Agricultural Operations on Airport Grounds (2022)

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9   Many airports have leased or are considering leasing airport property for agricultural pur- poses. Figure 3 shows crops being grown on airport land in North Dakota. While there may be benefits to implementing such a program, it is important to understand the impacts of this type of land use on airport operations and the regulatory and administrative background asso- ciated with agricultural operations on airport grounds. The survey data, airport interviews, and case example provide a broad overview of airport agricultural land lease programs in the country. This chapter summarizes the findings on the state of practice of these operations at airports. Key Motivations for Initiating Airport Agricultural Land Lease Programs Airports pursue agricultural land lease programs for several reasons that may involve both internal and external considerations. Of the airports surveyed, the most cited motivation was to decrease the cost of maintaining open spaces of land. This was followed closely by the revenue generated from agriculture leases. Inquiring why airports have so much open space revealed that many airports have acquired land to control the external non-aeronautical pressures that may infringe on aeronautical uses or future airport development. A large hub airport said its primary internal motivation to possess the land was to control the property for future development. The land was being farmed already, so it made sense to allow continued agricultural uses and develop leases with existing operators to decrease maintenance costs and generate revenue as secondary motivations. A medium hub airport interviewed stated the airport desired to retain control of the land (1) as part of its wildlife management plan and (2) for future development potential. Revenue generation, although a benefit, was not a primary factor in the decision to implement an agri- cultural land lease. The airports interviewed, supported by broad-based survey results, indicated the most common motivations for having agricultural land uses at airports were • Decreased land maintenance costs (e.g., mowing, noxious weed control, erosion control) • Increased revenue • Control of airport land • Environmental reasons C H A P T E R   3 State of Practice of Agricultural Operations on Airport Grounds Of the airports surveyed, the most cited motivation was to decrease the cost of maintaining open spaces of land. This was followed closely by the revenue generated from agricultural leases.

10 Agricultural Operations on Airport Grounds • Wildlife control • Benefits to community/public demand • Existing use when airport acquired property Benefits of Airport Farmland Lease Programs The survey data, airport interviews, and case example showed that airports of all sizes benefit from agricultural land uses on airport property. Consistent with motivating factors, nearly all airports in the study reported the most commonly stated benefits of decreased land mainte- nance cost and land lease revenue generation. On the surface, it is only logical to have a tenant pay to manage property that would otherwise need to be maintained by airport staff, assuming any risk factors can be effectively managed. However, many other benefits were also reported, including • Land being used for highest and best purpose, • Compatibility with airport operations, • Control of wildlife habitat, • Weed control, • Ability to share resources with farmer, • Aesthetics, • Public demand for land or production of the land, • Erosion control, • Environmental benefits, and • Improvements to airport security. Airports typically own open areas of land acquired for airport development and aircraft safety areas. These large areas can be expensive to maintain, and when looking at the number of potential revenue-generating acres it is understandable airport administration would con- sider alternative uses. While the majority of airports responding to the survey indicated less than 100 acres of airport property were used for agricultural purposes, there were still 13.9% of airports that allowed for over 500 acres to be farmed (Figure 4). For example, if the airport owns over 500 or maybe even 1,000 acres, equipment and personnel time expenses are required just to maintain (mow, brush) the property. The study also exam- ined the revenue side of agricultural land use of this same property. The most common revenue received was between $100 and $200 per acre annually. There were also a number of airports that Source: D. Anderson, Fargo, North Dakota. Figure 3. Crops at Hector International Airport.

State of Practice of Agricultural Operations on Airport Grounds 11   reported much higher per-acre revenues, which may be dependent on factors such as type of crops, soil conditions, anticipated yield, size of parcel, irrigation, area of country, and other variables. One airport reported that airport farming activities benefit the local community by producing lower-cost produce. Types of Crops at Airports Airports have several factors to consider when determining what types of crops, if any, should be allowed on the airport property. Neighboring lands may already support a type of crop and the soil conditions may dictate the ability for certain crops to produce high yields. Other factors may determine that crops on airport property are not in the best interest of airport operations. Although the intent may be good, irrigation and soil challenges may be a detriment. The attempted operation at Alexander Field South Wood County (ISW), Wisconsin, encountered very sandy soils and poor yields, resulting in termination of the farming activi- ties 3 years later. FAA Advisory Circular 150/5200-33C, “Hazardous Wildlife Attractants on or near Airports,” and FAA Advisory Circular 150/5300-13A, “Airport Design,” address potential issues involving wildlife hazards and height restrictions of crops, as discussed in more detail in Chapter 5. Although many airports responding to this study appear to manage these issues well, there are airports that have made the conscious decision not to allow agriculture operations on the property. Industry Highlight #1 – Airport Decision Prohibiting Agricultural Land Lease Dallas Fort Worth International Airport (DFW) Until the late 1990s, DFW leased over 1,500 acres of its undeveloped property for agricul- tural purposes. These lands were used for cattle grazing and grain crops, which alleviated the airport’s maintenance costs (mowing) and also generated revenue. Early in calendar year 1997, elevated bird activity in addition to a multiple bird strike prompted DFW to have a Wildlife Hazard Assessment conducted. While the assessment determined that the bird strike was not directly correlated with the agricultural operations, documentation 13.90% 5.00% 2.50% 7.50% 19.90% 51.20% 0.00% 10.00% 20.00% 30.00% 40.00% 50.00% 60.00% 500 or more 400 - 499 300 - 399 200 - 299 100 - 199 1 - 99 Figure 4. Number of acres of airport property used for agricultural purposes.

12 Agricultural Operations on Airport Grounds of the airport’s wildlife (bird) activity highlighted the potential risk that agricultural prac- tices at the airport might entail. Lease agreements were terminated or allowed to expire without renewal, and to this day DFW prohibits cattle grazing and agricultural practices of any kind on its property. Currently, the airport works closely with neighboring property owners through close communication and collaboration to ensure wildlife attractants that can be hazardous to aviation safety are restricted. Further, landscape plans at the airport explicitly prohibit certain wildlife-attracting plant species from being introduced, while encouraging those that are native and do not attract wildlife. Coordination and communication between key Airport Board departments (Operations; Commercial Development; Environmental Affairs; and Design, Code and Construction) are critical when collaborating with future business development(s) on airport property to mitigate wildlife attractants and promote a robust business environment for growth at the airport. (Source: Dallas Fort Worth International Airport.) ACRP Report 32: Guidebook for Addressing Aircraft/Wildlife Hazards at General Aviation Airports also cautions against using airport property for crop production, including hay crops, within the FAA separation criteria. If there is no financial alternative to maintain the viability of the airport, the airport must Follow the crop distance guidelines listed in the table titled ‘Minimum Distances between Certain Airport Features and Any On-Airport Agricultural Crops’ found in AC 150/5300-13, ‘Airport Design.’ Avoid production of cereal grains and sunflowers. Weigh the cost of wildlife control and potential accidents against the income produced by the on-airport crops when deciding whether to allow crops on the airport. (Cleary and Dickey, 2010, p. 45) The aforementioned FAA separation criteria concerning land use that may attract hazardous wildlife is also further defined in FAA Advisory Circular 150/5200-33C, “Hazardous Wildlife Attractants on or near Airports,” which describes separation distances including a recommended 5-mile range perimeter around the airport to protect approach, departure, and circling airspace. The AC cautions that many agricultural crops can attract wildlife and should not be planted within the separations identified in the guidance (FAA, 2020). These operations and associated risk factors are described in Chapter 5. Airports in this study that implemented an agricultural land use on their airport provided the types of crops through responses to the survey and direct interviews. The most common crop type was hay or alfalfa, followed by some type of food crop such as corn or other grains (Figure 5). Examples of crops grown on airports: • Hay • Alfalfa • Soybeans • Corn • Grains • Wheat • Sugar cane • Wine grapes • Grass • Sunflowers • Oats • Ginseng • Cotton • Milo • Sugar Beets • Sod Generally, the type of crops found at airports in various geographical areas of the country was consistent with typical crops grown in the respective regions and climates. For example, it would

State of Practice of Agricultural Operations on Airport Grounds 13   be expected to see crops such as corn and soybeans primarily grown in the Midwest. Addition- ally, many airports indicated that land is used for cattle grazing and pasture. Many airports in the study allow for hay production on airport grounds. A number of these airports even restrict agricultural land leases to “hay only.” FAA Advisory Circular 150/5200-33C, “Hazardous Wildlife Attractants on or near Airports,” suggests that if it is finan- cially necessary to produce income through agricultural uses, hay is an alternative to consider over other agricultural crops because hay holds little food value for hazardous wildlife. Several airports in the study allow farmers or adjacent landowners to cut the grass areas of airport grounds in exchange for the hay. Alternatively, airports interviewed typically collected revenue by parcel size or by bale. Interview respondents require operators to remove baled hay as soon as possible so as not to create obstructions, and some airports surveyed also require cutting hay before it goes to seed. Provisions for operators’ equipment parking, access, and other safety considerations were mentioned as needs to be discussed and agreed upon between parties. Bartow Executive Airport in Bartow, Florida, uses 6 acres for a successful orange grove, which is managed by airport staff. The airport director states that the grove averages as a break-even operation and admits that the airport has never attempted to quantify the savings, but the direc- tor acknowledges that there are cost savings because there is less area to mow. This product itself has not attracted any additional wildlife to the airport. Bacon County Airport, Alma, Georgia, hosts the Bacon County Blueberry Research and Demonstration Farm. Its 40 acres are included in a larger operation producing more blueberries than any other county in Georgia. The program is a collaborative effort between Bacon County and the University of Georgia (UGA) Extension. It is staffed and managed by UGA employees, who also conduct research for the industry. The airport recognizes maintenance cost savings and states that there are no additional wildlife issues with this crop. Van Nuys Airport in California is a busy reliever airport located in the FAA Western Pacific region. Sod farming has been in place at the airport since 1991 under lease agreement with the airport. Airport officials interviewed reported that sod farming is the only agricultural land lease at the airport and involves 47 acres leased for this purpose, which is considered the highest and best use of that part of the property. Secondary benefits reported were increased revenue and decreased maintenance costs. Another example of sod farming on airport can be found in Industry Highlight #5. 0.50% 3.00% 14.40% 20.80% 39.60% 53.00% 0.00% 10.00% 20.00% 30.00% 40.00% 50.00% 60.00% Ornamental Crops (Ex. flowers) Fiber Crops (Ex. cotton, flax) Oil Crops (Ex. canola, soybean oil) Other - Write In Food Crops (Ex. grains, vegetables) Feed Crops (Ex. hay, alfalfa) Figure 5. Types of crops on airport leased land. Many airports in the study allow for hay production on airport grounds. A number of these airports even restrict agricultural land lease to “hay only.”

14 Agricultural Operations on Airport Grounds Agricultural Operations in the Airport Environment Airports operate in a highly regulated and safety-conscious environ- ment. Tenants and users of airports are often subject to rules, regula- tions, and procedures allowing them to operate on the airport. Airport managers contemplating an agricultural land lease program may con- sider the potential impacts of a farming operation on airport grounds. (See Figure 6 for an example of one potential impact.) If an airport chooses to enter into a formal or even informal agreement with a farming operation, it must ensure that the operator, which may be unfamiliar with airport operations, clearly understands expectations, including • Parking of equipment; • Working in proximity to airport operations; • Crossing of any aircraft operations areas (AOAs), including runways, taxiways, and aprons; • Clearance required from any runway safety area (RSA); • Closing and locking gates; • Access control measures; • Need to maintain the airfield surface free of debris (FOD); • Use of lights on equipment; and • Need to notify the airport regarding unusual conditions such as excessive dust. For airports with passenger service operating under 49 CFR 1542, Airport Security, it is critical that issues related to access to any AOA or secure areas of the airport are reviewed to ensure compliance with airport policy and TSA regulations. The airport may consider the applicability of the farm operator to be vetted or go through the badging process. This may also involve training on gate access, airfield driver training, and screening process. Airport operators must ensure that crops are compatible with aircraft safety area requirements and are located outside of areas such as the primary surface of the runway or object-free areas. Airports in the study reported that crop placement that might interfere with any navigational aid or Airport managers contemplating an agricultural land lease program may consider the potential impacts of a farming operation on airport grounds. Source: Denver International Airport. Figure 6. Sunflower admirers caught entering property and helping themselves to the crop.

State of Practice of Agricultural Operations on Airport Grounds 15   that might restrict the line of sight of pilots or air traffic control should be avoided. It is suggested that sightlines between intersecting runways and taxiways not be obscured and that pilots be able to see the entire length of the runways. Special Conditions Each airport is unique and will have operational differences based on airport layout and types of use. Many airports interviewed included addressing special conditions within their agricul- tural land lease to clarify actions dealing with the following: • Permits • Wildlife control • Soil testing • Pest control • Application of chemicals • Land maintenance • Drain tile maintenance • Water well maintenance • Standing water There are many questions (which may vary by location) that can be reviewed and agreed upon by the airport owner and the operator, such as the following: • Who will install and repair drain tile as needed (surface water management)? • Which party is responsible for soil testing or obtaining environmental permits as necessary? • Who finances and maintains structures or improvements? • What are the cost implications of these decisions and how should that be considered in the rental rate? The airport may also impose special conditions on agricultural land renters to help meet airport environmental goals. A common requirement airports impose on renters is to imme- diately plow under waste material after harvest to reduce crop residue and deter wildlife. Others intentionally require no-tilling of fields after harvest; for example, Eastern Iowa Airport (CID) values environmental land use practices and incorporates a no-till farming requirement on leases (Chapter 6, Case Example). Some airports also allow for secondary uses of agricultural land parcels, such as seasonal hunting. This is evaluated carefully; for example, use of calls to attract waterfowl may pose a risk to aircraft operating to and from the airport. Caution is exercised to ensure that uses do not interfere with airport functionality or create additional safety or security issues. Strategies to Overcome Challenges FAA Order 5190.6B, FAA Airport Compliance Manual, encourages airports to seek compat- ible land uses for aviation safety. It also provides that, in some cases, concurrent land use can be an appropriate compatible land use. It defines concurrent land use as land that can be used for more than one purpose at the same time. For example, portions of land needed for airspace protection purposes could also be used for agricultural purposes at the same time, which would be consistent with Grant Assurance 21, Compatible Land Use (FAA, 2009). Many airports have successfully implemented agricultural land lease programs that are safely conducted within established FAA and other industry guidelines. The implementation of these

16 Agricultural Operations on Airport Grounds uses is common not only at civilian public and private use airports but also within branches of the armed services. The following is a snapshot of one such program. Industry Highlight #2 – Agricultural Land Lease Program at Naval Air Stations The Department of Defense (DOD) has a Navy Forestry and Ag Outlease Program. A program manager interviewed for this study reports that the program is quite robust, with 33,000 acres of agricultural land leased on 20 installations in the U.S. and consisting of approximately 75 leases on naval air stations. The agricultural and grazing program provides for a competitive bid process approxi- mately every 5 years for parcels supporting a variety of crop types. The program is an effective way to decrease the costs of maintaining the land, saving the department an estimated $5 million–$6 million in expenses while producing annual revenues of an esti- mated $2 million. These funds are then used to maintain the program and contribute to other environmental programs. The DOD has a Bird Air Strike Hazard (BASH) program to mitigate wildlife hazards. The program manager shared lessons learned, including • Crop selection needs to be coordinated with all parties. For example, corn was an issue as a bird attractant, creating BASH issues. The solution was using corn in select loca- tions; ensuring that it was harvested right away when matured; immediately disking to plant in a cover crop; and using crop rotation so that corn is not the primary crop each year. • The program history shows the BASH issues increase when there is no active farming on parcels. Interestingly, there is an increase in the presence of rodents and other small animals that in turn attract raptors and other predators. Airports are encouraged to use resources available through consul- tation with a professional biologist trained in wildlife hazard manage- ment at airports. Additional guidance can be obtained through the U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS). When determining concurrent land uses, it is advisable to seek assistance through the appropriate FAA Airports District Office (ADO). The majority of airports surveyed in the study do not coordinate agricultural land lease programs with the FAA or their state divisions of aeronautics. However, a number of airports reported coordinating with these agencies as needed and through the development of their Wildlife Hazard Management Plan (WHMP). Agricultural land leases can enhance compatible land use and may, in certain cases, decrease wildlife hazards and improve environmental conditions. Other shared practices to overcome situational challenges include • Using comprehensive leases • Ensuring fair market value • Communicating clearly with operators Additional guidance can be obtained through the USDA Animal and Plant Health Inspection Service (APHIS).

State of Practice of Agricultural Operations on Airport Grounds 17   • Clarifying any responsibilities for special conditions • Initiating a process to evaluate the effectiveness and safety of the program • Evaluating potential wildlife attractant issues during all phases (planting, harvesting, tilling) Industry Highlight #3 – Commercial Airport Gardening in the Last Frontier State Meyers Farm Bethel Airport Bethel, Alaska Permafrost, cold winds, and a short growing season—what agricultural products could possibly grow in these conditions? The Meyers Farm’s overall operation can produce up to 100,000 lbs. of fresh produce annually to support its local communities—56 rural communities to be exact. The Meyers Farm was established in 2002 by Tim and Lisa Meyers and is located in Bethel, Alaska, approximately 1 mi. north of the Bethel Airport. This family-owned and operated business not only supports the local economy but also provides fresh produce to families and businesses who would typically have to depend on shipments flown in from Anchor- age and the lower 48 states. These lengthier shipments increase family grocery expenses. The Arrangement The airport agriculture parcel is 9.6 acres located outside of the airport’s secured area and air operations area, just northwest of the departure end of Runway 1L. The Bethel Airport is a state-owned airport, so the agreement between Meyers and the airport is subject to an operating permit overseen by the airport leasing specialist and airport manager. Originating in 2008, a 10-year permit with a 30-day cancellation provision is in place. The rental rate, or fair market value, is defined by state statute, Alaska Administrative Code 17 AAC 45.127 (j)(1). Currently, it is set at $100 per acre, providing $960.00 to the airport annually. The parcel permit is subject to the Army Corps of Engineers special conditions to maintain natural drainage patterns to avoid any impacts to wetlands. There is no special condition in the permit; however, the permit does state that fill material must be clean and mineral fill must be free of unsuitable material or toxic pollutants, and it includes additional language to address any hazardous material and spills. The Alaska Department of Fish and Game, Division of Habitat, did not identify any habitat concerns with the project. The parcel does not appear to be a significant attractant to wildlife during surveys for the wildlife hazard assessment and would be addressed should this change. According to airport manage- ment, no additional FAA approval is necessary, as the parcel is designated a “future non- aviation revenue support area.” How It Works Tim Meyers observed a Cooperative Extension Service master gardening course held at the airport several years ago. He knew the delta area’s ground comprised the world’s most extremely fertile soils. He began to grow produce at his farm and later tilled the acres at the airport, improvising and using crop-boosting techniques in Alaska. This includes using natural fertilizer available from salmon waste from the delta area and taking advantage of the Alaskan summer providing up to 21 hours of daylight per day. An underground

18 Agricultural Operations on Airport Grounds bunker at his farm is used to start many seeds and later holds the produce in storage. The seedlings for the root vegetables and potatoes are generally planted around the second week of June and row covers are placed over the plants until about July 4. Meyers states that the permafrost located approximately 2 ft. under the soil’s surface is key to the growth. The icy conditions assist with converting the starches to sugars, contributing to the excellent taste. Upon harvesting, the produce is boxed per order using the company’s website. The boxes are weighed and shipped to end users often by air, using the airport. Financial assistance is available to end users from the Alaskan Food Bank to cover part of the costs and from the Yukon-Kuskokwim Health Corporation to pay the shipping costs. (Source: Meyers Farm.) (Source: Meyers Farm.)

State of Practice of Agricultural Operations on Airport Grounds 19   The Benefits The airport benefits from a reduction in ground maintenance and enjoys revenue gen- eration for otherwise unused airport property. The airport recognizes the value of the operation for the local communities and receives community acceptance and support for the airport operations. The community (56 rural communities) enjoys fresh, locally grown produce to supple- ment the Alaskan diet, which is often composed of fish, waterfowl, and additional meats. The economy benefits from a local business using local resources and providing a product that lowers consumer costs. The family’s farming practices are all sustainable and free of pesticides and herbicides, not only providing an organic product but doing so as envi- ronmental stewards. Additional information: Meyers Farm, https://meyersfarm.net/