2011

UPDATE: 21 December 2011

Happy Holidays!
Recent Kodiak Airport EIS project updates have been used to alert you to
meetings or let you know what progress has been made since previous
communications.  I think we are now sufficiently advanced with our project
planning and alternatives development to start using these updates to
provide more in-depth information, especially concerning topics or issues
of widespread interest.  We have plenty of material with which to work, but
don’t hesitate to let me know if you have suggestions for future updates.
FAA fielded a number of questions concerning runway use during our Runway
Safety Area EIS meetings in November.  For example, while most people are
generally aware of the types of aircraft flying in and out of that airport,
especially the commercial aircraft, there was widespread interest in
learning which runways are the busiest and why.  This project update should
answer some of those questions.
Let me start by reviewing runway characteristics and some of the key
factors influencing runway use at Kodiak Airport.  I’ve attached a figure
that will help you to follow the different runway references.
As you know, Kodiak has three runways.
   Runway 07/25 is the longest runway at 7,542 feet and is the most often
   used, especially for commercial and military aircraft. This is the
   runway used when landing from, or taking off to, the east.
   Runway 18/36 is 5,013 feet long and used by both commercial and military
   aircraft.  Even though Runway 18/36 is shorter than Runway 11/29, the
   north-south alignment and generally favorable terrain beyond the runway
   ends allow it to be used by larger aircraft.
   Runway 11/29 is 5,399 feet in total length and, because of the
   mountainous terrain inland of this runway, is normally used only by
   smaller general aviation aircraft.  FAA is not considering expansion of
   the Runway 11/29 Runway Safety Areas because they already meet standards
   for the smaller general aviation aircraft that are the primary users of
   that runway.  Larger aircraft do use this runway, but not often enough
   to warrant development of larger safety areas.
Runway length is certainly a factor in the process of deciding which runway
to use for an operation (i.e. a takeoff or landing), but not the only one.
Terrain is an important consideration relative to Kodiak Airport; for
example, Barometer Mountain limits approaches from, or departures to, the
west on Runway 07/25.
Aircraft characteristics are also a key factor in runway use.  Generally
speaking, the larger (in terms of weight and wing-span) and faster (in
terms of landing or takeoff speeds) aircraft need more runway.  Finally,
wind direction is a critical element of the decision-making process for
each operation.  It is easier and safer for aircraft to land or takeoff
into the wind.  Other considerations may include the types of navigational
aids for a particular runway, such as landing lights or approach slope
indicators, or the availability of special approach procedures.
So, knowing the runway lengths and something about the other elements that
influence operational decisions, what does the data tell us about runway
utilization at Kodiak Airport?
Air traffic control tower staff estimated that about half of the aircraft
activity takes place on Runway 07/25.  Of the remaining operations, the
north-south Runway 18/36 gets slightly more use (~28% of operations) than
does the northwest-southeast trending Runway 11/29 (~22% of operations).
Again, though, these numbers reflect all fixed-wing aircraft, large or
small, and include military, commercial and general aviation (but not
helicopter operations).
It is equally instructive to consider runway use in terms of the types of
operation and the individual aircraft types. We’ve compiled information
supplied by Alaska Airlines, Era Aviation, and the Coast Guard concerning
the larger aircraft they fly into Kodiak:
   · Alaska Airlines (Boeing 737-400 aircraft):
         o 99% of takeoffs are conducted on Runway 07; 90% of landings are
            conducted on Runway 25.
         o 10% of landings are conducted on Runway 36; less than 1% of
            operations take place on Runway 18, and Runway 11/29.
   · Era Aviation (Dash-8 Turboprop aircraft):
         o 80% of takeoffs are conducted on Runway 07; 75% of landings are
            conducted on Runway 25.
         o Approximately 17% of takeoffs and landings are conducted on
            Runway 36; most of the remainder of their operations (about 5%)
            is on Runway 18.  Rarely, and primarily due to wind conditions,
            the Dash-8 will use Runway 11/29.
   · Coast Guard (C-130 cargo aircraft):
         o Approximately 80% of annual operations take place on Runway
         o Runway 36 is used for about 15% of operations, and Runway 18
            for another 5%.
The data for these three operators can’t be directly compared because of
differences in how each of them estimated runway usage for their own
aircraft.  However, it is obvious that Runway 07/25 not only accommodates
about as many annual operations as the other two runways combined, but more
than ¾ of the “large” aircraft operations take place on it as well. Indeed,
because of its length and a “precision” instrument approach to Runway end
25 for landings from the east, Runway 07/25 is the most used runway at
Kodiak Airport.  Runway 18/36 serves to accommodate aircraft operations
when the winds are not favorable for takeoffs or landings on Runway 07/25.
I hope this information helps explain the differences in runway use at
Kodiak Airport.  We should have other opportunities to answer some of your
questions from the meetings in future updates.  By the way, we’ve loaded
all the previous project updates from 2011 on the website at
Again, thank you for continuing to stay involved in this project.  Please
don’t hesitate to call (271-5453) or write ( if you
have questions, comments or concerns.
Leslie Grey
Environmental Protection Specialist
FAA - Alaskan Region, Airports Division