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Airport Environmental Clearance
Pollution Prevention Plans
Spill Prevention Counter Control (SPCC) PlansThe Environmental Protection Agency (EPA) requires facilities that store more than 1,250 gallons of polluting material above ground to develop spill prevention counter control (SPCC) plans. The Michigan Department of Transportation (MDOT), in cooperation with the EPA and FAA, has developed a checklist to assist Michigan airports in determining whether they need a SPCC plan. MDOT recommends each airport complete the checklist and keep it on file. For policies, procedures and additional information go to the EPA website.
Storm Water Pollution Prevention Plans (SWPPPs)
The Michigan Department of Environmental Quality (MDEQ) regulates discharges of storm water from airports that conduct regulated activities such as: vehicle washing/painting/re-fueling; vehicle maintenance activities and/or de-icing activities. Airports that have a point source discharge of storm water from their facility to surface waters of the state (drain, pond, stream, river, etc) and conduct a regulated activity must have a discharge permit from the MDEQ. The discharge permit will require the airport have a certified operator and a Storm Water Pollution Prevention Plan (SWPPP). For MDEQ policies and procedures and additional information link to EGLE.
Integrated Pollution Control Plans
Many Michigan airports are subject to both SWPPP and SPCC plan requirements. A compliance option that may be beneficial is to develop an integrated pollution control plan combining statutorily required elements of both the SPCC and SWPPP in one plan. This may be simpler for the airport to implement but present challenges for updating the manual when regulation changes require updates.
Environmental Clearance ProcessThe National Environmental Policy Act (NEPA) of 1969 established protocol by which agencies are required to evaluate project impacts on the social and natural environment. The Federal Aviation Administration (FAA) has developed NEPA Guidance under Order 5050.4B There are three levels of environmental clearance:
Projects that may be eligible for a categorical exclusion (catex) are listed in tables 6-1 and 6-2 of Order 5050.4B. Michigan Department of Transportation (MDOT), Aeronautics processes catex documents for general aviation (GA) airports. Primary airports are responsible for completing the FAA environmental checklist and providing the information to the Detroit ADO, Catex documents typically take three months to complete.
Environmental Assessment (EA)
The types of projects normally requiring an EA are described in Chapter 7 of Order 5050.4B. MDOT, Aeronautics coordinates EAs on behalf of general aviation airports. GA airports should plan on EAs taking 12 months to complete and plan accordingly. Shorter or longer time frames may apply, contact the MDOT, Aeronautics Environmental Specialist to discuss project specific schedules.
Environmental Impact Statement(EIS)
The types of projects normally requiring an EIS are described in Chapter 9 or Order 5050.4B. The FAA is required to be the lead agency for all EIS documents. EIS documents may take up to three years to complete and are generally significantly more costly than the other types of environmental documentation.
Environmental clearance questions? Contact Steve Houtteman, Aeronautics Environmental Specialist, at 517-335-9866.
Construction Storm Water Permit Guidance
Projects that will disturb more than 5 acres of land the sponsor airport must apply for a Notice of Coverage (NOC) from the Michigan Department of Environmental Quality (MDEQ). There is a $400 fee for this permit. The sponsor must have their Soil Erosion Sedimentation Control (SESC) permit from the county/city before they can get an NOC from MDEQ.
Projects that disturb between 1 and 5 acres of land are statutorily subject to the NOC requirements, but there is not an application requirement. Sponsors have implied NOC authorization when they receive the SESC permit. However, sponsors still have to comply with all NOC requirements (weekly inspections and inspections after a rain event by a certified operator).
Projects that disturb less than 1 acre do not need a NOC. These projects are only subject to the SESC requirements.