20040930 Ver 2_USACE Request for More Info_20200706

US Army Corps
Of Engineers
Wilmington District
Mr. John Ferguson
City of Statesville
238 Airport Road
Statesville, NC 28677
Dear Mr. Ferguson,
PUBLIC NOTICE COMMENTS
Date Issued: July 6, 2020
Response Deadline: August 7, 2020
Corps Action ID Number: SAW-2015-01645
Please reference your Individual Permit (IP) application for Department of the Army (DA)
authorization to discharge fill material into 1.93 acres of wetlands and 663 linear feet of stream,
associated with the expansion of the Statesville Regional Airport Anson County Waste
Management Facility in Statesville (Iredell County), North Carolina.
Your proposal was advertised by public notice on May 20, 2020. Comments in response to
the notice were received from the Environmental Protection Agency (EPA), the National
Oceanic and Atmospheric Administration, National Marine Fisheries Service (NMFS), the North
Carolina Wildlife Resources Commission (NCWRC), the North Carolina Department of
Environmental Quality, Division of Water Resources (NCDEQ-DWR), the Landings
Homeowners Association, Lakewood Golf Club, and North Carolina Department of Natural and
Cultural Resources, State Historic Preservation Office (NCSHPO). The comments and
recommendations received are enclosed for your information and to provide you with the
opportunity to address any of the stated concerns (i.e., Table 1). Please provide written responses
to the comments and recommendations from the EPA, NCWRC, NCDEQ-DWR, Landings
Homeowners Association, and Lakewood Golf Club. The NMFS, in a letter dated May 22, 2020,
stated the proposed project would not occur within the vicinity of essential fish habitat. The
NCSHPO have no comments on the proposed project. Additionally, this letter serves as the
Corps comment letter, which needs written response, and the comments are as follows:
With respect to the project purpose, its analysis is a critical first step in the Corps
permitting process. The Corps is responsible in all cases for independently defining the
project purposes from both the applicant's and the public's perspective. Initially, the
Corps evaluates a project's "basic purpose" to assess whether the project is water
dependent. Once the Corps has determined the water dependency of the project, it no
longer considers the basic project purpose, but analyses practicable alternatives in the
light of the "overall project purpose". The overall project purpose must be specific

enough to define the applicant's need, but not so restrictive as to preclude an analysis of
all reasonable alternatives. The project purpose stated in your application is "to improve
airport safety and meet the operation needs of existing users at Statesville Regional
Airport." In considering the overall project purpose, we have determined that this project
purpose does not capture the project function in its entirety and does not provide reason
(i.e., addressing the Federal Aviation Administration (FAA)'s regulatory requirements)
for the expansion of the existing airport. Therefore, we have determined the overall
project purpose of this project is to ensure the long-term viability ofthe existing
Statesville Regional Airport (i.e., runway and associated facilities) by complying with the
FAA's Advisory Circular Airport Design and FAA Order Runways Safety Area Program.
2. Currently, the Statesville Regional Airport has a maximum airplane capacity (i.e., critical
airplane or most demanding aircraft currently operating or expected to operate at the
airport on a regular basis) of a Embraer 145 which requires a Runway Safety Area (RSA)
that is 500 feet wide and extends 1,000 feet beyond the departure end. As proposed,
extension of the runway at the Statesville Regional Airport would meet these widths and
lengths required for the most demanding aircraft currently operating at the airport. With
increases in growth in the Charlotte metro area and the urban expansion in the region
including Statesville, North Carolina; what is the life expectancy of the proposed runway
expansion. Does the Airport anticipate with the expanding runway to increase the
size/type of the critical airplane that can utilize the Statesville Regional Airport? Will this
expansion result in further runway expansion in the future (near- or long-term) and if so,
please provide an estimate as to when another runway expansion would be needed?
3. The application stated Statesville Regional Airport is responsible for keeping the area
around the airport free from obstruction and proposed the removal of tree obstructions to
improve runway safety. Please quantify the number of trees planned for removal around
Statesville Regional Airport.
4. The areas where the tree obstructions are removed, what is the plan to ensure these tree
obstructions do not reoccur in the future. Therefore, please provide a plan to safeguard
against any tree obstructions in the future which may not comply with FAA's Runways
Safety Area Program.
5. The application states a majority of Wetland WA will be impacted by the proposed
project. Wetland WA drains into Stream ISA. The project proposes to discharge a large
amount of rill material into the project area to raise the elevation of the area and extend
the existing runway. Extending the runway will likely change the hydrology and
connection to downstream waters. Therefore, there is potential for the remaining acreage
of Wetland WA to be isolated/excluded from downstream waters. Please provide any
grading plans and/or justification as to why the remaining portion of Wetland WA will
not be isolated from downstream waters and permanently impacted.
6. In Section 5.1, it states "the No Build Alternative is not a practical alternative because it
does not improve airfield safety and operational utility at SVH." Currently, Statesville
Regional Airport does not meet FAA requirements; how long does the airport have to get
in compliance with FAA's regulations?
7. In Section 5.2 the application states, "it is not reasonable to assume that existing
conditions at Rowan County Airport (RUQ) would be sufficient for the anticipated
increased operational demand from Statesville Regional Airport tenants." You stated
E

previously, RUQ has a runway length exceeding Statesville Regional Airport. So please
clarify/justify why you think RUQ could not handle the increased operational demand, if
their current facilities are larger than that of Statesville Regional Airport.
8. In Section 5.2 the application states "an increase in operational demand would likely
result in impacts to Waters of United States as a result of the needed Greenfield
development at RUQ to accommodate existing Statesville Regional Airport tenants."
This is a general statement back with no quantitative data. Please quantify the impacts to
jurisdictional Waters of the United States based on the potential increase in operational
demand at RUQ.
9. In Section 5.3, the application states "this will significantly reduce or eliminate maximum
takeoff weight restrictions, which will financially benefit Statesville Regional Airport and
their current and prospective users." This is a broad statement and needs specific details
to support this assumption. Please provide the following information, but not limited to:
1) quantify the term "significantly reduce"; and 2) provide monthly, yearly, and multi-
year financial benefit to the proposed activities at Statesville Regional Airport.
10. The Preferred Alternative (i.e., Alternative A) proposes to abandon a 750-foot portion of
Old Bethlehem Road resulting in an approximate 3.4-mile permanent detour. The Corps
is concerned this permanent detour will have adverse effects to the community in the
vicinity of the Statesville Regional Airport. The application lacks specific details related
to the permanent detour resulting from the Preferred Alternative. Please provide the
following information, but not limited to: 1) A map showing the 3.4-permanent detour
route; 2) A narrative summary justifying why the applicant assumes this permanent
detour will not have a negative effect on the community surrounding the Statesville
Regional Airport; and 3) A summary of any discussion/consultant the applicant had with
NCDOT and/or local and county representatives related to new traffic patterns as a result
of the permanent detour proposed for the Preferred Alternative.
11. On -Site Alternative Al lacks enough detail to analyze and compare to the other on -site
alternatives. The application states On -Site Alternative Al would have a lower
construction costs but would also have an addition cost in land acquisition. Has
Statesville Regional Airport considered a permanent easement with church which would
not require the airport to purchase the entire parcel from the church and only a portion,
and in turn reducing the land acquisition costs of approximately $190,000. In addition,
more detail is needed as to why additional acreage is needed for this alternative (i.e.,
proposed slopes without retaining walls, etc.).
12. On -Site Alternative B suggests this alternative fails to improve safety for, or meet the
operational needs of, the majority of airport users, as only 10 percent of aircraft
departures occur in this direction. If Runway 28's runway safety area meets FAA
requirements instead of Runway 10, then please provide reason why take -off and landing
cannot be switched to accommodate this alternative.
13. The application states "existing surface drainage area from the northeast of Runway 10
will continue to be directed to remaining portions of Wetland WA." As previously stated,
the Corps is concerned the remaining portion of Wetland WA will be isolated/excluded
from downstream waters. How does the applicant propose to ensure the remaining
portion of Wetland WA will not be isolated/excluded from downstream jurisdictional
Waters of the United States?
3

14. The compensatory mitigation ratios proposed for Stream ISA is not sufficient to offset
the environmental losses resulting from the unavoidable impacts to the previously
mentioned stream within the proposed project area. Compensatory mitigation must be
commensurate with the amount and type of impact. The Corps determines appropriate
compensatory mitigation ratios based on site -specific factors such as the amount of
feature impacted, quality of feature impacted, etc. Table 1 summarizes the potential
mitigation ratios for the proposed project. As of July 1, 2020, the cost of a stream credit
is $558.81 a linear foot and a wetland credit is $61,264.36 an acre.
Feature
Quality
Impact
Applicant
Applicant
Corps
Corps
Impacted
of
Amount
Proposed
Proposed
Proposed
Proposed
Feature
Compensatory
Required
Compensatory
Required
Mitigation
Credits
Mitigation
Credits
Ratio
Ratio
Stream
Low
375
1:1
375
1.5:1
563
ISA
linear
linear
linear
feet
feet
feet
Stream
Medium
287
2:1
575
2:1
576
SA
linear
linear
linear
feet
feet
feet
Wetland
Low
0.57
2:1
1.14
2:1
1.14
WA
acre
acres
acres
Wetland
Low
0.16
2:1
0.32
2:1
0.32
WB
acre
acres
I acres
Wetland
Unknown
1.2
1:1
1.2 acre
1:1
1.2 acres
2006
acres
If you have any questions regarding these matters, please contact me at [phone] or
bryan.roden-re. nolds e,usace.army.mil.
Sincerely,
Bryan Roden -Reynolds
Regulatory Program Manager
Charlotte Field Office

Enclosures:
1. Table 2. Comments in Response to the Public Notice
2. EPA Comment Letter Dated May 21, 2020
3. NMFS Comment Letter Dated May 22, 2020
4. NCWRC Comment Letter Dated June 2, 2020
5. NCDEQ Comment Letter Dated June 3, 2020
6. Landings Homeowners Association Comment Letter Dated June 8, 2020
7. Lakewood Golf Club Comment Letter Dated June 13, 2020
8. NCSHPO Comment Letter Dated June 26, 2020
Copies Furnished (via email):
Brad Luckey — Pilot Environmental, Inc.
Todd Bowers — EPA
Olivia Munzer — NCWRC
Sue Homewood - NCDEQ
Matt Bailey — Landings Homeowners Association
Dennis Watkins — Lakewood Golf Club
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Roden Reynolds, Bryan K CIV (US)
From: Bowers, Todd <[e-mail]>
Sent: Thursday, May 21, 2020 4:02 PM
To: Roden Reynolds, Bryan K CIV (US)
Subject: [Non-DoD Source] FW: US Army Corps of Engineers Wilmington District Public Notice
(UNCLASSIFIED)
Bryan,
The EPA Region 4 Ocean, Wetlands and Streams Protection Branch has reviewed the subject Public Notice under DA
Action ID SAW-2015-01645 dated May 20, 2020 (obtained from Wilmington District Regulatory website). It is our
understanding that the applicant, the City of Statesville, is seeking authorization to impact 663 linear feet of stream
channel and 1.93 acres of wetlands for improvements to the runway safety area and the removal of tree obstructions to
comply with Federal Aviation Administration safety requirements. The project is located at 238 Airport Drive near
Statesville, Iredell County, North Carolina.
Specifically, according to the Public Notice, the applicant has attempted to avoid and minimize impacts where possible
and will compensate to the extent practicable, for the remaining unavoidable losses with compensatory mitigation.
Likewise impacts incurred to Wetland WB during unauthorized activity that resulted in the loss of approximately 1.2
acres of jurisdictional wetlands will be compensated for. The applicant has proposed compensatory mitigation in the
amount of 663 stream mitigation units (credits) for 663 If of stream impacts and 1.93 wetland mitigation units (credits)
for 1.93 acres of impact to low quality wetlands.
At this time, the EPA has a concern with the applicant's totals for compensatory mitigation needed per Table 4 of the
Public Notice. The proposed compensatory mitigation of 663 credits for stream impacts should be (375 X 1)+(288 X 2)
and equal 951 credits. This is applying the applicant's own proposal to replace Stream SA (medium quality perennial
channel) at a 2:1 ratio, which I concur with. I have no other issues with the amount or ratios proposed for replacing the
lost aquatic functions at the project site. Please ensure the applicant secures the appropriate type of mitigation (warm
water stream) from the nearest available NCDMS mitigation site (or appropriate mitigation bank) within the Yadkin River
Basin.
Thank you for the opportunity to provide feedback on DA Action ID SAW-2015-01645 for improvements to the runway
safety area and the removal of tree obstructions to comply with Federal Aviation Administration safety requirements at
238 Airport Drive in Iredell County, North Carolina.
Best Regards,
Todd Bowers
Todd Allen Bowers
US EPA Region 4 Oceans, Wetlands and Streams Protection Branch
61 Forsyth St. SW
Atlanta, GA 30303
404.562.9225
[e-mail]
Note: I am currently teleworking and away from the office. Please contact me via email or at 919.523.2637.

-----Original Message -----
From: Wallace, Nancy L CIV USARMY CESAW (US) <[e-mail]>
Sent: Wednesday, May 20, 2020 8:23 AM
Subject: US Army Corps of Engineers Wilmington District Public Notice (UNCLASSIFIED)
CLASSIFICATION: UNCLASSIFIED
As you requested, you are hereby notified that Wilmington District, United States Army Corps of Engineers has issued
a Public Notice. The text of this document can be found on the Public Notices portion of the Regulatory Division Home
Page. Each Public Notice is available in ADOBE ACROBAT (.pdf) format for viewing, printing or download at
Blockedhttps:Hgcc0l.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.saw.usace.army.mil%2FMissions%2F
Regulatory-Permit-Program%2FPublic-
Notices%2F&amp;data=02%7C01%7Cbowers.todd%40epa.gov%7Cff4eb36eaa9949b2c26c08d7fcc74d9f%7C88b378b36
7484867acf976aacbeca6a7%7C0%7C0%7C637255805238024191&amp;sdata=lCJJJOp9R8bAQohwFFJ86Pm29YfZtef% 2B
4ADPcpc2hZ4%3D&amp; reserved=0
As with anything you download from the internet, be sure to check for viruses prior to opening. The current notice
involves:
Corps Action ID#: SAW-2015-01645
Issue Date: May 20, 2020
Applicant: City of Statesville
Expiration Date: 5:00 p.m., June 18, 2020
Point of Contact: Bryan Roden -Reynolds, 704-510-1440
Project Description: The Wilmington District, Corps of Engineers (Corps) received an application from the City of
Statesville seeking Department of the Army authorization to impact 663 linear feet of stream channel and 1.93 acres of
wetlands for improvements to the runway safety area and the removal of tree obstructions to comply with Federal
Aviation Administration requirements.
Subscribe/Unsubscribe: This email was sent out as a result of subscribing to the Wilmington District regulatory program
public notices. Please reply to this email with the subject or message "unsubscribe" to remove your address from future
mailings.
CLASSIFICATION: UNCLASSIFIED

(UNITED STATES DEPARTMENT OF COMMERCE
mR"`"TYf`Cp�� National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
� 263 13th Avenue South
�
� St. Petersburg, Florida 33701-5505
https://www.fisheries.noaa.gov/region/southeast
(Sent via Electronic Mail) May 22, 2020
Colonel Robert J. Clark, Commander
USACE Wilmington District
69 Darlington Avenue
Wilmington, North Carolina 28403-1398
Dear Colonel Clark:
NOAA's National Marine Fisheries Service (NMFS) reviewed the projects described in the
public notices listed below. Based on the information in the public notices, the proposed projects
would NOT occur in the vicinity of essential fish habitat (EFH) designated by the South Atlantic
Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS.
Present staffing levels preclude further analysis of the proposed work and no further action is
planned. This position is neither supportive of nor in opposition to authorization of the proposed
work.
Notice No. Applicant(s) Notice Date
SAW-2016-01337 NCDOT; Big Mill Farm Road May 21, 2020
SAW-2015-01645 City of Statesville; Statesville May 20, 2020
Regional Airport
Please note these comments do not satisfy consultation responsibilities under section 7 of the
Endangered Species Act of 1973, as amended. If an activity "may effect" listed species or
critical habitat under the purview of the NMFS, please initiate consultation with the Protected
Resources Division at the letterhead address.
/for
Sincerely,
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
02 June 2020
Mr. Bradley Luckey
Pilot Environmental
P.O. BOX 128
Kernersville, NC 27285
SUBJECT: Individual Permit for the Statesville Regional Airport in Statesville, Iredell County, North
Carolina. DEQ No. 20040930v2.
Dear Mr. Luckey,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended) and Fish and Wildlife Coordination Act Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661 et seq.).
On behalf of the City of Statesville, Pilot Environmental has submitted a Section 404/401 Individual
Permit for the proposed Statesville Regional Airport Runway Safety Area Improvement project in
Statesville, Iredell County, North Carolina. The program includes proposed improvements to the Runway
Safety Area to comply with Federal Aviation Administration standards, close a portion of Bethlehem
Road, relocate the localizer further west, and removal of tree obstructions to the approach areas using
hand clearing in wetlands and streams. The proposed improvements would permanently impact 375.1
linear feet (If) of intermittent stream, 2.87.5 if of perennial stream, and 0.73 acres of wetlands. The
installation of retaining walls will reduce impacts
The project area drains to Back Creek in the Yadkin -Pee Dee River basin. We have no records of federal
or state listed species at or adjacent to the site. The lack of records from the project area does not imply or
confirm the absence of federal or state -listed species. An on -site survey during the appropriate survey period
is the only definitive means to determine if the proposed project would impact rare, threatened, or endangered
species.
NCWRC understands the need for increased safety, reducing wildlife attractants and hazards, and
increasing operational utility; however, we have some concerns regarding the amount of impacts to
jurisdictional waters. We offer the following recommendations to minimize impacts to aquatic and
terrestrial wildlife resources:
We prefer the Alternative A; however, we recommend further minimizing impacts to
Jurisdictional waters. Consider relocating Stream SA to the west side of the retention wall using
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
02 June 2020
Statesville Airport IP
DEQ No: 20040930v2
natural stream design.
2. Due to the decline in bat populations, avoid tree clearing activities during the maternity roosting
season for bats (May 15 — August 15).
3. Pesticides, fertilizers, and other chemicals should not be used in wetland areas or near streams,
even if they are labeled as water/wetland friendly.
4. Manage non-native, invasive species by pretreating the project site prior to construction,
preventing spread during construction, and control non-native, invasive species throughout the
monitoring period.
5. Disturbed areas should be re -seeded with native seed mixtures. We recommend avoiding
lespedeza, which is nonnative and invasive. Furthermore, lespedeza provides wildlife cover and
forage, and attract pollinators; therefore, it is not recommended around airports.
6. All mechanized equipment operated near surface waters should be inspected and maintained
regularly to prevent contamination from fuels, lubricants, hydraulic fluids or other toxic
materials.
7. Manage non-native, invasive species by pretreating the project site prior to construction,
preventing spread during construction, and control non-native, invasive species throughout the
monitoring period.
8. Disturbed areas should be re -seeded with native seed mixtures. We recommend avoiding
lespedeza, which is nonnative and invasive. Furthermore, lespedeza provides wildlife cover and
forage, and attract pollinators; therefore, it is not recommended around airports.
9. Sediment and erosion control measures should be installed prior to any land clearing or
construction. The use of biodegradable and wildlife -friendly sediment and erosion control
devices is strongly recommended. Silt fencing, fiber rolls, and/or other products should have
loose -weave netting that is made of natural fiber materials with movable joints between the
vertical and horizontal twines. Silt fencing or similar materials that have been reinforced with
plastic or metal mesh should be avoided as they impede the movement of terrestrial wildlife
species. Excessive silt and sediment loads can have detrimental effects on aquatic resources
including destruction of spawning habitat, suffocation of eggs and clogging of gills.
Thank you for the opportunity to provide input for this project. If I can provide further assistance or free
technical guidance, please call [phone] or email olivia.munzerkncwildlife.org.
Sincerely,
C2���_-
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
ec: Bryan Roden -Reynolds, U.S. Army Corps of Engineers
Sue Homewood, N.C. Division of Water Resources
Byron Hamstead, U.S. Fish and Wildlife Service
Todd Bowers, U.S. Environmental Protection Service

DocuSign Envelope ID: OF387047-2B67-42EF-8FFA-472146CD55F9
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
June 3, 2020
DWR # 20040930 v2
Iredell County
City of Statesville
Attn: Mr. John Ferguson
238 Airport Rd
Statesville NC 28677
Subject: REQUEST FOR ADDITIONAL INFORMATION
Statesville Regional Airport Runway Safety Area Improvements
Dear Mr. Ferguson:
On May 5, 2020, the Division of Water Resources — Water Quality Programs (Division) received your
application requesting an Individual 401 Water Quality Certification from the Division for your project.
The Division has determined that your application is incomplete and cannot be processed. The
application is on -hold until all of the following information is received:
1. Please clarify if there has been any consideration for higher or longer retaining walls to further
reduce impacts to jurisdictional features. [15A NCAC 02H .0506(f) and (g)]
The application states that Old Bethlehem Road will be abandoned as part of this project and
that a 3.4-mile permanent detour will result from this abandonment. Please clarify whether the
City or NCDOT are considering, discussing, or planning for any future roadway improvements as
a result of this road abandonment and detour. [15A NCAC 02H .0506(f) and (g)]
The Division appreciates your efforts to maintain existing surface hydrology to the remaining
portions of Wetland A and to downstream sections of stream SA. Please address the following
additional concerns related to stormwater flow from this project [15A NCAC 02H .0502(b)]:
a. The Division is concerned that although the remaining portion of Wetland WA will be
hydraulically supported by overland stormwater flow, it will become isolated from other
jurisdictional features and result in a loss of federal jurisdiction and federal protections.
b. Please indicate whether a groundwater drain system (French drains) will be installed below
the new fill to direct groundwater towards stream SA.
c. Please provide a detail showing how existing stormwater from Old Bethlehem Road and
property across from old Bethlehem Road will be managed after this project is constructed.
Q North Carolina Department of Environmental Quality I Division of water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH OAROa.INA �
919.707.9000

DocuSign Envelope ID: OF387047-2B67-42EF-8FFA-472146CD55F9
City of Statesville
DWR Project #20040930 v2
Request for Additional Information
Page 2 of 2
In order to ensure that the proposed overland stormwater flow will protect downstream
water quality, please provide documentation to show that the new fill slopes and
constructed swales will maintain flows as non -erosive velocity during the peak flow from a
ten-year storm. You may refer to the guidelines from DEMLR -Sedimentation and Erosion
Control, to determine an appropriate non -erosive velocity of each feature. The permissible
velocities for erosion protection may be found under Appendix 8.05 (Chapter 8).
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. Please respond in writing within 30
calendar days of receipt of this letter by sending one (1) copy of all of the above requested information
to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617 OR by
submitting all of the above requested information through this
link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note the DWR# requested on
the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be denied as incomplete. The denial of this
project will necessitate reapplication to the Division for approval, including a complete application
package and the appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for this
activity and any work done within waters of the state may be a violation of North Carolina General
Statutes and Administrative Code.
Please contact Sue Homewood at 336-776-9693 or [e-mail] if you have any
questions or concerns.
Sincerely,
DocuSigned by:
P~I W10
949D91BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Branch
cc: Brad Luckey, Pilot Environmental Inc. (via email)
Bryan Roden -Reynolds, USACE Charlotte Regulatory Field Office (via email)
Olivia Munzer, NCWRC (via email)
DWR MRO 401 files
DWR 401 & Buffer Permitting Unit

DocuSign Envelope ID: OF387047-2B67-42EF-8FFA-472146CD55F9
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
June 3, 2020
Corps Action ID# SAW-2015-01645
DWR# 20040930 v2
Iredell County
Mr. Bryan Roden -Reynolds
U.S. Army Corps of Engineers
Charlotte Regulatory Field Office
8430 University Executive Park, Suite 615
Charlotte NC 28262
Subject Project: Statesville Regional Airport Runway Safety Area Improvements
Dear Mr. Roden -Reynolds
On behalf of the NC Division of Water Resources, we respectfully request that you consider the
following comments within your review of the 404 Individual Permit request for the above referenced
property:
During a pre -application site visit the consultant indicated that there were additional projects
under development at the Statesville Airport. The Division recommends that if any additional
projects are planned for the near future that they be incorporated into the current application.
2. The proposed project will result in isolating a portion of Wetland WA. The Division recommends
consideration of whether this area would be expected to lose jurisdiction due to future isolation
and whether the loss of protections should be considered an indirect impact to this wetland.
3. The Division has requested additional technical information from the applicant and requests
that the USACE also consider the attached letter during the review of the application.
Q North Carolina Department of Environmental Quality I Division of water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH OAROa.INA �
919.707.9000

DocuSign Envelope ID: OF387047-2B67-42EF-8FFA-472146CD55F9
Corps Action ID# SAW-2015-01645
DWR# 20040930 v2
Page 2 of 2
Thank you for your considering the Division's comments during your review of this Individual Permit. If
you have any questions, please contact Sue Homewood at 336-776-9693 or
[e-mail].
Sincerely,
Paul Wojoski, Supervisor
401 & Buffer Permitting Unit
cc: Brad Luckey, Pilot Environmental Inc (via email)
Olivia Munzer, NCWRC (via email)
DWR MRO
DWR — Wetlands and Buffer Permitting Branch

The landings Home Owners
Association, Inc.
151 Heathrow Lane
Statesville, NC 28677
June 8, 2020
US Army Corps of Engineers
Wilmington District
8430 University Executive Park Drive
Suite 615
Charlotte, NC 28262
Attn: Bryan Roden -Reynolds, Charlotte Field Office
Ref: Corp Action ID : SAW-2015-01645
Dear Sir:
This letter regards the proposed actions of the City of Statesville as outlined in the above
referenced action.
The report identifies as "Existing Site Conditions" of the proposed project 6 subject areas.
It omits and fails to identify a seventh critical component; the fact that a heavily traveled
two lane county road (Old Bethlehem Road) cuts directly through the proposed project
area. This road has been in existence for over 50 years as a public road. Home owners
have built and bought homes in some regard to the accessibility that it provides. Located
along this road are three churches and over a hundred homes. At the immediate western
end is located "Celeste Henkel Elementary School" with a student body of 600 students
and staff.
The proposed plan gives no consideration to the detrimental effects of this closure to
public welfare. The most recent traffic study conducted quantifies that 900-1300 hundred
vehicles travel this road daily. Were this road to be closed, no alternative egress would be
available to eastbound traffic. Only the westbound egress would be available forcing all
traffic to go miles out of the way to reach eastern destinations.
Critical emergency services; Fire, Police, and EMC would be cut off from the most direct
approaches from the east where the closest local hospitals are located. 10-20 minutes
longer response time for EMC, Fire, and Police could be the difference in saving a home
from destruction or a life lost.
Of additional concern is the growing issue of stormwater runoff. The above referenced
report sites... "the elevation of the shallow water table is transient and can vary greatly
with seasonal fluctuations in precipitation." Wetlands WA, WB, and WC drain into stream

ISA, then into stream SA discharging into Back Creek. "...The Corps verified a
delineation in 2003/2004 for the same proposed project area. At that time, Wetland WB
was approximately 1.2 acres larger than the wetland delineated in 2020. Further analysis
determined the applicant conducted unauthorized activities in waters in the United States
sometime in 2006. This unauthorized activity resulted in the loss of approximately 1.2
acres of jurisdictional wetlands."
Since the Airport construction storm water flows west of the site gathering into the streams
identified as "ISA" and "SA" and then into "Back Creek" that crosses Old Bethlehem
Road. Flooding at this point has now become a frequent occurrence. The farm there, and
two residential properties adjacent now flood following rain events of 3+ inches. Last year
the road itself was washed out requiring the County to replace the culvert with two 52 in.
culverts and resurface the road. Westbound egress was closed for weeks while this was
done. If it were not for the eastern alternative exit, the 50 homes of the "Landings" located
there would have been cut off completely.
At this time, other than this US Army Corps of Engineers notice, that has not been widely
disseminated, the public has not been fully made aware of this plan.
As President of the "Landings Home Owners Association" representing the 42
homeowners and 33 future homeowners of this development, we oppose this proposed
action and formally request a "Public Hearing" to address the concerns of all parties.
Sincerely,
Matt Bailey
President
Landings Home Owners Association
151 Heathrow Lane
Statesville, NC 28677
Ph: 704-799-5339

Date: June 13, 2020
To: US Army Corps of Engineers
Bryan Roden -Reynolds
8430 University Executive Park Drive
Suite 615
Charlotte, NC 28262
[e-mail]
From:
NCDWR Central Office
Karen Higgins, 401 and buffer Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699
[e-mail]
Lakewood Golf Club, Dennis Watkins, President
273 Old Airport Rd
Statesville, NC 28677
[e-mail]
Subject: SAW-2015-01645 request for public hearings
We are in receipt of: Public Notice Action ID Number SAW-2015-01645 that was
submitted to us on May 20, 2020 from the Wilmington district of the US Army Corps
of Engineers. The comments presented here represent a request for public hearing
concerning this project.
As owners of Lakewood Golf Club we request the review of the impact of the City of
Statesville Airport expansion and construction on the property of the Lakewood Golf
Course. SAW- 2015-01645 is an expansion of the Statesville Airport that continues a
cumulative storm water impact on adjoining properties. Airport storm water is
engineered to be collected and efficiently discharged onto adjoining properties. The
volume and velocity of this discharge has proven to be damaging directly washing
out Bethlehem Road (stream SA) in 2019.
The Lakewood Golf Course adjoins the east & south end of the Statesville Airport.
Storm water runoff from 77+/- acres of the airport drain through the irrigation
ponds of the golf course. Since 2002, airport development has included runways,
hangars, parking lots, roadways, and taxi ways. Over 24 acres of impervious
surfaces have replaced former farm and forest land. The result of this
development has greatly increased the storm water runoff in volume, velocity, and
damage. The history since 2005 of siltation to ponds and wetlands as well as
erosion is documented including citations to the City of Statesville. In 2019

multiple documented storm water events contaminated our water supply with
sediment and flooding. As little as a 2" rain event now floods our ponds. The
ongoing runoff outflow has increased erosion damages and siltation into Third
Creek.
Our contacts with the City of Statesville have been with John Ferguson, Airport
Manager and Mark Taylor City PE. We attended Airport Commission meetings on
two occasions to voice our concerns. No known plans or budgeting is part of the
Airport Commission's future to deal with the cumulative storm water discharge. In
fact, planned parking areas will only increase this discharge volume on to our
property.
As a NC DEQ Division of Water Resources registered riparian rights water user, the
irrigation ponds serve as a vital part of our business.. Storm water runoff flood
volume threatens the integrity of the pond dams and continued sedimentaion. The
timeliness of corrective action is critical to our golf course business. It is
unreasonable to knowingly ignore the impact of storm water discharged to damage
adjoining properties.
On page 10 of the "Public Notice" SAW-2015-01645 it is clearly stated that the
"cumulative impacts of the proposed activity on the public interest" will be
evaluated. "All factors which may be relevant to the proposal will be considered
including the cumulative effects thereof'.
The cumulative effects of airport expansion has greatly impacted our property
ownership and will continue to do so based on future plans.

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secreuiy Susi H. Hamilton
June 26, 2020
Bryan Roden -Reynolds, WPIT
U.S. Army Corps of Engineers
Wilmington District
Charlotte Regulatory Field Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office of Archives and Histoiy
Deputy Secreuiy Kevin Cheny
Bryan.K.RodenRevnoldskusace.armv.mil
Re: Extend runway safety area west, 2 retaining walls, remove obstructing trees, 238 Airport Drive,
Statesville, Iredell County, ER 20-1200
Dear Mr. Roden -Reynolds:
Thank you for your email of May 20, 2020, concerning the above project.
We have conducted a review of the project and are aware of no historic resources which would be affected by
the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or
environmental.reviewkncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,
k"Ramona Bartos, Deputy
State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599