20071841 Ver 3_Staff Comments_20100623

Division of Water Quality
Asheville Regional Office
Surface Water Protection Section
June 23, 2010
Memorandum
To: Ian McMillan, 401 Coordinator, 401 Oversight and Express Permitting Unit
Through: Edwards, Regional Supervisor, Surface Water Protection Section
Asheville Regional Office
From: Susan A. Wilson, P.E., Environmental Engineer fRegional Office
Subject: Asheville Regional Airport Authority/Cargo Hold Expansion
IP/401 Comments
DWQ#07-1841-v3
Buncombe County
The Asheville Regional Airport Authority proposes to develop an air cargo facility and associated
infrastructure near the southwest corner (Hwy. 280 and Old Fanning Bridge Road) of the airport property.
The proposed stream impact will total 1260 linear feet.
The Asheville Regional Office (ARO) has the following concerns / questions regarding the proposal,
which need to be addressed:
Project Purpose (4.0) - the previous project (2007-1841 v2) had a purpose and need to expand the
airport (and it was stated that the project "will satisfy a portion of the publicly approved 20 year
master plan"). Due to the economic change from 2007, please state again the purpose and need
of the project still in process, and if there have been any changes in purpose to that project (v2),
and why the purpose and need of the proposed project cannot be met at the previously approved
site. (The ARO concern is that there was a stated need for the previous project, which has yet to
be completed, but is mostly grassed such that final construction does not appear to be underway.)
The ARO requested the master plan (or a synopsis of the plan) during the pre-construction
meeting March 9, 2010. ARO does not see this in the submittal. This plan should also give a
time estimate of the completion of the previously approved project (v2). Based on the vigorous
construction at the airport, even during an economic downturn, ARO/DWQ has concerns that the
immediate purpose and need of the project may be not be for immediate growth, but most likely
for the use of immediately available, low/no cost fill material.
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2. Regarding Alternatives Analysis -
a. 6.1.2 B - Can this area be separated from passengers? (in order to be compliant with
FAA regulations (i.e. - Fencing)). Please give the rule reference for this regulation.
b. 6.1.2. D - can the facility be located beyond the planned parallel runway? (since the
access area with the proposed new runway may be available by that time?)
c. 6.1.2. F - The applicant has discussed that road acces does not exist to make this site a
feasible alternative. The supplied plans show a road network parallel to the proposed
secondary taxiway. Further discussion and clarification as to why this site is not feasible
must be submitted.
d. 6.1.2. G - bridging taxi-ways has been completed at other airports - is that a possibility
for this site (west) across from Old Fanning Bridge Road? If this is cost prohibitive,
please demonstrate.
6.1.2. H - as stated in No. 1 above, the purpose and need should be further explained.
3. Mitigation - mitigation must be provided prior to impacts to prevent temporal losses - does EEP
have 1260 linear feet of credits currently available?
4. Regarding Section 404 (b)(1) Code -
a. 8.2.1 - Fly ash fill must also comply with 15A NCAC 2T Waste Not Discharged to
Surface Waters, implemented by the DWQ's Aquifer Protection Section. Please refer to
the letter dated April 21, 2009 to Progress Energy from Jon Risgaard, Aquifer Protection
Section.
b. 8.2.2 - ARO/ DWQ recommends that monitoring be conducted for turbidity and TSS
during all site work (weekly and/or after 0.5 inch storm event).
c. 8.2.3 - again, fly ash fill must also comply with 15A NCAC 2T.
d. 8.4.2 - ARO/ DWQ requires wetlands to be fenced off during proposed site work, as
performed on the previously approved activity.
e. 8.4.6 - mitigation does not address riffle-pool complex instabilities below the culverts
proposed. The applicant should evaluate and mitigate for increased velocities due to
proposed impact. Additionally, since all the streams observed on the west side of the
runway show instability due to unmitigated stormwater discharges, part of this plan
should be for stormwater velocity controls and stream stability work (both inside and
outside the proposed activity area).
Asheville Regional Airport - Cargo Expansion
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5. Public Interest Considerations
a. 9.3 - increase in road traffic and noise must be acknowledged and addressed.
b. 9.4 - use of ash fill and potential groundwater effects should be discussed in this section.
Protective measures (under-drains and liners) should be discussed.
c. 9.5 - wetland protection - specifically incidental fill and maintaining hydrologic
connection should be acknowledged and discussed.
d. 9.7 - potential long term habitat impacts and potential ash impacts should be addressed.
Liner lifespan should be addressed here.
e. 9.8 - please discuss the applicability of a "no rise" certification for the proposed project.
f. 9.9 - increased impervious surface area and its effects on increased hydraulic load should
be discussed. Proposed stormwater measures will address water quality, not necessarily
water quantity. All SW plans must address quantity and discharge rate.
g. 9.10 - please discuss the loss of agricultural land, currently used by NCSU.
h. 9.12 - again, the increased impervious surface effects should be discussed (refer to
comment (f) above).
i. 9.13 - please discuss the potential increase in noise and the effect on the French Broad
River recreation due to the proximity of the proposed project. Also discuss the potential
impact on recreation at the boat launch area.
j. 9.14 - Please discuss the increased water consumption from the site, the water source,
and any nearby water supply wells.
k. 9.18 - again, please discuss the loss of agricultural area (refer to (g)).
1. 9.19 - please discuss minerals that will no longer be available due to the proposed
project.
m. 9.21 - discuss the "needs and welfare of the public" immediately adjacent to the project.
Discuss in more detail how the expansion of the cargo facility will directly benefit the
public.
6. Secondary and Cumulative Effects
a. Please discuss the effects of increased traffic, noise, associated infrastructure in this
section. The effect of increased jobs, etc. should also be discussed.
7. Summary
a. Please provide a projected timeline for completion of the building and facilities.
8. Post Construction Stormwater Plans
a. The Asheville Regional Airport's consultant, AVCON, must provide a full size set of
plans to ARO/DWQ, the City of Asheville, along with a courtesy copy to Mike Randall,
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SWPU (Raleigh). AVCON should refer to the DWQ's BMP manual and provide the
appropriate calculations, drainage area, etc. for each BMP.
An Operation and Maintenance Agreement must also be completed by the applicant.
Please refer to DWQ's website for detailed information:
http://portal.ncdenr.oriz/web/wq/ws/su/bmp-manual
The plans cannot be properly reviewed as currently submitted.
Thank you for the opportunity to comment. Please contact me at [phone] or
[e-mail] should you have any questions regarding this memo.
cc: ARO files
S:\SWP\Buncombe\401s\Non-DOT\AshevilicAirport\AVL Airport Cargo Hold Expansion 07-1841-v3\Memo 6 2010.401 AVL
Cargo Hold.07-1841-v3.doc