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