20151065 Ver 1_Scoping Comments_20220419

Carpenter,Kristi
From:Conchilla, Ryan
Sent:Tuesday, April 19, 2022 10:52 AM
To:Aileen Mayhew; [e-mail]; '[e-mail]'; Morales,
Suzette (FHWA); [e-mail]; Homewood, Sue; Wilson, Travis W.
Cc:Ketner, Brian K; Parker, Jerry A
Subject:NCDOT HE-0005: Boom Roadway Access & Connectivity Project - Start of Study
Notification
Attachments:Scoping_HE-0005_WBS 50338_Boom Access_4-19-22.pdf
Aileen,
Good morning. Attached please find the Scoping comments for the proposed project.
Let me know if I can provide further assistance.
Thanks-

Ryan Conchilla, PWS
Environmental Specialist II
401 and Buffer Transportation Permitting Branch (DOT Divisions 7+8)
Division of Water Resources, NC Department of Environmental Quality
[e-mail]

From: Aileen Mayhew <[e-mail]>
Sent: Friday, March 25, 2022 8:27 AM
To: [e-mail]; '[e-mail]' <[e-mail]>; Morales, Suzette (FHWA)
<[e-mail]>; [e-mail]; Conchilla, Ryan <[e-mail]>;
Homewood, Sue <[e-mail]>; Wilson, Travis W. <[e-mail]>
Cc: Ketner, Brian K <[e-mail]>
Subject: \[External\] NCDOT HE-0005: Boom Roadway Access & Connectivity Project - Start of Study Notification

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Dear Agency Representative:

SUBJECT: Notification of start of activities for STIP HE-0005 - Proposed Roadway Access & Connectivity Project at PTI
Airport
NCDOT Highway Division 7 has begun the planning, environmental, and engineering studies for the following project:
STIP No. WBS No. Project Description County Latitude Longitude
Proposed Roadway Improvements to Provide
HE-0005 50338 Access and Connectivity to PTI Property in Guilford 36.119095 -79.951637
Greensboro

1

The proposed project is located at the Piedmont Triad International Airport in Greensboro, Guilford County. Boom
Supersonic selected Greensboro for the first supersonic airliner manufacturing facility. The proposed project includes
roadway improvements to provide access and connectivity to PTI property.
NCDOT would appreciate any information you might have that would be helpful in evaluating potential environmental
impacts of the project. A project location map and study area map are attached. Your comments will be used in the
preparation of a Minimum Criteria Determination Checklist, prepared in accordance with the State Environmental Policy
Act.
Please note that there will be no formal interagency meeting for this project. It is desirable that your agency respond by
April 20, 2022 concerning any beneficial or adverse impacts of the proposed project. If you would like additional time to
provide comments, please let me know.
If you have any questions concerning this project, please contact Brian Ketner, PE, Division 7 Project Engineer, at (336)
487-0075 or [e-mail] or me at [phone] or [e-mail]. Please include the
Project Number (HE-0005 - Boom) in all correspondence and comments.

Thank you,
Aileen

Aileen S. Mayhew, P.E.
Senior Project Planner
D [phone]
[e-mail]

2

ZNc STATE o,A;11,
ROY COOPERC4 _ -'
Governor •
'
ELIZABETH S.BISER I2
Secretary *�f Q NOCW
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
April 19,2022
MEMORANDUM
To: Brian Ketner,PE,NC DOT Division 7 Project Engineer
Aileen S.Mayhew,P.E.,Mott Macdonald, Senior Project Planner
From: Ryan Conchilla,NC Division of Water Resources,Transportation Permitting Branch
Subject: Scoping comments on proposed improvements to:
STIP#HE-0005,WBS#50338
Boom Roadway Access&Connectivity Project at the PTI Airport in Guilford County,NC
Reference your correspondence dated March 25th,2022 in which you requested comments for the referenced project.
Preliminary analysis of the project reveals the potential for multiple impacts to streams and jurisdictional wetlands in
the project area. More specifically,impacts to:
Boom Roadway Access on Regional Road North at the PTI Airport in Guilford County,NC
Stream Name River Basin Stream Stream Index Number 303(d)Listing
Classification(s)
Brush Creek Cape Fear WS-III,NSW 16-11-4-(1) YES
Moores Creek Cape Fear WS-III,NSW 16-11-3 No
Further investigations at a higher resolution should be undertaken to verify the presence of other streams and/or
jurisdictional wetlands in the area. In the event that any jurisdictional areas are identified, the Division of Water
Resources requests that the applicant consider the following environmental issues for the proposed project:
Project Specific Comments:
1. The design plans shall provide treatment of the stormwater runoff through BMPs as detailed in the most
recent version of the North Carolina Department of Transportation Stormwater Program Manual, and the
Stormwater Best Management Practices Toolbox Manual. The BMPs should,to the MEP,be selected and
designed to reduce impacts of the target pollutants of concern(POCs)for the receiving waters.
2. The Brush Creek is class WS-III,NSW;303(d)waters of the State.The Brush Creek is on the 303(d)list for
fair, poor or severe bio-classification. The NCDWR is very concerned with sediment and erosion impacts
that could result from this project.The NCDWR recommends that the most protective sediment and erosion
control BMPs be implemented in accordance with Design Standards in Sensitive Watersheds(15A NCAC
04B .0124)or comparable BMPs to reduce the risk of further impairment to Brush Creek. Post-construction
stormwater BMPs should be selected and designed to the MEP,to reduce target POCs in the 303(d)list for
the receiving waters.
3. As noted during the public involvement process for the development of the adjacent FedEx facility, there
has been,and continues to be,significant public concern regarding water quality and water quantity impacts
to the Brush Creek watershed. The NCDWR recommends that you conduct a careful evaluation of potential

impacts that may cause or contribute to downstream water quality degradation and take all possible measures
to incorporate the highest level of protection to downstream waters
4. Brush Creek and Moores Creek are class WS-III;NSW waters of the State. The NCDWR is very concerned
with sediment and erosion impacts that could result from this project. The NCDWR recommends that highly
protective sediment and erosion control BMPs be implemented to reduce the risk of nutrient runoff to Brush
Creek. Post-construction stormwater BMPs should, to the MEP, be selected and designed to reduce
nutrients. Projects within the Jordan Lake watersheds must implement NCDOT's GREEN Program.
5. On August 27,2012,DWR provided a notification letter to the Piedmont Triad Airport Authority(PTAA),
stating that all 404 and 401 permit applications resulting from development activities conducted within
PTAA's property boundaries(or leased parcels)will be subject to approval by the Division and regulated
by the Jordan Lake Buffer Rules.
This project is within the Jordan Lake Basin.Riparian buffer impacts shall be avoided and minimized to the
greatest extent possible pursuant to 15A NCAC 2B.0267. New development activities located in the
protected 50-foot wide riparian areas within the basin shall be limited to "uses" identified within and
constructed in accordance with 15A NCAC .02B .0295. Buffer mitigation may be required for buffer
impacts resulting from activities classified as"allowable with mitigation"within the"Table of Uses"section
of the Buffer Rules or require a variance under the Buffer Rules.A buffer mitigation plan,including use of
the North Carolina Division of Mitigation Services,must be provided to the NCDWR prior to approval of
the Water Quality Certification. Buffer mitigation may be required for buffer impacts resulting from
activities classified as"allowable with mitigation" within the "Table of Uses" section of the Buffer Rules
or require a variance under the Buffer Rules.A buffer mitigation plan,coordinated with the North Carolina
Division of Mitigation Services,must be provided to the NCDWR prior to approval of the Water Quality
Certification.
On July 27, 2015, NCDENR provided a letter response to Cooke & Cooke, LLP for Water Supply
Watershed Management and Protection Rules of the PTAA. The letter referenced Session Law 2013-395
and 15A NCAC 2B.0267 stating that to the extent the PTAA is subject to the riparian buffer protections of
the Jordan Lake Watershed Rules,a project permitted under Section 404 of the Clean Water Act would be
allowable upon authorization from NCDWR and would not require mitigation under the buffer rule. It was
also recommended that PTAA amend it's Watershed Ordinance to conform to the Jordan Lake requirements
as appropriate.
6. Jordan Lake Basin Diffuse Flow Requirements-Diffuse flow of runoff shall be maintained in the riparian
buffer by dispersing concentrated flow prior to its entry into the buffer and reestablishing vegetation as
follows: 1. Concentrated runoff from new ditches or man-made conveyances shall be converted to diffuse
flow at non-erosive velocities before the runoff enters Zone Two of the riparian buffer;2.Periodic corrective
action to restore diffuse flow shall be taken as necessary and shall be designed to impede the formation of
erosion gullies;and 3. As set out in Sections 7.(D)and 8.(B)of this Ordinance,The Zones of the Riparian
Buffer and Table of Uses respectively, no new stormwater conveyances are allowed through the buffers
except for those specified in the Table of Uses, Section 8.(B) of this Ordinance, addressing stormwater
management ponds,drainage ditches,roadside ditches,and stormwater conveyances.
7. The proposed construction activities should be identified according to the Lake Jordan Basin Table of Uses,
located in Section B,page 12 of the Buffer Ordinance.
8. During the jurisdictional field determination conducted on-site April 5th, 2022, deep channel incision was
observed on several stream features located within the project limits. Additional measures should be taken
to minimize off-site sedimentation and erosion to these jurisdictional stream features.

Transportation General Project Comments:
1. The environmental document should provide a detailed and itemized presentation of the proposed impacts to
wetlands and streams with corresponding mapping. If mitigation is necessary as required by 15A NCAC
2H.0506(h), it is preferable to present a conceptual(if not finalized) mitigation plan with the environmental
documentation. Appropriate mitigation plans will be required prior to issuance of a 401 Water Quality
Certification.
2. Environmental impact statement alternatives shall consider design criteria that reduce the impacts to streams
and wetlands from storm water runoff. These alternatives shall include road designs that allow for treatment of
the storm water runoff through BMPs as detailed in the most recent version of the North Carolina Department
of Transportation Stormwater Best Management Practices Tool box manual, such as grassed swales, buffer
areas,preformed scour holes,retention basins,etc.
3. Prior to an issuance of the 401 Water Quality Certification,the applicant is respectfully reminded that they will
need to demonstrate the avoidance and minimization of impacts to wetlands (and streams) to the maximum
extent practical. In accordance with the Environmental Management Commission's Rules (15A NCAC
2H.0506[h]), mitigation will be required for impacts of greater than 1 acre to wetlands. In the event that
mitigation is required, the mitigation plan shall be designed to replace appropriate lost functions and values.
North Carolina Division of Mitigation Services may be available for assistance with wetland mitigation.
4. In accordance with the Environmental Management Commission's Rules(15A NCAC 2H.0506[h]),mitigation
will be required for impacts of greater than 300 linear feet to any perennial stream. In the event that mitigation
is required, the mitigation plan shall be designed to replace appropriate lost functions and values. The North
Carolina Division of Mitigation Services may be available for assistance with stream mitigation.
5. Future documentation, including the 401 Water Quality Certification Application, shall continue to include an
itemized listing of the proposed wetland and stream impacts with corresponding mapping.
6. The NCDWR is very concerned with sediment and erosion impacts that could result from this project. The
applicant shall address these concerns by describing the potential impacts that may occur to the aquatic
environments and any mitigating factors that would reduce the impacts.
7. An analysis of cumulative and secondary impacts anticipated as a result of this project is required. The type
and detail of analysis shall conform to the NC Division of Water Resource Policy on the assessment of
secondary and cumulative impacts dated April 10,2004.
8. The applicant is respectfully reminded that all impacts, including but not limited to, bridging, fill, excavation
and clearing,and rip rap to jurisdictional wetlands,streams,and riparian buffers need to be included in the final
impact calculations. These impacts,in addition to any construction impacts,temporary or otherwise,also need
to be included as part of the 401 Water Quality Certification Application.
9. Where streams must be crossed,the NCDWR prefers bridges be used in lieu of culverts. However,we realize
that economic considerations often require the use of culverts. Please be advised that culverts should be
countersunk to allow unimpeded passage by fish and other aquatic organisms. Moreover, in areas where high
quality wetlands or streams are impacted,a bridge may prove preferable. When applicable,the applicant should
not install the bridge bents in the creek,to the maximum extent practicable.
10. Whenever possible,the NCDWR prefers spanning structures. Spanning structures usually do not require work
within the stream or grubbing of the streambanks and do not require stream channel realignment. The horizontal
and vertical clearances provided by bridges shall allow for human and wildlife passage beneath the structure.

Fish passage and navigation by canoeists and boaters shall not be blocked. Bridge supports(bents)should not
be placed in the stream when possible.
11. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be directed across the bridge
and pre-treated through site-appropriate means(grassed swales,pre-formed scour holes,vegetated buffers,etc.)
before entering the stream. Please refer to the most recent version of the North Carolina Department of
Transportation Stormwater Best Management Practices Toolbox manual for approved measures.
12. Sediment and erosion control measures should not be placed in wetlands or streams.
13. Borrow/waste areas should avoid wetlands to the maximum extent practical. Impacts to wetlands in
borrow/waste areas will need to be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
14. The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater management. More specifically, stormwater shall not be permitted to discharge directly into
streams or surface waters. Please refer to the most recent version of the North Carolina Department of
Transportation Stormwater Best Management Practices Toolbox manual for approved measures.
15. Based on the information presented in the document, the magnitude of impacts to wetlands and streams may
require a 404 permit application to the Corps of Engineers and corresponding 401 Water Quality Certification.
Please be advised that a 401 Water Quality Certification requires satisfactory protection of water quality to
ensure that water quality standards are met and no wetland or stream uses are lost. Final permit authorization
will require the submittal of a formal application by the applicant and written concurrence from the NCDWR.
Please be aware that any approval will be contingent on appropriate avoidance and minimization of wetland
and stream impacts to the maximum extent practical,the development of an acceptable stormwater management
plan,and the inclusion of appropriate mitigation plans where appropriate.
16. If concrete is used during construction, a dry work area shall be maintained to prevent direct contact between
curing concrete and stream water. Water that inadvertently contacts uncured concrete shall not be discharged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills. Concrete shall be
handled in accordance with the NPDES Construction General Permit NCG010000.
17. If temporary access roads or detours are constructed,the site shall be graded to its preconstruction contours and
elevations. Disturbed areas shall be seeded or mulched to stabilize the soil and appropriate native woody species
shall be planted. When using temporary structures the area shall be cleared but not grubbed. Clearing the area
with chain saws,mowers,bush-hogs,or other mechanized equipment and leaving the stumps and root mat intact
allows the area to re-vegetate naturally and minimizes soil disturbance.
18. Unless otherwise authorized,placement of culverts and other structures in waters and streams shall be placed
below the elevation of the streambed by one foot for all culverts with a diameter greater than 48 inches,and 20
percent of the culvert diameter for culverts having a diameter less than 48 inches,to allow low flow passage of
water and aquatic life. Design and placement of culverts and other structures including temporary erosion
control measures shall not be conducted in a manner that may result in dis-equilibrium of wetlands or
streambeds or banks,adjacent to or upstream and downstream of the above structures.The applicant is required
to provide evidence that the equilibrium is being maintained if requested in writing by the NCDWR. If this
condition is unable to be met due to bedrock or other limiting features encountered during construction,please
contact the NCDWR for guidance on how to proceed and to determine whether or not a permit modification
will be required.
19. If multiple pipes or barrels are required,they shall be designed to mimic natural stream cross section as closely
as possible including pipes or barrels at flood plain elevation, floodplain benches,and/or sills may be required

where appropriate. Widening the stream channel should be avoided. Stream channel widening at the inlet or
outlet end of structures typically decreases water velocity causing sediment deposition that requires increased
maintenance and disrupts aquatic life passage.
20. If foundation test borings are necessary;it shall be noted in the document. Geotechnical work is approved under
General 401 Certification Number 4085/Nationwide Permit No. 6 for Survey Activities.
21. Sediment and erosion control measures sufficient to protect water resources must be implemented and
maintained in accordance with the most recent version of North Carolina Sediment and Erosion Control
Planning and Design Manual and the most recent version of NCS000250.
22. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP measures from
the most current version of the NCDOT Construction and Maintenance Activities manual such as sandbags,
rock berms,cofferdams and other diversion structures shall be used to prevent excavation in flowing water.
23. While the use of National Wetland Inventory (NWI) maps, NC Coastal Region Evaluation of Wetland
Significance(NC-CREWS)maps and soil survey maps are useful tools,their inherent inaccuracies require that
qualified personnel perform onsite wetland delineations prior to permit approval.
24. Heavy equipment should be operated from the bank rather than in stream channels in order to minimize
sedimentation and reduce the likelihood of introducing other pollutants into streams. This equipment shall be
inspected daily and maintained to prevent contamination of surface waters from leaking fuels, lubricants,
hydraulic fluids,or other toxic materials.
25. Riprap shall not be placed in the active thalweg channel or placed in the streambed in a manner that precludes
aquatic life passage. Bioengineering boulders or structures should be properly designed, sized and installed.
26. Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible. Riparian
vegetation must be reestablished within the construction limits of the project by the end of the growing season
following completion of construction.
Thank you for requesting our input at this time. The applicant is reminded that issuance of a 401 Water Quality
Certification requires that appropriate measures be instituted to ensure that water quality standards are met and
designated uses are not degraded or lost. If you have any questions or require additional information,please contact
Ryan Conchilla at [e-mail].
Electronic copy only distribution:
David Bailey,US Army Corps of Engineers,Raleigh Field Office
Jerry Parker,NC DOT Division 7 Environmental Officer
Gary Jordan,USFWS,Fish and Wildlife Biologist