20191081 Ver 1_USACE Request for More Info and Public Comments_20191016

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
October 16, 2019
Regulatory Division
Action ID: SAW-2017-00103
Mr. J. Alex Rosser, P.E.
Piedmont Triad Airport Authority
1000A Ted Johnson Parkway
Greensboro, North Carolina 27409
Dear Mr. Rosser:
Please reference your Individual Permit application for Department of the Array (DA)
authorization to permanently discharge dredged or fill material into 383 linear feet of stream
chamiel, 0.08 acre of wetlands, and 1.72 acres of open water, and temporarily discharge dredged
or fill material into 0.02 acre of wetlands, associated with the relocation of existing rental car
facilities in order to eliminate a "line -of -sight" issue for a proposed air traffic control tower at the
Piedmont Triad International Airport (GSO), in Greensboro, in Guilford County, North Carolina.
The U.S. Army Corps of Engineers, Wilmington District (Corps) advertised your proposal by
public notice dated August 21, 2019. Comments in response to the notice were received from
agencies including the North Carolina Division of Water Resources (NCDWR), North Carolina
Department of Natural and Cultural Resources (NCDNCR), North Carolina Wildlife Resources
Commission (NCWRC), United States Fish and Wildlife Service (USFWS), and United States
National Marine Fisheries Service (NMFS), as well as from nearby residents Mr. Andy Bullard
and Ms. Melanie Rice Peters. The comments received are enclosed for your information and to
provide you with the opportunity to address any of the stated concerns.
Please provide written responses to comments la-d through 5 from the NCDWR and the
concerns raised by Mr. Bullard. Please note that the NCDNCR, in a letter dated September 6,
2019, stated that they are aware of no historic resources which would be affected by the project,
and therefore have no comment on the project as proposed. The NCWRC, in an email dated
September 20, 2019, stated that they had no comments about the proposed project. The USFWS,
in a letter dated September 17, 2019, stated that the action is not likely to adversely affect
federally listed species or their critical habitat. Furthermore, the NMFS, in a letter dated August
22, 2019, stated that the proposed project would not occur in the vicinity of essential fish habitat
(EFH) designated by the South Atlantic Fishery Management Council, Mid -Atlantic Fishery
Management Council, or the NMFS, and that they are neither supportive of nor in opposition to
authorization of the proposed work.

Further, 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 CIean 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.
i. The Corps is very concerned that the proposed stream impacts for the future
aerospace development and relocation of Worldwide Drive appear to be
primarily justified as "the most efficient solution for earthwork required to
eliminate the Taxiway E visibility issue." Upland alternatives for disposal
areas for earthwork related to the line -of -site grading are presumed to exist
due to numerous areas of available uplands on or adjacent to PTIA property,
even if those alternative locations increase the cost of the project. It may be
difficult to show that upland disposal of the above referenced earthwork is not
practicable. As such, it may be beneficial for you to evaluate this phase of the
proposed project from a different purpose;
ii. See also comments 1 a-d and 2 in NCDWR public notice comments;
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.
i. Quantify potential indirect impacts to streams and wetlands, specifically
streams SBA and SB and wetlands WB I and WD2 due to proposed fill slope
impacts and resulting loss of drainage area/hydrology source. Provide also the
method by which you quantified these impacts. Note that compensatory
mitigation will be required for such impacts resulting in a loss of hydrology
and therefore aquatic function, typically at a 2:1 ratio unless otherwise
justified based on resource quality (NCWAM/NCSAM).
ii. See also comments 4 and S in NCDWR public notice comments;
-2-

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.
i. The Corps will evaluate the NCWAM form for wetland WD4 as project
evaluation proceeds to determine if your proposed compensatory mitigation
ratio is acceptable for this resource;
ii. Please note that evaluation of responses to item B.i above may affect
compensatory mitigation requirements.
Additionally, the following items must be resolved prior to continuing to process your permit
request:
1) Please copy the Corps on your response to NCDWR's Request for Additional
Information letter dated September 19, 2019;
2) Please note that responses to the questions above may prompt additional information
requests to allow full evaluation of the proposed project.
The above 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.Baile 2 usace.arm .mil.
Sincerely,
David E. Bailey, Regulatory Project Manager
Raleigh Regulatory Field Office
Enclosures
Copies Furnished w/enclosures:
Mr. Richard Darling
Michael Baker International
200 Centreport Drive, Suite 350
Greensboro, North Carolina 27409

Copies Furnished w/o enclosures;
Mr. Todd Bowers
Permit Review Specialist
Wetlands Regulatory Section
U.S. Environmental Protection Agency - Region IV
Sam Nunn Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303
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
K,S

ROY COOPER
Gnverhor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quoury
September 19, 2019
Corps Action ID# SAW-2017-00103
DWR# 20191081
Guilford County
David Bailey
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Subject Project: GSO Rental Car Facilities Relocation
Dear Mr. Bailey:
On behalf of the NC Division of Water Resources, we respectfully request that you consider the
following comments within your review of the 404 Individual Permit request for the above referenced
property:
The Applicant states that the "Proposed Action" is to resolve visibility obstruction issues as
determined by the FAA. The applicant indicates that there are four key components of the
project. The Division offers the following comments regarding the key components of the
Proposed Action:
The application states that one component of this project is "site preparation of
approximately 44 acres of approved [emphasis added] future aerospace development".
The 404 and 401 approvals for the future aerospace development have expired and were
specific to the project proposed (FedEx) at that time. Any development of this location
should be reviewed as a "new" project and follow standard 404/401 permitting procedures
for purpose and need, alternatives analysis, and avoidance and minimization as part of this
application.
The Applicant indicates that grading will occur for construction and continuation of utilities
along the Proposed Worldwide Drive right-of-way. The 404 and 401 approvals for
Worldwide Drive have expired and were specific to the project proposed (FedEx) at that
time. Worldwide Drive should be reviewed as a "new" project and follow standard
D North Carolina Depart meni of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Ralrigh, North Carolina 7.7699 1617
q 19.707.9000

Corps Action ID# SAW-2017-00103
DWR# 20191081
Page 2 of 3
404/401 permitting procedures for purpose and need, alternatives analysis, and avoidance
and minimization as part of this application.
c. The application indicates that excess earth from the car rental facilities relocation project
must be moved to the nearest appropriate respective locations for project efficiencies and
cost savings. The Division proposes that excess earth disposal into jurisdictional waters is
not justified in order to meet the FAA visibility obstruction issues.
d. The applicant states that "The Proposed Action, including all components, must not
interfere with aviation or economic development specific to GSO". The Division questions
whether interference with economic development justifies a project purpose under Section
404 of the Clean Water Act.
The Division has concerns regarding the statement "The use of fill material for site preparation
on airport sites that may be recovered in the future for airport -related development is an
efficient use of resources and minimizes earthwork, hauling, and associate environmental
impacts from repeated use of heavy equipment and vehicles". Specifically, the Division is
concerned regarding the use of the word "may" and whether the proposed aerospace
development is speculative in nature and that the applicant is relying on the cost reductions and
improved logistics for the car rental facility relocation to justify the future aerospace
development project rather than justifying the aerospace development project on its own merit.
If cost reduction and logistics are to be used as justification for these impacts the Division
recommends that specific data be provided to support the justification. The applicant states
that "avoiding development of this site now with simply be postponing a significant element of
PTAA's mission...". The Division requests that the USACE consider the temporal environmental
consequences that would be realized should impacts be approved for a "future" development
that "may" occur.
Further analysis of the Proposed Project and final determination of the project Purpose and
Need may warrant a further review of, or updates to, the Alternatives Analysis that has been
provided within the application.
4. The Division has concerns that there will be indirect hydrological impacts to Stream SB as a
result of the loss of drainage area/hydrology source and the proposed locations of the
stormwater control measure outlets.
5. The Division has concerns that there will be indirect hydrological impacts to the stream within
the Brush Creek Conservation Area that is downslope of the future aerospace development and
Worldwide Dr impacts as a result of loss of drainage area/hydrology source and the proposed
treatment of stormwater through previously constructed pond F-1.
6. The Division has requested additional technical information from the applicant (attached) and requests
that the USACE review and consider the applicant's response prior to issuing any authorizations for this
project.

Corps Action ID# SAW-2017-00103
DWR# 20191081
Page 3 of 3
Thank you for your considering the Division's comments during your review of this Individual Permit. If
you have any questions, please contact Sue Homewood at 336-776-9693 or
[e-mail].
Sincerely,
Mac Haupt, Acting Supervisor
401 & Buffer Permitting Unit
cc. Richard Darling, Michael Baker International (via email)
Olivia Munzer, NCWRC (via email)
DWR WSRO
DWR —wetlands and Buffer Permitting Branch

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
September 19, 2019
DWR # 20191081
Guilford County
Piedmont Triad Airport Authority
Attn: J. Alex Rosser
1000A Ted Johnson Parkway
Greensboro NC 27409
Subject: REQUEST FOR ADDITIONAL INFORMATION
GSO Rental Car Facilities Relocation
Dear Mr. Rosser:
On August 14, 2019, the Division of Water Resources — Water Quality Programs (Division) received your
application dated July 12, 2019, requesting an Individual Water Quality Certification and Jordan Lake
Buffer Authorization from the Division for your project. The Division has determined that your
application is incomplete and cannot be processed. The application is on -hold until all of the following
information is received:
If the U.S. Army Corps of Engineers requests a response to any comments received as a result of
the Public Notice, please provide the Division with a copy of your response to the USAGE. [15A
NCAC 02H .0502(c)].
2. Please provide detailed site plans at a scale of no smaller than 1"=50' with topographic contours
shown for the future aerospace development and Worldwide Dr. Please locate all wetlands,
streams, and riparian buffers as overlays on the site plan. These drawings must include clear
impact drawings and/or insets that include all permanent fill (fill slopes, road shoulders,
dissipator pads, etc.) and any temporary fill as hatching or color coded. [15A NCAC 02H
,0502(b)]
3. Please provide a detailed engineering plan, profile view, and cross-section of all proposed
culverts. These drawings must include details regarding stream alignment in relation to pipe
alignment, pipe slope, pipe burial, and dissipater pad. [15A NCAC 02H .0502(b)]
4. Please clarify whether the Division of Energy, Mineral and Land Resources will require riprap
within any stream channels or wetlands as part of the Erosion & Sedimentation Control Plan
D — Q- North Carolina Department of Environmental Quality I Dtvision of Water Resources
512 North Saltsbury Street 11617 Mail Service Center I Raleigh. North Carolina 27699 1611
naRn
°�\ r 919.707,9000

Piedmont Triad Airport Authority
DWR## 20191081
Request for Additional Information
Page 2 of 3
approval. If riprap is required, please enumerate and clearly label the temporary and
permanent impacts on the site plan and submit a channel restoration detail. Riprap must be
located below the stream bed elevation. [15A NCAC 02H .0506(f) and (g)]
5. All work must be done "in the dry", therefore, dewatering methods will be necessary to
temporarily dewater the stream channel during pipe installation. Please provide a construction
sequence that details the method of dewatering to be utilized for any proposed culvert
installation and the sequence of construction events to be followed to ensure compliance with
this requirement. In addition, please ensure that the location of the temporary impacts are
shown on the construction drawings and clearly indicated in the revised impact table. [15A
NCAC 02H .0502(b)(3)]
6. Pursuant to 15A NCAC 02H.0506(a) a 401 Water Quality Certification may only be issued upon
determining that existing uses are not removed or degraded by a discharge to classified surface
waters. The application notes that impervious surfaces from the future aerospace development
and Worldwide drive will be treated in Stormwater Pond F-1. Please note that the rerouting of
any drainage area and surface flow has the potential to remove existing hydrology from features
adjacent to this project and therefore remove existing uses of the stream channels or wetlands.
Please provide a detailed hydrologic analysis of indirect impacts to the stream immediately
below these impact areas.
7. Pursuant to 15A NCAC 02H.0506(a) a 401 Water Quality Certification may only be issued upon
determining that existing uses are not removed or degraded by a discharge to classified surface
waters. Based on the information provided in the application and associated documents, the
current drainage area of Stream SB within the New Rental Car Facilities is proposed to be
rerouted through multiple stormwater wet detention basins. Please note that the rerouting of
any drainage area and surface flow has the potential to remove existing hydrology from features
adjacent to this project and therefore remove existing uses of the stream channels or wetlands.
Please provide a detailed hydrologic analysis of indirect impacts to the stream immediately
below theis impact areas.
8. You have indicated that the future aerospace development and worldwide drive meet the
definition of "Airport Facilities" per 15A NCAC 02B .0267 and that the impacts are identified
within the Table of Lases as "Allowable with Mitigation". Please submit a buffer mitigation plan
detailing the amount of buffer impact for zone 1 and/or zone 2 and how the impact will be
mitigated. [15A NCAC 02B .0267]
9. The Division is currently reviewing the Stormwater Management Plan submitted for the New
Rental Car Facilities and will send comments regarding the review by separate document.
Pursuant to Title 15A NCAC 02H .0502(e) and 15A NCAC 02B [Neuse] .0267, the applicant shall furnish all
of the above requested information for the proper consideration of the application. Please respond in
writing within 30 calendar days of receipt of this letter by sending one (1) copy of all of the above

Piedmont Triad Airport Authority
DWR# 20191081
Request for Additional Information
Page 3 of 3
requested information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC
27699-1617 OR by submitting all of the above requested information through this
link: https://edocs.deg,nc.gov/FormsISuppIementaI-Information-Form (note the DWR# requested on
the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be returned. The return of this project will
necessitate reapplication to the Division for approval, including a complete application package and the
appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for this
activity and any work done within waters of the state may be a violation of North Carolina General
Statutes and Administrative Code.
Please contact Sue Homewood at 336-776-9693 or Sue. Homewood(@ncdenr.gov if you have any
questions or concerns.
Sincerely,
Mac Haupt, Acting S pervisor
401 & Buffer Permitting Branch
cc: Richard Darling, Michael Baker International (via email)
David Bailey, USAGE Raleigh Regulatory Field Office (via email)
Olivia Munzer, NCWRC (via email)
Chonticha McDaniel, Stormwater Engineer, 401 & Buffer Permitting Branch (via email)
DWR WSRO 401 files
DWR 401 & Buffer Permitting Unit

btu. STATE,,
North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
September 6, 2019
David Bailey
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Office of Archives and History
Deputy Secretary Kevin Cherry
Re: Relocate Rental Car Facilities, Piedmont Triad International Airport, Greensboro, SAW 2017-00103,
Guilford County, ER 17-0332
Dear Mr. Bailey:
We have received a public notice concerning the above project.
We have conducted a review of the project and are aware of no historic resources which would be affected by
the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-807-6579 or
environmental.reviewgncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,
}✓Ramona Bartos, Deputy
V State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

Bailey, David E CIV USARMY CESAW (USA)
From: Munzer, Olivia <[e-mail]>
Sent: Friday, September 20, 2019 10:33 AM
To: Bailey, David E CIV USARMY CESAW (USA); Homewood, Sue
Subject: [Non-DoD Source] GSO Rental Car Facility IP - PN
Dave,
I don't have really any comments at this time in response to the public notice for this project. Thanks
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Certified Wildlife Biologist
NC Wildlife Resources Commission
Rogers Depot, 1718 NC Hwy 56 West
Creedmoor, NC 27522
Office: 919.707.0364 // Cell: 336.269.0074
[e-mail] <mailto:[e-mail]>
Blockedwww.ncwildlife.org <Blockedhttp://www.ncwildlife.org/>
<Blockedhttp://twitter.com/ncwildlife>
<Blockedhttp://www.facebook.com/pages/NC-Wildlife-Resources-Commission/169986143088699?ref=tn_tmmn>
<Blockedhttp://instagram.com/ncwildlife>
<Blockedhttp://www.youtube.com/user/NCWRC?blend=2&ob=video-mustangbase>
i

Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third
parties

United States Department of the interior
FISH AND D fi_;DI_,IFE SERVICE
Raleigh ES `:,-field Office
Post Office Box 33726
Raleigh, North Carodna 27636-3726
September 17, 2019
David Bailey
U.S. Army Corps of Engineers, Wilmington District
Mitigation Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Re: Piedmont Triad Airport Authority/ SAW-2017-00103/ Guilford County
Dear Mr. Bailey:
The U.S. Fish and Wildlife Service (Service) has reviewed the project advertised in the above
referenced Public Notice. The project, as advertised in the Public Notice, is expected to have
minimal adverse impacts to fish and wildlife resources. Therefore, we have no objection to the
activity as described in the permit application.
In accordance with the Endangered Species Act of1973, as amended, (ESA) and based on the
information provided, and other available information, it appears the action is not likely to adversely
affect federally listed species or their critical habitat as defined by the ESA. We believe that the
requirements of section 7 (a)(2) of the ESA have been satisfied for this project. Please remember
that obligations under the ESA must be reconsidered if: (1) new information identifies impacts of this
action that may affect listed species or critical habitat in a manner not previously considered; (2) this
action is modified in a manner that was not considered in this review; or, (3) a new species is listed
or critical habitat determined that may be affected by the identified action.
For your convenience a list of all federally protected endangered and threatened species in North
C.arollila Is now ava,lai�lc on caul 14ek Sits at ti itiisjfr Nv�t 1.'f�r'�.�i;V��i'alk is:i via',"vYE 7 Node 4u ;ioii:S a
complete and updated list of federally protected species, and a list of federal species of concern
known to occur in each county in North Carolina.
The Service appreciates the opportunity to review and provide comments on. the proposed action.
Should you have any questions regarding the project, please contact Emily Wells at [phone],
extension 25.
_ Sinc IY, r
Pete jamin,
Field Supervisor
cc: NMFS, Beaufort, NC
EPA, Atlanta, GA
WRC, Raleigh

ONITED STATES DEPARTMENT OF COMMERCE
tit„T �A_�4 National Oceanic and Atmospheric Administration
4 ; NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
26313th Avenue South
+�T«� St. Petersburg, Florida 33701-5505
httys:!lwww.fi sheries.noaa.govlreg ionlsoutheast
(Sent via Electronic Mail)
Colonel Robert J. Clark, Commander
USACE Wilmington District
69 Darlington Avenue
Wilmington, North Carolina 28403-1398
Dear Colonel Clark:
August 22, 2019
NOAA's National Marine Fisheries Service (NMFS) reviewed the project described in the public
notice listed below. Based on the information in the public notice, the proposed project would
NOT occur in the vicinity of essential fish habitat (EFH) designated by the South Atlantic
Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS.
Present staffing levels preclude further analysis of the proposed work and no further action is
planned. This position is neither supportive of nor in opposition to authorization of the proposed
work.
Notice No. Applicants(s) Notice Date
SAW-2017-00103 Piedmont Triad Airport August 21, 2019
Authority
Please note these comments do not satisfy consultation responsibilities under section 7 of the
Endangered Species Act of 1973, as amended. If an activity "may effect" listed species or
critical habitat under the purview of the NMFS, please initiate consultation with the Protected
Resources Division at the letterhead address.
Sincerely,
WILBER.THOMAS.
PAYSON.1365820
Digitally signed by
WILBER.THOMAS.PAYSON.136
5820186
Date: 2019.08.22 17:35:39
fdr86-04'00'
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division

Bailey, David E CIV USARMY CESAW (USA)
From: Andy Bullard <[e-mail]>
Sent: Saturday, August 31, 2019 12:00 PM
To: Bailey, David E CIV USARMY CESAW (USA)
Subject: [Non-DoD Source] Opposed to
the plan to put the new car rental service centers and parking lot on Inman Rd across from Cornerstone Baptist Church.
That will be a great problem for the church that has a lot going all during the week with (children's) WEE School,
midweek service, and Sunday services. morning and evening.
Please ponder greatly the problems this might cause!
Andy Bullard
5305 Willow Ridge Dr.
Summerfield, NC

Bailey, David E CIV USARMY CESAW (USA)
From:
mcw mcw <[e-mail]>
Sent:
Thursday, September 19, 2019 9:15 AM
To:
Bailey, David E CIV USARMY CESAW (USA)
Subject:
[Non-DoD Source] a letter about the proposition by the airport authority and the
possible destruction of land on Inman Rd
Attachments:
rough draft for Army Corp1.docx
Mr. David Bailey or whomever it concerns, Hello. My name is Melanie Rice Peters. I read about the proposition by the
airport authority and the possible destruction of land on Inman Road in a local newspaper, and learned I could write in
an opinion concerning it to you. I thank you for your time and your consideration to read my letter and the other letters
surely also sent to you. I have attached it as a file to this email.
Regards,
Melanie

To whomever it Concerns,
I was inspired to speak out and write a letter after I read an article in a local newspaper on
the Airport Authority's proposition to destroy 57 acres of old farmland on Inman Road in order
to relocate the airport's service center and rental parking lot. From what I read, I understand that
the Airport Authority already bought this land, and that the Federal Aviation Administration is
requiring said Authority to demolish the airport's current rental car service facility. Surely
finding this to be a necessity could and should have been avoided. Nevertheless, is it a hopeless
cause now to object to the relocation? I hope not. But even if it is too late for that tract of land, I
trust it is not in vain that I write this letter, for this isn't simply about Inman Road. This is about
defending all the places at risk of being demolished and disregarded for the sake of a rather
shallow definition of "progress".
The article read that this tract of land and the pond on it was largely "unused". Unused?
What exactly does this mean? This inevitably implies what some may see of the land: that it, in
its current state, is useless —at least in comparison to what they wish to do to it. But nothing
could be further from the truth. Even if it isn't put to the use of or under contract of a company, it
is most certainly used. And is useful.The land could be cleared of some briers and put to use in a
way that more people could enjoy it if desired, but it is counter intuitive to tear down the trees
and drain the pond. Even small plots of land can play vital roles in our ecosystem and world —for
both animals and humans. From the perspective of those who live there, putting the airport's
service center and rental parking lot there is nothing short of destructive. Surely anyone who
takes note of nature's importance would agree.
Development is inevitable and necessary, but it can be done in a way that minimizes a
negative impact on the environment. And as development increases, this method becomes more

and more important. In a time when more people have been beginning to see and admit to how
essential protecting the environment is, there is still an astonishing degree of disregard for
actually preserving nature —all for the sake of "efficiency" or "progress". Even a section of land
like the one on Inman road is worthy of respect. Destroying it shows respect for nothing. Don't
we know that the use of an old tree in its habitat is nearly limitless and its value is beyond
words? Don't we know that thousands of creatures already call the land and water home, and that
if their home is drained and bulldozed, they have nowhere to go? Don't we know that nature in
pure form provides for us humans not just joy but countless emotional, physical, mental, and
spiritual benefits so essential to healthy life? Don't we know that saying "oh well" too many
times leaves us with nothing?
The common mentality of "oh well, another piece of our planet is destroyed" is
dangerous. None of us should allow ourselves to fall victim to it, much less someone in a
position to make such heavy decisions. When any company makes a decision, they cannot
always do what is most convenient for them. What if what was most efficient for them in their
specific scenario potentially involved mistreating groups of people? This is rightfully deemed
immoral and therefore inappropriate. Likewise, actions that destroy havens for hundreds of
species and mental health for local people are equally immoral and unacceptable.
I plead whom it concerns, stand up for what matters most.
Thank you,
Melanie Rice Peters