20191081 Ver 1__20191011

196PTI
PIEDMONT TRIAD AIRPORT AUTHORITY
October 11, 2019
United States Army Corps of Engineers; Wilmington District
69 Darlington Avenue
Wilmington, NC 28403-1343
Attention: Mr. Scott McLendon
Supervisory Regulatory Project Manager
Subject: Action IDSAW-2017-00103, DWR#20191081, Guilford County NC; Request for
Additional Review Time
The Piedmont Triad Airport Authority (PTAH) has a copy of the "request for additional review time"
From 60 days to 12 months by the Chief of the Water Quality Permitting Section of the North Carolina
Department of Environmental Quality (NCDEQ) Division of Water Resources (DWR) on September 23,
2019. We understand that this request and the specific time period may have been submitted by DWR
due to unknown response to the Public Notice and reluctance to request multiple more specific time
extensions. However, the PTAA. respectfully requests that you not grant the 12 -month time period asked
For by DWR to act on the GSO Rental Car Facilities Relocation (the "Project") Application because this
six -fold increase in review time is well beyond any length of time that would be justified by the
circumstances of the Application.
• Type and Complexity of Proposed Activity. Two of the four key components of the Project as
described in the extension request (Site preparation and stabilization of approximately 49 acres of
developed land to allow line of sight from the Air Traffic Control Tower to Taxiway E and Site
preparation of approximately 28 acres for proposed spoil embankment) involve no jurisdictional
resources. Site preparation of approximately 44 acres of future aerospace development, including
continuation of Worldwide Drive is essentially the same project component permitted under the
FedEx 404/401 certification (SAW -2000-21655, DWR#2000-0846). These three components are
included as "connected projects" to the site preparation of approximately 57 acres of land for
construction of new car rental facilities. All four project components have already been subject to
several meetings and discussions with appropriate regulatory personnel, and numerous specific
site assessments, including an EA/FONSI, have been submitted over the past three years. As
evidenced by the September 19 DWR comments on the 401 application, appropriate regulatory
personnel fully understand all components of the project and Application.
• DWR public notice requirements. It is PTAAs understanding that no significant public comments
were received by the September 20 deadline in the Public Notice of PTAAs permit application.
DWRs review and its response to the limited public comments that were received should not
delay its action on the 401 certification.
•
Magnitude
of potential impacts to aquatic resources. The new rental car facilities will only impact
approximately 0.10 acre of wetlands and 1.72 acres of open water. The stream and related buffer
impacts that would result from the future aerospace development, including continuation of
Worldwide Drive, have already been permitted, and the required mitigation has been completed
(SAW -2000-21655). These impacts are included in the current application due to expiration of that
permit.
1000A Ted Johnson Parkway •Greensboro, North Carolina 27409 •Phone: [phone] •Fax: [phone] www.flyfrompti.com

Mr. Scott McLendon
October 11, 2019
Page 2 of 2
The FAAs construction of the new Air Traffic Control Tower is well underway, with a planned
commissioning of the new ATCT by Spring 2022. The line of sight for the new ATCT must be cleared by
then. PTAA understands DWRs need for a careful consideration of the 401 certification, but it is
critically important to PTAA that the 401 certification review not be delayed unnecessarily.
We appreciate your consideration of this request. Please feel free to contact Mr. Alex Rosser
([e-mail], 336.665.5620) or Mr. Richard Darling ([e-mail], 919.481.5740)
with questions or comments.
Sincerely,
PIEDMONT TRIAD AIRPORT AUTHORITY
Kevin J. Baker, P.E.
Executive Director
RBD/,1AR/WOC/KJB ach
cc: David Bailey, Raleigh Regulatory Field Office (via email)
Todd Bowers, USEPA (via email)
Jeffrey Poupart, Sue Homewood, DWR (via email)
Richard Darling, Michael Baker International (via email)
hftos.//proiecfs. mbakercoro. com/PTIA/404/rime.pd/