Everything you would need to know about the practice of National Environmental Policy Act (1969) environmental review as implemented by the U. S. Department of Housing and Urban Development in United Sates Code 24, Part 58 and associated laws and statutes. Every project federally permitted or funded in whole or in part, with certain exceptions for defense related activities, must undergo this practice of determining effects of a proposed project on and from the human and natural environment. The resulting analysis and characterization intends to inform decision makers while a proposed project is still in the planning stages. The goal is to optimize a proposal to maximize envrionmental goods and minimize environmental harms both to and from the project before any irreversable action is taken.
Sometimes called the discipline of Environmental Planning, the process suffers from a sectioned view of the environment, made necessary by the disparate laws and scientific disciplines that contribute knowledge to an assessment of project-based environmental effects. Another weakness is its treatment as a paperwork exercise late in a proposal's development, which often foregoes the very benefits that such planning undertaken early enough can afford. Finally, it suffers a lack of public participation, arising from the notion that this is best left in the hands of experts. However, decision makers can be left feeling as helpless as the public distinguishing between imperitives and luxuries in tradeoffs among definite social, economic, and environmental impacts of their actions. Decision makers generally benefit from an all-hands approach in a democratic nation of a great many people so blessed with education, qualifications, and hard-won experience.
Please feel free to ask questions or make suggestions about this presentation at any time and for any reason.
So without further ado follows HUD environmental review...
2. “Ultimately, of course, it is not better documents but
better decisions that count. NEPA’s purpose is not to
generate paperwork – even excellent paperwork –
but to foster excellent action. The NEPA process is
intended to help public officials make decisions that
are based on understanding of environmental
consequences, and take actions that protect, restore,
and enhance the [Human and Built] environment.”
CEQ Regulations
2
5. Goals for the Course
When is an ER required?
What is the process?
What is qualified documentation?
What is the timing?
How can the ER process be
expedited?
5
13. NEPA
Environmental Study
• Agency Comments
• Public Document
13
14. NEPA
Environmental Study
• Agency Comments
• Public Document
Scientific Analysis
Relevant Issues
14
15. NEPA
Established the CEQ
• Exec. Office of the President
• CEQ Regs 42 CFR 1500
• Agency Regs Consistent
w/NEPA
• Oversees Federal Agencies ERs
• Cooperating Agreements
15
16. HUD Regulations
24 CFR Part 58 Procedure for
REs
24 CFR Part 51 Hazards
24 CFR Part 55 Floodplains
24 CFR Part 50 HUD Procedure
16
18. Who’s Responsible? --58.4
Grant to a Unit of
Local Government
Must assume Part 58 for:
• Formula Grants
• Neighborhood
Stabilization Grant is a
formula grant
18
19. Who’s Responsible? --58.4
State Funds
Grants to LG
• LG Responsible
• RROFs to State
Grants to Others
• State Responsible
• RROF to HUD
19
29. Overview
Steps In the Process:
--Alternatives
The preferred alternative may be the
program as proposed, a modification of
the program as proposed, including
alternative sites or site selection criteria,
or "no action."
29
31. Level of Review
Full Assessment
Categorically
Excluded, Subject to
58.5/6
Categorically
Excluded NOT
Subject to 58.5
Exempt
31
32. Exempt Activities
24 CFR Part 58.34(a)
Environmental, planning & design costs
Information & financial services
Administrative/management activities
Public services (no physical impact)
Inspections
Purchase of tools/insurance
Technical assistance & training
Temporary assist. for imminent threats
Payment of principal and interest on HUD
loan
32
33. Exempt “Level of Review”
24 CFR Part 58.34
Document determination in
writing
Document compliance with
58.6
SIGN and DATE
No RROF or further
approval from HUD or the
State is required
33
34. Categorically Excluded Activities not
subject to 58.5
at 24 CFR Part 58.35(b)
Tenant-based Rental Assistance
Supportive Services (Hsg. Counseling)
Operating Costs (maintenance,
supplies)
ED Costs (non-construction)
Down-payment Assistance on Existing
Pre-development Costs
Supplemental Assistance (NEW to Regs)
34
35. Categorically Excluded
Not subject to 58.5
SAME AS EXEMPT:
Document determination in writing
Document compliance with 58.6
SIGN and DATE
No RROF or further approval from HUD
or the State required
35
36. Categorically Excluded
subject to 58.5
24 CFR Part 58.35(a)(1)
Public Facilities:
• Acquisition
• Repair
• Reconstruction
• Improvement
If Facility in place
20% or less change in size or capacity
36
37. Categorically Excluded
subject to 58.5
24 CFR Part 58.35(a)(2)
Special Projects for removal of:
• Material
• Architectural Barriers
That restrict mobility and
accessibility
37
38. Categorically Excluded
subject to 58.5
(24 CFR Part 58.35(a)(3(i))
Rehabilitation of 1 to 4 family Dwellings
• Density is not > 4 units
• Land use is not changed
• The site is not in FP
• The footprint is not expanded
38
39. Categorically Excluded
subject to 58.5
24 CFR Part 58.35(a)(3)(ii)
Rehab of Multifamily
residential when:
• Density is not
changed > 20%
• Does not involve
change in land use
• Cost is < 75% cost of
replacement
39
40. Categorically Excluded
subject to 58.5
24 CFR Part 58.35(a)(3)(iii)
Rehab of Non-
residential when:
• < 20% change
in size and
capacity
• does not change
land use
40
41. Categorically Excluded
subject to 58.5
24 CFR Part 58.34(a)(4)
1. An individual action on a 1-to-4 family
dwelling
2. A project of five or more units
more than 2,000 ft apart
developed on scattered sites
41
42. Categorically Excluded
subject to 58.5
24 CFR Part 58.35(a)(5)
Acquisition or Disposition
Existing Structure or Land IF
Structure will be used for
the same use
Land will be used for the
same use
42
43. Categorically Excluded
Clearance
Complete Statutory Checklist
If Compliance is triggered:
•Publish/Post NOI/RROF
•Wait 7 /10days,
•Send RROF to HUD/State
•HUD Waits 15 days
43
44. Categorically Excluded
Clearance
Complete Statutory Checklist
If Compliance is NOT triggered:
•Project reverts to exempt
•document determination in writing
(58.34(a)(12) and (b))
•place all documentation
in ERR (sign and date)
44
45. Environmental Assessment
Activities
24 CFR 58.36
Project Activities that are:
• Not Categorically Excluded
See Conditions 58.35(a)
• Change in Use
• Major Rehab
• Increase in size or capacity > 20%
• New Const > 4 SF together
Require a FULL ASSESSMENT
45
46. Environmental Assessment
Activities
Greater potential for Impact
Always requires a FONSI and
RROF
Determines if EIS is required
Requires study of alternatives
46
47. Environmental Assessment
Requires NEPA study
• Includes the Laws and
Authorities at 58.5 and 6
Studies:
• Human Environment
• Built Environment
47
48. Environmental Assessment
Clearance
Complete EA Checklist
Make Finding
Publish/Post Combined Notice
Wait 15/18 days
RROF and certifications to HUD)
HUD waits 15 days
48
49. Environmental Impact Statement
“EIS” 24 CFR Part 58.37
Completed for:
Controversial Projects
Findings of Significant Impacts (FOSI)
Large projects (2,500 or more units)
49
50. Overview of Public
Notification
EA: Combined Notice (FONSI and NOI)
CE that “trigger” compliance: NOI/RROF
only
CE No Compliance Triggered None
CE Not Subject to 58.5 : None
Exempt: None
50
51. Public Comment Periods
24 CFR part 58.45
NOI/FONSI - 15 days from
Publication or 18 days from Posting
NOI - 7 days from Publication or
10 days from Posting
RE must consider comments prior
to submitting its RROF to HUD
51
52. Local Period - Objections
FONSI
NO
RROF
Basis for Objections:
• ANYTHING!!!
52
53. Request for Release of Funds
Certification Indicates:
•ER Complete
•Notice Published
•Local Comment
•Period Complete
•CO Signs
Subject to False Claims Act
53
54. RROF Submission
Requirements
24 CFR Part 58.71
Signed 7015.15 from CO
Copy of Public Notice
Submit to local HUD
54
55. Objections to HUD
24 CFR Part 58.75
Basis for Objections :
• 7015.15 not signed by CO
• FONSI not written
• Omitted Steps (at subpart E)
• Committed funds prior to RROF
• Another Federal agency objects
55
56. Environmental Review Record
24 CFR Part 58.38
Project Description - Scope
Determination of Level of Review
Completed review form - as required
Documentation attached
FONSI and RROF Information
Comments and Responses/Analysis
HUD Removal of Grant Condition
Revisions/changes to original review
56
57. Limitations on Activities
Pending Clearance
24 CFR Part 58.22
Funds are committed when:
A legally binding, irrevocable, contract
is signed
57
58. Limitations on Activities
Pending Clearance
24 CFR Part 58.22
Conditional Commitment
• Subject to the ER
• Legally Binding Document
• Must prevent commitment by 3rd
party
58
59. Limitations on Activities
Pending Clearance
24 CFR Part 58.22
Upon receipt of application/proposal for
funding the RE must provide notice to
third party:
24 CFR Part 58.22(a)and(c)
Third party cannot commit HUD funds
or any other funds
Third party cannot take any choice
limiting action
59
60. Limitations on Activities Pending
Clearance
24 CFR Part 58.22 (d)
Options to purchase property are allowed
prior to receiving ATUGF if:
• Cost is nominal
• Site can be rejected based on
environmental finding
60
61. Tiering
24 CFR Part 58.15
The Tiering process allows:
• The ER to be conducted in 2 stages:
The Broad review
The Site Specific review
• Allows RROF for the project
Multi-year
Multi-site
61
62. Tiering
24 CFR Part 58.15
Requires:
• Broad review with documentation
• Written strategy
• Site specific compliance
Must maintain entire record
62
63. Steps for Tiering an ER
24 CFR part 58.15
Define Scope of PROJECT:
• Include all activities anticipated
• Aggregate geographically or
functionally
Conduct the Environmental Review
Develop a WRITTEN strategy
Develop an Site Specific Checklist
Publish/Post a Public Notice for Project
Receive ATUGF from HUD
Conduct a SITE SPECIFIC REVIEW
Sign, date, place in ERR
Commit funds for the Site
63
68. National Historic Preservation
Act (16 U.S.C. 470 et. seq.)
GOALS:
Establish broad agency responsibilities to
protect & preserve historic properties
(Section 110)
Require agencies to consider effects of their
projects on historic properties (Section 106)
68
69. What’s an historic property?
Buildings, objects, districts, sites, or
structures usually 50+ years old; AND
Listed on or eligible for listing on the
National Register of Historic Places
NR Criteria – 36 CFR Part 60.4
69
70. Section 106 of NHPA
REQUIREMENTS:
Take into account the effects of your
project on historic properties
Afford the Advisory Council on Historic
Preservation a reasonable opportunity to
comment
70
71. What triggers 106?
Federal funding, assistance, license,
permit, or approval
Project is defined as an “undertaking”
Project has potential to cause effects to
historic properties
71
72. Is your project exempt from
Section 106?
Refer to §58.34 and § 58.35(b) to see if
your project is exempt or categorically
excluded not subject to…
• If so, then under 106, you may make
the unilateral decision that the project
has “no potential to cause effects”
Does an existing Programmatic Agreement
exempt your activity?
72
73. The Regulation
36 CFR Part 800, “Protection of Historic
Properties”
Establishes a 4-step compliance process
Mandates consultation, not preservation
Agency is the decision-maker
73
74. The 4-Step 106 Process
1. Initiate consultation
2. Identify and evaluate historic properties
3. Assess effects
4. Resolve adverse effects
74
75. 1. Initiate Consultation
Is the project an undertaking?
Is it exempt or CENST?
• §58.34 or §58.35(b)
• Programmatic Agreement
Which SHPO/THPO do you contact?
What other stakeholders should be
contacted?
How will you involve the public?
75
76. 2. Identify historic properties
Define “area of potential effect”
Gather existing information from
knowledgeable sources
Contact stakeholders for any new info
Evaluate NR eligibility
Submit finding of “no historic properties
affected” or move to next step
• Include supporting documentation
76
77. 3. Assess Effects
Apply criteria of adverse effect
• See §800.5(a)(1)
Consult with SHPO/THPO and
stakeholders, the public
Submit finding of “no adverse effect” or
go to next step
• Include supporting documentation
77
78. 4. Resolve Adverse Effects
Notify ACHP of adverse effect
Continue consultation with stakeholders
Involve the public
Consider ways to avoid or minimize
effects by modifying the project
Negotiate mitigation to offset adverse
effects
Execute Memorandum of Agreement
78
79. Expediting & Streamlining
Section 106
Use §800.3(g) when appropriate
• Combine findings into 1 submission to
SHPO and stakeholders
Use a Programmatic Agreement (§800.14(b))
• Tailors compliance to meet needs of your
program/activities
• Reduces SHPO review time
• Allows you to make decisions without SHPO
79
82. Floodplain Management
EO 11988 & 24 CFR Part 55
Goal: AVOID development in Floodplain
• Unless there is No Alternative
• Requires 8 Step Process (Part
55.20)
• Written analysis
• 2 Public notices
• Comment 15 and 7 days
82
83. Floodplain
24 CFR Part 55.12
Exceptions:
Acquisition of existing 1 to 4 family
dwellings
Minor repairs to 1 to 4 family dwellings
Incidental portion in FP (conditions)
Projects with LOMA or LOMR
Avoid the FP – reject the site
83
84. Floodplain
24 CFR Part 55
Is the building or construction
in the 100 yr Floodplain?
• If Yes,
compliance time increased
costs are increased
flood insurance required:
Grant: Economic life
Loan: Life of loan
84
85. The 8-Step Process
What are the Steps:
1. Is the site in the FP/WL?
2. Early Public Notice
3. Evaluate Alternatives
4. Identify Impacts
5. Minimize Impacts
6. Reevaluate Alternatives
7. Publish Final Notice
8. Proceed and Mitigate
85
86. Streamlining Floodplain
24 CFR Part 55.25
Area-wide Compliance:
Invite agencies with knowledge
to participate - scoping
Requires development and
publication of strategy (2 notices)
Determines mitigation for actions
Expires in 10 years
86
87. Wetlands – EO 11990
24 CFR Part 58.5(B)(2)
Goal: Avoid Development
in Wetland
Water
Marks
87
88. Wetlands - EO 11990
Exceptions:
Rehabilitation
Acquisition of Existing
Other projects without soil
disturbance
Wetland on site but avoided
88
95. HUD Noise Standards
24 CFR Part 51 (b)
Exceptions:
Acquisition of existing structures
without rehab
Uses that are not noise sensitive
95
96. HUD’s Noise Standards
24 CFR Part 51(b)
Acceptable: Less than 65 DNL
Normally Unacceptable: 65 -75 DNL
Unacceptable: greater than 75 DNL
Determined by exterior noise levels
Interior Goal is 45 DNL
96
97. HUD Noise Standards
24 CFR Part 51 (b)
When is the calculation required?
Is the site:
1000 feet from highway
3,000 feet from a Railroad
15 miles from a civil airport or military
airport
97
99. Above Ground Storage Tanks
24 CFR Part 51 (C)
Exceptions:
Acquisition of existing single family
homes, multifamily developments,
other structures
Rehabilitation with out expansion
Because the number of persons
exposed to is not increased
99
100. Above Ground Storage Tanks
24 CFR Part 51 (C)
Exceptions:
High Pressure Mobile tanks en route
Pipelines
Natural gas holders
Underground With Floating Tops
Storage Tanks
100
101. Above Ground Storage Tanks
24 CFR Part 51 (C)
Collect the following Information:
1. size of the tank
2. contents
3. liquid or gas
4. pressurized/ not under pressure
5. distance from project site
6. Is the tank diked or undiked?
101
102. Above Ground Storage Tanks
24 CFR Part 51 (C)
Use the Chart on Page 51 and 52
of the guide book to calculate the ASD
ASD
Stationery
Distance Above
Ground
HUD Storage Tank
assisted
Project
102
103. Mitigation Options
Bury the assessed tank
Move the building outside
the ASD
(exterior uses must also be
mitigated)
Modify the building design
Choose another site
Design and implement a
barrier
103
104. Airport Clear Zones
24 CFR Part 51 Subpart D
Policy:
To avoid provision of HUD funds for
projects that are occupied or
frequently used by people
Exceptions:
Purchase of existing with notice and
written statement by airport operator
of no planned expansion or buy out
planned for the site
104
105. Airport Clear Zones
Part 51 Subpart D
Prohibits use frequented by people for:
• No New Construction
• No major rehab >75%
• No increase in density
• No purchase of land for development
105
107. Airport Clear Zones
24 CFR Part 51 Subpart D
Is there an airport in 1 mile of the site?
If no, document the file with a map
If yes:
Obtain:
• Civil: “Airport Layout Plan”
• Military: “AICUZ”
To determine:
• Civil: Runway Clear Zone
• Military:
Clearzone and
Accident Potential Zone
107
108. Airport Clear Zones
Part 51 Subpart D
When is an impact review required?
When the project site is located at
the end of a runway:
• civil airport: 2,500 feet
• military airport: 15,000 feet
If Yes,
ER must contain written
determination by airport operator
stating site in or out of Clearzone
108
109. Airport Clear Zones
Part 51 Subpart D
Leasing, purchase or sale in Clear Zone or
APZ
Requires Notice
see HUD website for a copy
Notice
Signature
109
110. Toxics
24 CFR Part 58.5(i)
Must determine site is :
• free of hazards,
contamination
toxic chemicals, gas and
radioactive materials
• that could affect:
health and safety of
occupants, and/or
conflict with use of property
110
111. Toxics
24 CFR Part 58.5(i)
Emphasis on sites with likely
hazards:
• Landfills
• Dumps
• Industrial sites
• Gas stations
• Substations
111
112. Toxics
24 CFR Part 58.5(i)
Very Few Exceptions:
Phase I: Environmental Site Assessment ASTM
standards do not apply to single family but
HUD regulations do apply
However, all HUD funded projects must be free
from hazards that could affect the health and
safety of the residents or conflict with the
intended use of the property
112
113. Toxics
24 CFR Part 58.5(i)(2)
i. Site must be free of hazards
ii. Multifamily or nonresidential must
study previous use
iii. Emphasis on sites with known
hazards
iv. Current techniques by qualified
professionals
113
115. Sole Source Aquifers
24 CFR Part 58.5(d)
Goal:
To preserve
and
conserve the
only
source of
water for a
community.
115
116. Sole Source Aquifers
Exceptions:
Acquisition of
structures with no
change in use
Rehab of existing
structures
States and areas
with out sole source
aquifers
116
117. Sole Source Aquifers
Generally applies
to:
New Construction
Change of use
Acquisition of
vacant land for
development
117
120. Endangered Species Act
Exceptions:
Building acquisition;
Rehabilitation;
Reconstruction w/in existing
footprint;
Demolition;
Other projects w/out soil
disturbance, vegetation removal or
excessive noise.
120
121. Endangered Species Act
Step 1: Consult with USFWS:
• Species known from county
(parish)
• Species known from project
watershed (aquatics)
If no – “No Effect”
121
122. Endangered Species Act
Step 2: Species in community:
• Basic habitat (e.g. forest,
field)
• Staff survey (obvious
habitat absence)
• Professional survey
No habitat – “No Effect”
Habitat, no species – “Not
likely to adversely affect”.
122
123. Endangered Species Act
Likely to Adversely Affect:
Biological Assessment
Biological Opinion:
• Alternatives &
• Measures
123
125. Wild and Scenic Rivers Act
24 CFR Part 58.5(f)
http://www.rivers.gov/
wildriverslist.html
To identify Wild and Scenic
Rivers
125
126. Wild and Scenic Rivers
Exceptions:
Acquisition of existing structures
Rehabilitation of existing structures
126
127. Wild and Scenic Rivers
Applies to designated rivers
Study within 1 mile of site
For:
• new construction
• change of use,
• major rehab and
• acquisition of land
127
128. Laws and Authorities 58.5
Historic Preservation
Floodplain & Wetlands
HUD Env. Standards
Aquifers
Endangered Species
Rivers
Air
128
129. Air Quality
24 CFR Part 58.5(g)
• Is the site in a Non
-attainment Area?
• Local Requirements on
SIP?
• Will Project impact?
129
130. Air Quality
24 CFR Part 58.5(g)
Exceptions:
Actions outside non-attainment
areas
Emission levels below de minmus
level
Rehabilitation activities
Acquisition for continued use
Land banking (required when site
is developed)
130
131. Air Quality
24 CFR Part 58.5(g)
Additional Issues:
Demolition and Rehab
• Comply with EPA and State
Laws (emissions, asbestos &
lead)
Project proximity to other
sources such as:
• Stack emissions
• Roads
131
132. Laws and Authorities 58.5
Historic Preservation
Floodplain & Wetlands
HUD Env. Stadards
Aquifers
Endangered Species
Rivers
Air
Farmlands
132
133. Farmlands Protection Act
24 CFR Part 58.5(h)
Avoid impact to farmlands designated as :
• Prime
• Unique
• State or Local Importance
133
136. Farmlands Protection Act
If outside an urban area:
Consult “Important
Farmland Map”
from NRCS;USDOA
www.nrcs.usda.gov/technical/NRI/maps/meta/m5970.html
136
137. Farmlands Protection Act
If site is indicated on map:
conduct analysis using form
AD1006
• If it meets threshold, contact
NRCS
137
138. Laws and Authorities 58.5
Historic Preservation
Floodplain &
Wetlands
HUD Env. Standards
Aquifers
Endangered Species
Rivers
Air
Farmlands
Coastal Zone 138
139. Coastal Zones
24 CFR Part 58.5(c)
Coastal zone management
Exceptions:
Rehabilitation of
structures
Acquisition of existing
structures
139
140. Coastal Zones
24 CFR Part 58.5(c)
Applies to:
New construction
Conversion of land use
Major Rehabilitation
Acquisition of
undeveloped land
140
141. Coastal Zones
24 CFR Part 58.5(c)
Avoid
If not,
• Increased compliance time
• Obtain letter indicating
project is Consistent with
State Coastal Zone
Management Plan
141
142. Laws and Authorities 58.5
Historic Preservation
Floodplain & Wetlands
Coastal Zone
Aquifers
Endangered Species
Rivers
Air
Farmlands
HUD Env. Standards
Environmental Justice
142
143. Environmental Justice
24 CFR Part 58.5(j)
EO 12898
Addresses:
• Disproportionate impact:
adverse effects on human health
environmental effects
to low income and minority
populations
143
145. Environmental Justice
E.O. 12898
Is there an environmental impact
or condition:
• If yes, does the condition
disproportionately affect:
Low Income
Minority
145
146. Environmental Justice
Applies to:
Disproportionate impact
to low income and
minority for:
Acquisition of existing
housing
Acquisition land for
development
New Construction
146
149. Laws and Authorities 58.6
OTHER
Flood Insurance
Coastal Barrier
Clear Zone
notice
149
150. Flood Insurance
Purchase of Flood
Insurance is
mandatory for
properties
assisted with
HUD funds &
located in the
Special Flood
Hazard Area
(SFHA) 100 year
flood plain
150
151. Flood Insurance
How Much – How long?
Grants:
Life of the property
* Even if title is transferred
Amount of the project cost
Loans:
Life of the Loan
Amount of the Loan
151
152. Flood Insurance
Exceptions
Formula Grants to State
State Owned Property
Loans of < $5,000 repaid in 1 year
Leasing without rehab, acquisition or
improvements
Maintenance – very limited NOT Rehab
• See maintenance memo from you FEO
152
153. Coastal Barriers
Coastal Barrier Resources Act
Prohibits
Federal funding
for projects in
coastal barriers.
Consult DOI Maps
153
154. Coastal Barrier Resources
Designated by:
• US Fish and Wildlife
• Coastal Barrier Maps and FEMA Maps
Administered by:
• NOAA with local CZM Agencies
Covers:
• Gulf of Mexico
• Atlantic
• Great Lakes
154
An environmental determination is required even for exempt activities and documentation with 58.6 is also required but often for exempt activities compliance is not triggered – for example you have to consider if flood insurance is required for administrative costs but administrative costs are not physical so it is not something for which you can buy flood insurance If the local government is providing housing counseling then you would document in writing that housing counseling project is exempt and then consider if 58.6 is applicable -
15
15
The full environmental assessment checklist is recommended to guide you through the review – The NEPA analysis must study conditions on site and the direct and indirect effects of the project – the cumulative effect must also be considered – that means how does your project contribute to impacts from all other approved projects in the community
mitigation
.
This is an example of a military airport. Military airports have Clearzones and accident potential zones. The regulation is more restrictive in the Clearzone. The APZ has Land Use Compatibility Guidelines for APZs developed with guidelines from DOD. The project should be compatible with those guidelines. Civil airports have runway clearzones which are similar to the military the Military clearzone. The clearzone is the area at the end of the runway. This is the location where accidents are most likely to happen. Many cleazones are actually owned by the airport.