20151065 Ver 1_Corps of Engineer Correspondence_20151228

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Regulatory Division/1200A
Action ID: SAW -2012-01547
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
Mr. J. Alex Rosser
Piedmont Triad Airport Authority
1000-A Ted Johnson Parkway
Greensboro, North Carolina 27409
Dear Mr. Rosser:
December 28, 2015
15--o.0
RECEIVED
N C Dept of ENR
DEC 3 9 2015
Winston-Salem
Regional Office
Please reference your Individual Permit application for Department of the Army (DA)
authorization to permanently discharge fill material into 391 linear feet of stream channel and
5.96 acre of open water habitat (impoundments), associated with constructing access and
infrastructure for Phase I of the Piedmont Triad International Airport (PTIA) Northwest Site
Development, including a cross -field taxiway. The project area is located between the north side
of PTIA/Bryan Boulevard and Pleasant Ridge Road, approximately 0.25 mile east of NC
Highway 68, in Greensboro, in Guilford County, North Carolina.
The U.S. Army Corps of Engineers, Wilmington District (Corps) advertised your proposal by
public notice dated November 18, 2015. Comments in response to the notice were received from
the North Carolina Department of Cultural Resources (NCDCR), North Carolina Wildlife
Resources Commission (NCWRC), and the United States Fish and Wildlife Service (USFWS).
The comments received are enclosed for your information and to provide you with the
opportunity to address any of the stated concerns. Specifically, please provide written responses
to the comments from the NCWRC. Please note that the NCDCR, in a letter dated November 24,
2015, stated that they are aware of no historic resources which would be affected by the project,
and therefore they have no comment on the project as proposed. Also, the USFWS, in a letter
dated December 17, 2015, stated that the action is not likely to adversely affect federally listed
species or their critical habitat, and that they have no objection to the activity as described in the
permit application.
Further, your responses to a Request for Additional Information made by the North Carolina
Division of Water Resources (NCDWR) were received via letter dated December 14, 2015, and
via e-mail on December 21, 2015 and December 22, 2015. This correspondence proposed
increasing the permanent impacts to 394 linear feet of stream channel, and adding a temporary
impact of 45 linear feet of stream channel for construction access and dewatering to the project.

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On February 6, 1990, the Department of the Army (DA) and the U.S. Environmental
Protection Agency (EPA) signed a memorandum of agreement (MOA) establishing procedures
to determine the type and level of mitigation necessary to comply with Clean Water Act (CWA)
Section 404(b)(1) Guidelines. This MOA provides for first, avoiding impacts to waters and
wetlands through the selection of the least damaging, practical alternative; second, taking
appropriate and practical steps to reduce impacts on waters and wetlands; and finally,
compensation for remaining unavoidable impacts to the extent appropriate and practical. To
enable us to process your application, in compliance with the MOA, we request that you provide
the following additional information:
a. Permits for work within wetlands or other special aquatic sites are available only if
the proposed work is the least environmentally damaging, practicable alternative.
Please furnish information regarding any other alternatives, including upland
alternatives, to the work for which you have applied and provide justification that
your selected plan is the least damaging to water or wetland areas.
1) Your permit application, dated October 2, 2015, includes alternative
alignments for the crossfield taxiway, and references alternatives for
future site development described in the Environmental Assessment
prepared by the Federal Aviation Administration (FAA).
b. It is necessary for you to have taken all appropriate and practicable steps to minimize
losses of waters of the U.S., including wetlands. Please indicate all that you have
done, especially regarding development and modification of plans and proposed
construction techniques, to minimize adverse impacts. Specifically:
1) Please provide additional information regarding efforts to avoid and
minimize impacts to waters of the US, including information pertaining to
structure and building pad sizes for the Northwest Site Development Phase
I. Are the proposed conceptual specifications comparable to other similar
aviation -related industrial facilities in the region, and would changes in
building/pad orientation and/or size be practicable and result in
minimization of impacts to waters of the US?
c. The MOA requires that appropriate and practicable mitigation will be required for all
unavoidable adverse impacts remaining after the applicant has employed all
appropriate and practicable minimization. Please indicate your plan to mitigate for the
projected, unavoidable loss of waters or wetlands or provide information as to the
absence of any such appropriate and practicable measures.
1) The Corps has evaluated the compensatory mitigation plan included in
your application. Note that the justification for 1:1 mitigation to impact

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ratio for the intermittent section of stream must be based on functional
quality rather than flow regime alone. As such, please submit a stream
reach functional assessment in the form of a North Carolina Stream
Assessment Method (NCSAM) evaluation per the Corps Wilmington
District Public Notice dated April 21, 2015 (attached).
2) Note that your compensatory mitigation proposal, to use credits from the
Causey Farm mitigation site previously obligated to the PTIA Runway 5R
Safety Area project (Action ID: SAW -2006-41354), is under further
review by the Corps and will be addressed by separate correspondence.
The aforementioned requested information is essential to the expeditious processing of your
application; please forward this information to us within 30 days of your receipt of this letter. If
you have any questions regarding these matters, please contact me at [phone] extension
30 or David. E.Bailey2gusace anny.mil.
Sincerely,
David E. Bailey
Regulatory Project Manager
Raleigh Field Office
Enclosures
Copies furnished with enclosure:
Mr. Richard B. Darling
Michael Baker Engineering, Inc.
8000 Regency Parkway, Suite 600
Cary, North Carolina 27518
Copies furnished without enclosure:
Mr. Todd Bowers
Wetlands Regulatory Section
U.S. Environmental Protection Agency - Region IV
Sam Nunn Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303

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Ms. Karen Higgins
NCDENR — Division of Water Resources
Water Quality Programs
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Ms. Sue Homewood
Division of Water Resources
North Carolina Department of Environment
and Natural Resources
450 W. Hanes Mill Rd, Suite 300
Winston Salem, North Carolina 27105