HomeMy WebLinkAbout20061632 Ver 1_More Info Received_20070125JAN 2 5 2007
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PIEDMDNTTRIAD JErlr~ _ vtiATER QUAUIY
ainPORrauTRarslrv
a','~TIANDS AND STORkNKATER BRANCH
January 26, 2007
U.S. Army Corps of Engineers,
Wilmington District,
Raleigh Regulatory Field Office
6508 Falls of the Neese Road, Suite 120
Raleigh, NC 27615
North Carolina Deparhnent of Environment
and Natural Resources, Division of Water
Quality, 401 Oversight Unit
2321 Crabtree Boulevard, Suite 250
Raleigh, NC 27604
Attention: Mr. John Thomas Ms. Cyndi Karoly
Subject: Application for Section 404 Permit for Runway SR Safety Area and Related
Improvements at Piedmont Triad International Airport, Greensboro, NC
Corps Action ID #: SAW 20(16 41354241
DWQ Project No.: 06-1632
The Piedmont Triad Airport Authority (PTAA) offers the following responses to comments received
from the U.S. Army Corps of Engineers (USAGE) on January 23, 2007 [comments from the North
Carolina Wildlife Resources Commission (NCWRC) and U.S. Fish and Wildlife Service (USFWS)
dated December 14, 2006] and the North Carolina Department of Environment and Natural Resources
(NCDENR) Division of Water Quality (DWQ) on January 9, 2007 regarding the Individual Permit
application under Sections 404 and 401 of the Clean Water Act for unavoidable impacts to Waters of
the U.S. in conjunction with Runway SR Runway Safety Area (RSA) and Related Improvements at
Piedmont Triad Intemational Airport (PTIA). Comments are restated in italics followed by PTAA
response.
Why was this project not included with the permit application jor FedEx?
(LTSACE,11/28/2006 informal)
The existing, non-standard Runway Safety Area (RSA) configuration at Runway SR (500 feet wide
by 600 feet long, instead of the required SOOx 1000) was granted a "Modification to Standards" firm
the Federal Aviation Administration (FAA) in 1998, primarily due to runway length, fleet mix, and
development cost issues. This constituted the FAA guidance and approval for appropriate operation
of Runway SR with RSA of only 600 feet long for the time period when the Environmental Impact
Statement (EIS) and Section 404 pemmt application were developed for the FedEx project (New
Runway SU23R, Overnight Express Air Cargo Sorting and Distribution Facility, and Associated
Developments). The FedEx Section 404 permit was issued in December 2003, at which time the
FAA Modification to Standards was still effective. Because extending the Runway SR RSA had no
relation to the FedEx project, it was a separate and distinct consideration, and was not added to the
associated project components for the FedEx EIS or 404 permit application. Indeed, inclusion of a
potential RSA improvement project would have been premature (it was not considered until 2005)
and inappropriate (entirely different and unrelated project need and purpose). The Runway SR RSA
project need is based entirely on concern for public safety and driven by FAA requirements.
Mr. John Thomas & Ms. Cyndi Karoly
January 26, 2007
Page 2 of 5
In January 2005, FAA reevaluated the earlier RSA deternunation at PTIA and concluded that it was
practicable for the RSA on Runway SR to be modified to meet standards, perming completion of a
feasibility study, funding, and an environmental assessment (EA). Project funding is dependant on the
outcome of the EA and project conshuction is pending this and receipt of aU appropriate pemrits,
including Section 404 from USACE and Section 401 from DWQ.
"Please submit a complete and comprehensive mitigation plan. Please reference the following link for
guidance in preparingyour mid'rgation plan:
hdn//wwwsaw.usacGarmxmiUwedands/mit~ation/stream mitiration.hbnl
Please be sure m Include all relevant map~c to support your proposed plan You are advised that a 401 Water
Certification cannot bt issued until a complete, approvable mitigation plan is included with your applicaAion"
(DWQ, 01/09/2007)
As stated in the Wetland and Stream Mitigation Plan provided with the permit application, both the
0.6 saes wetland creation and the 1,1231inear feet stream restoration proposed to mitigate the project
impacts are components of the approved mitigation plans for the FedEx project. Both of these
mitigation components were approved by USACE (Action ID 200021655) and DWQ
(Certification 3428) for the FedEx Froject.
The 1,123-linear foot restoration of North Prong Stinking Quarts Creek was constructed in 2004 and
two years subsequent monitoring has indicated success. This excess credit was not applied to the
FedEx project impacts and was approved as credit for potential future PTAA project(s). The 2006
(2"~ year) success Monitoring Report including this mitigation component is due to be submitted prior
to February, 2007.
The Conservation Easement including the 0.6-sae wetland creation at Brush Creek has been recorded
and mitigation construction is scheduled to commence in 2007. This specific 0.6 awes was not
credited in the FedEx permits but is a contiguous extension of the approved FedEx mitigation. Final
mitigation plans and specifications for the 0.6-acre wetland aeation are currently being developed and
scheduled to be submitted to USACE and DWQ for review by June 2007. The project will be
advertised, bids received, and mitigation construction contractor selected prior to August 2007.
Both of these mitigation plan components were summarized, including relevant maps, in the Wetland
and Stream Mitigation Plan submitted with the permit application, in approvable format consistent
with the April 2003 Stream Mitigation Guidelines linked above. Complete comprehensive full-size
plans and specifications for the Causey Farm stream restoration were approved by USACE and DWQ
in 2003 and will be provided for Brush Creek wetland aeation prior to construction this year as noted
above.
Mr. John Thomas & Ms. Cyndi Karoly
January 26, 2007
Page 3 of 5
"PTAA indicates that the proposed impervious surface will not create an increase br the volume of storinwater
reachLtg downstream waters Please submit documentation demonsdwting that all smrmwater runoff from the
proposed impervious surfaces can be treated to Water Supply Wattrsherl; Nutrient Sensitive Waters watershed
and Critical Area watershed requirements under PTAA's Stormwater Management Plan."
(DWQ, 01/09/2007)
The stormwater controls proposed will be treated to applicable requirements to achieve 85% removal
of total suspended solids (TSS) and, under PTAA's Stormwater Management Plan (SWMP), will
prevent post-development peak flows fiom exceedingthepre-development peak for storm events up
to and including the 10-year storm. In this case, a dry detention pond will be constn~cted with
appropriate features to achieve 85% TSS removal. The location and other details concerning the
stormwater controls for the proposed project have not yet been finalized, but no additional wetland or
stream impacts aze proposed. Pre-development hydrographic conditions will be maintained post
project to the extent practicable.
"• Please provide information on the p%lect alternatives considered and the impacts to wetlands and sh cam
channels for each project alternative"
(NCWRC, O1/23/2007)
Detailed analyses of all project alternatives are discussed in the Environmental Assessment (EA) for
this project. Project alternatives considered included use of other modes of transportation, use of other
existing airports, use of smaller aircraft, a no-action alterative, and six build alternatives. Of these
alternatives only the six build alternatives would address the purpose and need of the project while
also meeting constructability, environmental, and cost considerations. Build Alternative 1 (relocate
Runway SR threshold 1,134 feet to the northeast and relocate the north end of Runway 23L a distance
of 1,434 feet to match the end of extended Taxiway K) is the applicant's (PTAA) Preferred
Alternarive. Detailed description and analysis of each practicable alternative and corresponding
potential impact to jurisdictional wetlands and/or stream channels is provided in the EA. Each of the
build alternatives addressing project purpose and need would result in the same impacts to wetlands
and stream channel.
NCWRC comments (Bryant, 06/12/2006) addressing the EA scoping document for this project have
been incorporated into the project to the extent practicable and are addressed fully in the EA.
"• Please provide information on whether additional impacts m wetlands and strewn channels are anticipated
as a result of other p%/eet rnmponents detailed in the scoping document (msg., relocatwn oja portion of Old
Oak Ridge Road"
(NCWRC, 01/23/2007)
No other component of the preferred alternative, including the relocation of a portion of Old Oak
Ridge Road, will result in additional impacts to jurisdictional wetlands or stream channels.
"1. We recommend the maintenance or establishment of a minimum IOU-foot native forested bu,Q`er along
each side ofpertnnial streams and SO-foot native forested buffer along each side of intermittent streams and
wetlands Maintaining undiskcrbed forested bu,B'ers along these areas will minimize impacts m aquatic and
terresbtial wildhje resources, water quality, and aquatic habitat both within and downstream of the project erica.
Mr. John Thomas & Ms. Cyndi Karoly
January 26, 2007
Page4of5
In addition, wide rl parian bu~'ers are helpful in niainAoining stability of strewn banks and for treabnent of
pollutants associated with storm water runoff. Whereas, a gtw.csed bu,~'er, particularly fescue, is a vegetated
bu,,Q'er but will notprovidi the necessary and highly voluabk functions as discussed for forested bu,Qers."
(NCWRC, 01/23/2007)
100-foot wide vegetated buffers are required on all streams identified on the U.S. Geological Survey
7.5-minute topographic quadrangles by PTAA's Water Supply Watershed rule for the Brush Creek
and Horsepen Creek watersheds. The remaining portions of PTIA are located in the East Fork Deep
River watershed and are subject to Randleman Rule stream buffer protection. The entire airport is
therefore subject riparian buffer protection.
" 2. We recommend that all remauting wetlands and screams on the site should be protected from additional
impacts by placutg them do a permanent eonservabon easement to prohibitftlldn~ draining, floodutg, and
excavation."
(NCWRC, 01/23/2007)
All remaining wetlands and streams are already protected in dedicated conservation easements to the
extent practicable. These permanent easements were recorded as permit conditions of the "FedEx"
project (USAGE Action ID 200021655, DWQ Certification 3428).
" 3. Use bridges for all permanent roadway crossings ojscreams and associated wetlands to eliminate the need
to fill and culvert where practicable If culverts must be used, the culvent should be designed to allow passage
of aquatic organisms Generally, this means that the culvert or pipe invert is buried at least one foot below the
natural sd eambed Ijmuhfple cells are required, the second and/or thud cells should be placed so that their
bottoms are at stream bankjull stags This will allow su,,~rcient water depth do the culvert or pipe during
normal Jlows to accommodate movements of aquatic organisms If culverts are long and su~teient slops exists,
ba,,~?e systems are recommended ta trap gravel and provide resting areas for fish and other aquatic organisms
If muhliple pipes or cells are used, at least one pqx or box should be designed to remain dry during norneal
flows to allow for wildlife passages In addition, culverts or pipes should be situated so that no channel
realignment or widening is required Widening ojthe stream channel at the inlet or outlet of sb~uctures usually
causes a decease in water velocity causing sediment deposition that will require future maintenance. Finally,
riprap should not be placed on the streambed"
(NCWRC, 01/23/2007)
Appropriate consideration has been given to use of bridges, passage of aquatic organisms, wildlife
passage, channel widening/realignment, and future maintenance, during project planning. This project
necessitates filling the hemwaters of a stream such that wildlife and aquatic passage is not applicable.'
Further, FAA aircraft safety regulations preclude encouragement of wildlife passage through RSA.
Riprap will not be placed on the streambed, downstream from the proposed impacts.
"~ Stotmwater management should be unplemented so that the pre-development hydrographie conditions are
maintained to the maximum exxent possible: Multiple studies have shown that stream degradation occurs at
appra~rimately ]0% coverage by unpervious surfaces"
(NCWRC, 01/2312007)
See response to DWQ's second comment.
Mr. John Thomas & Ms. Cyndi Karoly
January 26, 2007
Page 5 of 5
"S. Specialized ejfortc and techniques should be bnplemented to reduce sediment runo,Q from construction
activiAies Excessive silt and sediment loads can have numerous dedrmentirl e,,Q'ects on aquatic resources
including destruction of spawning habitat, suffocation of eggs, and clogging of gills of aquatic species"
(NCWRC, 01/23/2007)
Prior to the commencement of construction, a Sedimentation and Erosion Control Plan for the project
will be submitted to NCDENR, and PTAA will obtain a Sedimentation and Erosion Control Pernut
and an accompanying National Pollutant Discharge Elimination System (NPDES) Construction
Pernut. Potential impacts to surface water quality as a result of the Build Alternative construction
activities will be effectively mitigated through adherence to the approved Sedimentation and Erosion
Control Plan and to the permit requirements, as well as through compliance with
FAA AC 150/5370-1OB.
"In order to a,,8'ect fish and wildlife conservation and to fulfrU the public trust stewardship obligations in this
matter, the Service recommends that the proposed wetland and stream mitigation be required in the 404 permit,
and that aggressive erosion and sediment control plans be developed and incorporated into any permit to
protect aquatic life and protect the natural integrity of the remaining streams and to protect downstream water
quality. Also, any remaining xvethrnds and streams on the site should be placed under permanent protective
instruments for the life of the project"
(LJSFWS, Ol/23/2007)
See response to NCWRC Comment 5, above and NCWRC Comment 2.
We understand that no further comments were received in response to the Public Notice. We
appreciate your consideration of this request for Individual Permit. Please feel free to contact me or
Richard Darling with Baker and Associates at 336-931-1500 with any questions or comments.
Sincerely,
cc: Daryl Lamb, DWQ Winston-Salem Regional Office
Richard Darling, Baker and Associates
David Alberts, URS Corporation
1110. f0.431gvIdDOCUt~lU1S1104066 - GSO Flogram NfarregemerA1003-000000022 (401 401)Vt~iMeY 5R23f- RSAUPApp.dnc
JCA/RBD/LJA/KJB/MLE:rbd
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PIEDMONT TRIAD
A111P0RT AUTHORITY
January 26, 2007
U.S. Army Corps of Engineers,
Wilmington District,
Raleigh Regulatory Field Office
6508 Falls of the Neuse Road, Suite 120
Raleigh, NC 27615
North Carolina Department of Environment
and Natural Resources, Division of Water
Quality, 401 Oversight Unit
2321 Crabtree Boulevard, Suite 250
Raleigh, NC 27604
Attention: Mr. John Thomas Ms. Cyndi Karoly
Subject: Application for Section 404 Permit for Runway SR Safety Area and Related
Lnprovements at Piedmont Triad International Airport, Greensboro, NC
Corps Action ID #: SAW 2006 41354241
DWQ Project No.: 06-1632
The Piedmont Triad Airport Authority (PTAA) offers the following responses to comments received
from the U.S. Army Corps of Engineers (USAGE) on January 23, 2007 [comments from the North
Carolina Wildlife Resources Commission (NCWRC) and U.S. Fish and Wildlife Service (USFWS)
dated December 14, 2006] and the North Carolina Department of Environment and Natural Resources
(NCDENR) Division of Water Quality (DWQ) on January 9, 2007 regarding the Individual Permit
application under Sections 404 and 401 of the Clean Water Act for unavoidable impacts to Waters of
the U.S. in conjunction with Runway SR Runway Safety Area (RSA) and Related Improvements at
Piedmont Triad International Airport (PTIA). Comments are restated in italics followed by PTAA
response.
Why was this project not included with the permit application for FedExP
(USAGE, 11/28/2006 informal)
The existing, non-standard Runway Safety Area (RSA) configuration at Runway SR (500 feet wide
by 600 feet long, instead of the required SOOx 1000) was granted a "Modification to Standards" from
the Federal Aviation Administration (FAA) in 1998, primarily due to runway length, fleet mix, and
development cost issues. This constituted the FAA guidance and approval for appropriate operation
of Runway SR with RSA of only 600 feet long for the time period when the Environmental impact
Statement (EIS) and Section 404 permit application were developed for the FedEx project (New
Runway SU23R, Overnight Express Air Cargo Sorting and Distribution Facility, and Associated
Developments). The FedEx Section 404 permit was issued in December 2003, at which time the
FAA Modification to Standards was still effective. Because extending the Runway SR RSA had no
relation to the FedEx project, it was a separate and distinct consideration, and was not added to the
associated project components for the FedEx EIS or 404 permit application. Indeed, inclusion of a
potential RSA improvement project would have been premature (it was not considered until 2005)
and inappropriate (entirely different and unrelated project need and purpose). The Runway SR RSA
project need is based entirely on concern for public safety and driven by FAA requirements.
Mr. John Thomas & Ms. Cyndi Karoly
January 26, 2007
Page 2 of 5
In January 2005, FAA reevaluated the earlier RSA determination at PTIA and concluded that it was
practicable for the RSA on Runway SR to be modified to meet standards, pending completion of a
feasibility study, funding, and an environmental assessment (EA). Project funding is dependant on the
outcome of the EA and project construction is pending this and receipt of all appropriate pernuts,
including Section 404 from USACE and Section 401 from DWQ.
"Please submit a complete and comprehensive mitigation plan. Please rejerenee the following link for
guidance in P~Paring your mitigation plan:
hun://www saw usac~arnrvmilhvedands/miti¢ation/stream mitiration.hbnl
Please be sure to include all relevant maps b support your proposed plan. You are advised that a 401 Water
Certification cannot be issued until a complete, approvable mitigationplan is included with your application."
(DWQ, 01/09/2007)
As stated in the Wetland and Stream Mitigation Plan provided with the permit application, both the
0.6 acres wetland creation and the 1,123 linear feet stream restoration proposed to mitigate the project
impacts are components of the approved mitigation plans for the FedEx project. Both of these
mitigation components were approved by USACE (Action ID 200021655) and DWQ
(Certification 3428) for the FedEx Project.
The 1,123-linear foot restoration ofNorth Prong Stinking Quarter Creek was constructed in 2004 and
two years subsequent monitoring has indicated success. This excess credit was not applied to the
FedEx project impacts and was approved as credit for potential future PTAA project(s). The 2006
(2~ year) success Monitoring Report including this mitigation component is due to be submitted prior
to February, 2007.
The Conservation Easement including the 0.6-acre wetland creation at Brush Creek has been recorded
and mitigation conshudion is scheduled to commence in 2007. This specific 0.6 acres was not
credited in the FedEx permits but is a contiguous extension of the approved FedEx mitigation. Final
mitigation plans and specifications for the 0.6-acre wetland creation are currently being developed and
scheduled to be submitted to USACE and DWQ for review by June 2007. The project will be
advertised, bids received, and mitigation construction contractor selected prior to August 2007.
Both of these mitigation plan components were summarized, including relevant maps, in the Wetland
and Stream Mitigation Plan submitted with the permit application, in approvable format consistent
with the Apri12003 Stream Mitigation Guidelines linked above. Complete comprehensive full-size
plans and specifications for the Causey Farm stream restoration were approved by USACE and DWQ
in 2003 and will be provided for Brush Creek wetland creation prior to construction this year as noted
above.
Mr. John Thomas & Ms. Cyndi Karoly
January 26, 2007
Page 3 of 5
"PTAA indicotes that the proposed hnpervioWS surface will not create an increase in the vohune of storinwater
reaching downstream waters. Please submit documentation demonstrating that all stormwater runo,,~''from the
proposed impervious surfaces can be treated to Water Supply Watershed, Nutrient Sensitive Waters watershed
and Critical Arta watershed requirements under PTAA's Stormwater Management Plan."
(DWQ, Ol/09/200'n
The stormwater controls proposed will be treated to applicable requirements to achieve 85% removal
of total suspended solids (TSS) and, under PTAA's Stormwater Management Plan (SWMP), will
prevent post-development peak flows from exceeding the pre-development peak for storm events up
to and including the 10-year storm. In this case, a dry detention pond will be constricted with
appropriate features to achieve 85% TSS removal. The location and other details concerning the
stormwater controls for the proposed project have not yet been finalized, but no additional wetland or
stream impacts are proposed. Pre-development hydrographic conditions will be maintained post
project to the extent practicable.
"• Please provide information on the project ahernatlves rnnsidered and the impacts to wetlands and stream
channels for each project ahernativa"
(NCWRC, 01/23/2007)
Detailed analyses of ail project alternatives are discussed in the Environmental Assessment (EA) for
this project. Project alternatives considered included use of other modes of transportation, use of other
existing airports, use of smaller aircraft, a no-action alterative, and six build alternatives. Of these
alternatives only the six build alternatives would address the purpose and need of the project while
also meeting constructability, environmental, and cost considerations. Build Alternative 1(relocate
Runway SR threshold 1,134 feet to the northeast and relocate the north end of Runway 23L a distance
of 1,434 feet to match the end of extended Taxiway K) is the applicant's (PTAA) Preferred
Alternative. Detailed description and analysis of each practicable alternative and cornesponding
potential impact to jurisdictional wetlands and/or stream channels is provided in the EA. Each of the
build alternatives addressing project purpose and need would result in the same impacts to wetlands
and stream channel.
NCWRC comments (Bryant, 06/12/2006) addressing the EA scoping document for this project have
been incorporated into the project to the extent practicable and are addressed fully in the EA.
"• Please provide information on whether additional impacts m wetlands and stream channels are anticipated
as a result of other project components detailed in the scoping document (ag., relocation of a portion of Old
Oak Ridge Road)."
(NCWRC, Ol/23/200'n
No other component of the preferred alternative, including the relocation of a portion of Old Oak
Ridge Road, will result in additional impacts to jurisdictional wetlands or stream channels.
"1. We recommend the maintenance or establishment oja minimum 100-foot native forested bu,(jer along
each side of perennial streams and SO-foot native forested bujJ'er along each side of intermittent streams and
wetlands Maintaining undisturbed forested bu.,~`ers along these areas wiU minimize impacts to aquadc and
terrestrial wildlife resources, water quality, and aquatic habitat both within and downstream of the project area.
Mr. John Thomas & Ms. Cyndi Karoly
January 26, 2007
Page 4 of 5
In addrtion, wide riparian bu,,~'ers are helpful in maintaining stability of stream banks and jar treabnent of
pollutants associated with smrm water runoff: W/rtreag a grossed bu,(~'er, particularly fescue, is a vegetated
bu,Qer but will notprovide the naessary and highly valuable functions as discussed jar jor~sted bu,,Q'ers."
(NCWRC, 01/23/2007)
100-foot wide vegetated buffers are required on ail streams identified on the U.S. Geological Survey
7.5-minute topographic quadrangles by PTAA's Water Supply Watershed rule for the Brush Creek
and Horsepen Creek watersheds. The remaining portions of PTIA are located in the East Fork Deep
River watershed and are subject to Randleman Rule stream buffer protection. The entire airport is
therefore subject riparian buffer protection.
"2 We recommend that all remaining wetlands and sdeams on the site should be protected from additional
impacts by placing them in a permanent conservation easement m prohibit filling draining, jbodin~ and
excamdotr."
(NCWRC, 01 /23/2007)
All remaining wetlands and streams are already protected in dedicated conservation easements to the
extent practicable. These permanent easements were recorded as permit wnditions of the "FedEx"
project (USAGE Action ID 200021655, DWQ Certification 3428).
" 3. Use bridges for aQ permanent roadway crossings of streams and associated wetiands to eliminate the need
to fill and culvert wherepracticable If culverts must be used the culvert should be designed to allowpassage
of aquatic organisms Generally, uric means that the culvert or pipe invert le buried at least one foot below the
nahtral str+eambed If multiple eeAs are required, the second and/or third cells should be placed so that their
bottoms are at stream bankfuU stage 77ris will allow su,,~'iclent water depth in the advert or pipe during
normal flows to accommodate movements ojaquatic organisms If culverts are long and su,,()'iclent slope exists,
bagle systems are recommended m dap gravel and provide resting areas jorfish and other aquatic organisms
If mulb'ple pipes or cells are used, at least ant pq~e or bax should be designed ta remain dry during normal
flows to allow for wildlife passages In addition, culverts or pipes should be situated so that no channel
realignment or widening is regnirtid Widening of the sdeam channel at the Wet or outlet ojsductures asually
causes a decrease in water velocity causing sediment deposition that will require future maintenances Finally,
riprap should not be placed on the sdeambed"
(NCWRC, 01/23/2007)
Appropriate consideration has been given to use of bridges, passage of aquatic organisms, wildlife
passage, channel widening/realignment, and future maintenance, during project planning. This project
necessitates filling the headwaters of a stream such that wildlife and aquatic passage is not applicable.
Further, FAA aircraft safety regulations preclude encouragement of wildlife passage through RSA.
Riprap will not be placed on the streambed, downstream from the proposed impacts.
"~ Stormwater management should be implemented so that the pre-development hydrographic conditions are
maintained to the maximum extent possible Multiple studies have shown that sdeam degradation occurs at
approximately 10'/ coverage by impervious surfaces"
(NCWRC, 01/23/2007)
See response to DWQ's second comment.
Mr. John Thomas & Ms. Cyndi Karoly
January 26, 2007
Page 5 of 5
"S. Specialized efforts and techniques should be pnphrynented to reduce sediment runo,,~`jrom consductwn
actinides, Excessive silt and sediment loads can have numerous detrimental t,~'ects on aquadc resources
including desduction of spawning habitat' suffocation of eggs, and clogging ofgdls ojaquatic species"
(NCWRC, 01/23/2007)
Prior to the commencement of construction, a Sedimentation and Erosion Control Plan for the project
will be submitted to NCDENR, and PTAA will obtain a Sedimentation and Erosion Control Permit
and an accompanying National Pollutant Discharge Elimination System (NPDES) Construction
Permit. Potential impacts to surface water quality as a result of the Build Alternative construction
activities will be effectively mitigated through adherence to the approved Sedimentation and Erosion
Control Plan and to the permit requirements, as well as through compliance with
FAA AC 150/5370-1 OB.
`7n order to a.Qect fish and wildlife conservation and to fulJlll the public dust stewardship obligations in this
matter, the Service recommends that the proposed wetland and sdeam mitigation be required in the 404 permit,
and that aggressive erosion and sediment control plans be developed and incorporated into any permit m
protect aquatic life and protect the natural integrity of the remaining sdeams and to protect downsdeam water
quality. Also, any remaining wetlands and streams on the site should be placed under permanent protective
insduments for the life of the project"
(USFWS, 01/23/2007)
See response to NCWRC Comment 5, above and NCWRC Comment 2.
We understand that no further comments were received in response to the Public Notice. We
appreciate your consideration of this request for Individual Permit. Please feel free to contact me or
Richard Darling with Baker and Associates at 336-931-1500 with any questions or comments.
Sincerely,
cc: Daryl Lamb, DWQ Winston-Salem Regional Office
Richard Dazling, Baker and Associates
David Alberts, URS Corporation
1110.10.43 i1~o121000(/A~NTSIf0406B - GSO Rogam blarragernen110 03-00 0 0 00022 (401 401)IRirmay ~~ RSAVPApp.doc
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