20151065 Ver 1_More Info Received_20160201

-AWPTI
PIEDMONT TRIAD AIRPORT AUTHORITY
February 1, 2016
Department of the Army
Wilmington District, Corps of Engineers
69 Darlington Ave.
Wilmington, NC 28403-1343
Attention: Mr. David E. Bailey, Regulatory Project Manager
Raleigh Field Office
Subject: Action ID SAW -2012-01547
Northwest Taxiway Connector at Piedmont Triad International Airport
The Piedmont Triad Airport Authority (PTAA) has received your Request for Additional
Information dated December 28, 2015 and offers the following responses to your comments:
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.
The project, as revised in the permit drawings provided on December 22, 2015, represents the
least environmentally damaging practicable alternative. Information regarding the alternatives
considered is summarized in the Environmental Assessment (EA) and Finding of No
Significant Impact (FONSI) completed by the FAA.
1) Your permit application, dated October 2, 2015, includes alternative alignments for the crossfieldtaxiway,
and references alternatives for future site development described in the Environmental Assessment
prepared by the Federal Aviation Administration (FAA).
PTAA concurs with this statement.
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 ofplans and proposed construction techniques, to minimize adverse impacts. Specifically:
Preliminary site development and taxiway connector plans were presented during scoping for
the EA in June 2013. This original concept was modified significantly over the course of
regulatory and public input to the EA process. The concept presented in the EA was then
further modified during coordination with the North Carolina Department of Environmental
Quality (NCDEQ) Division of Water Resources (DWR) in order to further avoid and minimize
impacts to jurisdictional resources.
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?
1000A Ted Johnson Parkway • Greensboro, Nordi Carolina 27409 . Plione: 336.665.5600 • Fax: [phone]

_..AA4PT1
PIEDMONT TRIAD AIRPORT AUTHORITY
Mr. David E. Bailey
February 1, 2016
Page 2 of 6
Structure and building pad sizes are based on previously specified tenant (FedEx, Honda,
HAECO, and Boeing) expectations. Because these dimensions are based on existing
projects/tenants, they are comparable to other similar aviation -related industrial facilities
in the region. Changes to these project components have been instigated to result in
minimization of impacts to waters of the US. Jurisdictional wetlands and streams at the
site have been completely avoided. Due to the size and orientation of the remaining waters
(golf course ponds), further changes in building/pad orientation and/or size would result in
project dimensions not consistent with the proposed aviation development. Further
reduction in hangar and/or tarmac/apron dimensions would be inconsistent with FAA
airport development constraints.
The development area as shown is similar to other facilities on the airport property in
regards to space requirements and layout. The NW Development area requires taxiway
access, aircraft parking apron, hangar space, office building, and employee parking areas.
When laying out a development space on airport it is important to understand the
limitations of the improvements based on airfield design criteria. Special attention is
required for the three dimensional analysis from an airspace perspective. Runways have
imaginary surfaces that buildings, aircraft, and other stationary items need to remain below.
This development area is quite a distance from the closest runway and thus the vertical
constraints in regards to height limitations are not significant. The challenge with this
facility is existing airfield infrastructure elevations and in particular the bridge over
Interstate Highway I-73.
The proposed NW Taxiway connector must tie into the pavement elevation as constructed
for the I-73 bridge. From that location towards the North and South Campus' the taxiway
profile is limited in grade by FAA criteria. This facility is anticipated to be used by large
aircraft. These aircraft fall into approach category D and Airport Design Group V (ADG
is based on wingspan). A relatively new additional requirement is the Taxiway Design
Group layout (the TDG requirement was implemented by the FAA in September 2012,
TDG is based on the distance between nose gear and main gear). The TDG for most of the
large aircraft is TDG 6.
Thus the profiles, pavement widths, and object clearance widths have to meet D -V criteria.
A summary of the design criteria follows:
1. Taxiway Profile: 1.5% maximum grade.
2. Taxiway Width: 75 feet total width. At taxiway connections width varies to
accommodate aircraft turning.
1 fl00A Ted Johnson Parkway • Greensboro, Nortli Carolina 27409 • Phone: [phone] • Fax: [phone]

-�AePTI
PIEDMONT TRIAD AIRPORT AUTHORITY
Mr. David E. Bailey
February 1, 2016
Page 3 of 6
3. Taxiway Transverse Grades: 1% to 1.5% (see S-1 from Figure 4-35 of FAA
Advisory Circular 150/5300-13A).
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4. Taxiway Paved Shoulder Width: 3 5 feet.
5. Taxiway Paved Shoulder Transverse Grades: 1.5% to 5.0% (S-2).
6. Taxiway Safety Area Width: 214 feet (107 feet from centerline).
7. Taxiway Safety Area Transverse Grades: 1.5% to 3.0% (S-3).
8. Taxiway Object Free Area Width: 320 feet (160 feet from centerline).
9. Taxiway Object Free Area Transverse Grades: 0% to 4:1 (elevation of ground
between TSA and OFA cannot be higher than ground elevation at the TSA limit).
1 OOOA Teel Johnson Parkway 9 Greensboro, North Carolina 27409 • Phone: 336.665,5600 • Fax: 336.665,1425

'agAePTI
PIEDMONT TRIAD AIRPORT AUTHORITY
Mr. David E. Bailey
February 1, 2016
Page 4 of 6
10. Taxiway Width at Intersection: the width varies as the fillets get wider for the aircraft.
The Figures 4-13 and 4-16 show the typical widening required along with the data in
Table 4- 7 for TDG 6.
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From a design perspective, the Taxiway Safety Area (TSA) has the following requirements:
a. Cleared and graded and have no potentially hazardous ruts, humps, depressions,
or other surface variations.
b. Drained by grading or storm sewers to prevent water accumulation.
c. Capable, under dry conditions, of supporting snow removal equipment, aircraft
rescue and firefighting equipment, and the occasional passage of aircraft
without causing structural damage to the aircraft.
d. Be free of objects, except those required for because of their function. Objects
higher than 3 inches above grade must be constructed on Low Impact Resistant
(LIR) supports (frangible mounted structures).
From a design perspective, the Object Free Area (OFA) has similar constraints as above
plus the clearing standards prohibit service vehicle roads, parked aircraft, and other
objects except those required by navigational function. Vehicles may operate in the OFA
provided they pull back and give aircraft the right of way.
1000ATed Johnson Parkway 9 Greensboro, North Carolina 27409 ' Plione: 336.665.5600 • Fax: 336,665,1425
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From a design perspective, the Taxiway Safety Area (TSA) has the following requirements:
a. Cleared and graded and have no potentially hazardous ruts, humps, depressions,
or other surface variations.
b. Drained by grading or storm sewers to prevent water accumulation.
c. Capable, under dry conditions, of supporting snow removal equipment, aircraft
rescue and firefighting equipment, and the occasional passage of aircraft
without causing structural damage to the aircraft.
d. Be free of objects, except those required for because of their function. Objects
higher than 3 inches above grade must be constructed on Low Impact Resistant
(LIR) supports (frangible mounted structures).
From a design perspective, the Object Free Area (OFA) has similar constraints as above
plus the clearing standards prohibit service vehicle roads, parked aircraft, and other
objects except those required by navigational function. Vehicles may operate in the OFA
provided they pull back and give aircraft the right of way.
1000ATed Johnson Parkway 9 Greensboro, North Carolina 27409 ' Plione: 336.665.5600 • Fax: 336,665,1425

/ )1y
PIEDMONT TRIAD AIRPORT AUTHORITY
Mr. David E. Bailey
February 1, 2016
Page 5 of 6
The constraints and requirements listed above were used to develop the layout for the
improvements to the North and South Campuses. Steep slopes of 4:1 beyond the TSA
were used to the extent possible to minimize the area of disturbance and to avoid impact
to environmentally sensitive areas.
On December 14, 2015, PTAA responded to the DWR request of November 16, 2015
with the following items: Regarding culvert design under taxiway — 1) specified riprap
placement at culvert outlet; 2) Provided a construction sequence to ensure culvert
construction work is "in the dry"; 3) Revised sediment and erosion control measures to
keep them outside riparian buffers to the maximum extent practical; and 4) Provided a
buffer restoration plan. Regarding the NW Development area — 1) Revised site plan
hydrology and hydraulics to prevent indirect wetland impacts; and 2) Stormwater
management plan details were added as requested. In addition, on December 22, 2015,
PTAA provided further clarification of the permit drawings in response to the DWR
request of December 21.
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.
There are no direct or indirect, permanent or temporary impacts proposed to any wetlands by
the proposed project. Wetland impacts have been completely avoided through significant
design efforts and project component adjustments. These avoidance measures, along with
efforts to locate all project components outside jurisdictional stream and riparian buffer areas
have necessitated unavoidable impacts to the man-made impoundments upstream of the
jurisdictional stream reaches. These golf -course ponds currently function only as water
features and retain/detain runoff from the active golf course. These current functions will be
replaced by the proposed project stormwater management system designed consistent with
current NCDEQ standards and expected to exceed present water quality treatment
performance.
1) The Corps has evaluated the compensatory mitigation plan included in your application. Note that the
justification for 1:1 mitigation to impact 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).
Based on acceptability of the mitigation (Comment c.2, below) and NCSAM application
scheduled for February 10, 2016; PTAA will revise the mitigation ratio for the intermittent
stream impacts.
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.
Comment noted. PTAA will respond to applicable correspondence when received.
10001 Tecl Johnson Pai kway a Greensboro, North Carolina 27409 • Phone: [phone] • Fax: 336,665.1425

''PT,
PIEDMONT TRIAD AIRPORT AUTHORITY
Mr. David E. Bailey
February 1, 2016
Page 6 of 6
PTAA has addressed recommendations provided by the North Carolina Wildlife Resources
Commission (NCWRC) dated December 11, 2015 in the attached correspondence to Shari Bryant.
We appreciate your continued consideration of this application for Section 404 Individual Permit.
Please feel free to contact me (rossera @gsoair.org, 336.665.5620) or Richard Darling
(rdarling@ bakerintl.com, 919.481.5740) with additional questions or comments.
Sincerely,
PIEDMONT TRIAD AIRPORT AUTHORITY
mj(— ��
J. A ex Rosser, P.E.
Deputy Executive Director
Enclosures: PTAA Response to NCWRC
cc: Todd Bowers; USEPA
Sue Homewood; NCDEQ
Richard Darling; Michael Baker International
1 OOOA Ted Johnson Parkway • Greensboro, North Carolina 27409 • Phone: [phone] • Fax: 335,665.1425

PIEDMONT TRIAD AIRPORT AUTHORITY
February 1, 2016
North Carolina Wildlife Resources Commission
Division of Inland Fisheries
1721 Mail Service Center
Raleigh, NC 27699-1721
Attention: Ms. Shari L. Bryant, Western Piedmont Coordinator
Habitat Conservation Division
Subject: USACE Action ID SAW -2012-01547; DWR File 15-1065
Northwest Taxiway Connector at Piedmont Triad International Airport
The Piedmont Triad Airport Authority (PTAA) has received your Memorandum to the United
States Army Corps of Engineers (USACE) dated December 11, 2015 and offers the following in
response to your recommendations:
1. Maintain a minimum 100 foot undisturbed, native, forested buffer along perennial streams, and a minimum 50 -
foot buffer along intermittent streams and wetlands. Maintaining undisturbed, forested buffers along these
areas will minimize impacts to aquatic and terrestrial wildlife resources, water quality, and aquatic habitat
both within and downstream of the project area. Also, wide riparian buffers are helpful in maintaining stability
of stream banks, for treatment of pollutants associated with urban stormwater, and provide a travel corridor for
wildlife species.
The Water Supply Watershed Management and Protection (WSWMP) Rules of the PTAA
specify 100 -foot riparian protection buffers along all perennial waters throughout the airport..
Application of the PTAA 100 -foot buffer is superseded by the Jordan Water Supply Nutrient
Strategy rules which specify 50 -foot riparian buffers and allow airport facilities within these
buffers.
2. Avoid development and fill in the 100 year floodplain. Development and fill in the floodplain increases the
potential for flooding and interferes with the natural hydrologic process of the waterways. It also disrupts the
continuity of migration corridors for wildlife.
No development or fill in the 100 -year floodplain is proposed for this project.
3. Limit impervious surface to less than 10% or use stormwater control measures to mimic the hydrograph
consistent with an impervious coverage of less than 10%.
Due to the nature of airport development and Federal Aviation Administration (FAA) airport
design requirements (AC 150/5300-13A), impervious surfaces (runways, taxiways, aprons,
etc.) are combined with vast grassed (pervious) in -field areas. PTAA impervious cover is
less than 24% for the entire airport. Stormwater control measures are included for the NW
Development site in order to mimic the pre -development hydrograph.
1©OCA Ted Johnson Parkway • Greensboro, North Carolina 27409 a Phone: [phone] • Fax: 336,665.1425

/P-- 77
PIEDMONT TRIAD AIRPORT AUTHORITY
Ms. Shari L. Bryant
February 1, 2016
Page 2 of 3
4. Use bridges for all permanent roadway crossings of streams and associated wetlands to eliminate the need to
fill and culvert, where practicable. If culverts must be used, the culvert should be designed to allow passage of
aquatic life.
Permanent roadway crossings of streams and wetlands have been avoided for the project.
The proposed Taxiway stream crossing is unavoidable, with impacts minimized and
mitigated as described in the permit application and FAA Environmental Assessment.
5. If sewer lines, water lines, or other utility infrastructure will be installed for the building pads, these should be
kept out of riparian buffer areas. The directional bore (installation of utilities beneath the riverbed, avoiding
impacts to the stream and buffer) stream crossing method should be used for utility crossings wherever
practicable. The open cut stream crossing method should be used only when water level is low and stream flow
is minimal. Maintain a minimum 100 foot setback on perennial streams and a 50 foot setback on intermittent
streams. Pesticides should not be used for maintenance of rights-of-way within 100 feet ofperennial streams
and 50 feet of intermittent streams, or within floodplain and wetlands associated with these streams.
Applicable utility extensions required for the project are included within the proposed project
disturbance area and will not impact additional wetland, stream, or buffer resources.
6. Use landscaping that consists of non-invasive native species and Low Impact Development (LID) technology.
Using native species instead of ornamentals should provide benefits by reducing the need for water, fertilizers,
and pesticides. Using LID technology in landscaping will not only help maintain the predevelopment hydrologic
regime, but also enhance the aesthetic and habitat value of the site.
PTAA is restricted in application of project landscaping by current FAA airport design
regulations. Further, FAA AC 150/5200-33B restricts the application of features with
potential to enhance the habitat value of the site for potentially hazardous wildlife due to
aircraft -wildlife strike potential.
Sediment and erosion control measures should be installedprior 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 andlor 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 that has been reinforced
with plastic or metal mesh should be avoided as it impedes the movement of terrestrial wildlife species. These
measures should be routinely inspected and properly maintained. Excessive silt and sediment loads can have
numerous detrimental effects on aquatic resources including destruction of spawning habitat, suffocation of
eggs, and clogging of gills of aquatic species.
As stated in the Section 404/401 (of the Clean Water Act) permit application, erosion and
sedimentation control measures for the project will be coordinated through the North
Carolina Department of Environmental Quality (NCDEQ). PTAA will obtain the applicable
Erosion and Sedimentation Control Permits and accompanying National Pollutant Discharge
Elimination System (NPDES) Construction Permits. Potential temporary impacts to surface
water quality as a result of construction activities will be effectively mitigated through
adherence to the approved Erosion and Sedimentation Control Plans and to the NPDES
permit requirements, as well as through compliance with FAA AC 150/5370-1013.
10OOATed Johnson Parkway • Greensbom, North Carolina 27409 * Phone: 336,665.5600 & Fax; 336,665.1425

PIEDMONT TRIAD AIRPORT AUTHORITY
Ms. Shari L. Bryant
February 1, 2016
Page 3 of 3
We appreciate your review of the PTAA application for Section 404 Individual Permit. Please
feel free to contact me ([e-mail], 336.665.5620) or Richard Darling
(rdarling_(a,mbakerintl.com, 919.481.5740) with questions or comments regarding your
recommendations.
Sincerely,
PIEDMONT T AD AIRPORT AUTHORITY
J. Dml�'
ex Rosser, P.E.
Deputy Executive Director
RD/AR:rd
cc: David Bailey; USACE
Sue Homewood; NCDEQ
Richard Darling; Michael Baker International
1 OOOATed Johnson Parkway • Greensboro, North Carolina, 27409 * Phone: [phone] a Fax: 336.665,1425