20071841 Ver 3_More Info Letter_20100629

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
June 29, 2010
CERTIFIED MAIL: RETURN RECEIPT REQUESTED
Mr. Lew Bleisweis
Asheville Regional Airport Authority
61 Terminal Drive, Suite 1
Fletcher, NC 28732
Subject Property: Asheville Airport Cargo Hold Expansion
Ut to French Broad River [040302, 6-54.5, B]
REQUEST FOR MORE INFORMATION
Dear Mr. Bleisweis:
DWQ Project # 07-1841, Ver. 3
Buncombe County
On May 3, 2010, the Division of Water Quality (DWQ) received your application dated April 28, 2010, with
Public Notice issued on May 20, 2010, by the USACE, and received by the DWQ on May 20, 2010, to fill or
otherwise impact 1,260 linear feet of stream to construct the proposed level pad at grade with existing
infrastructure at the airport. The DWQ has determined that your application was incomplete and/or provided
inaccurate information as discussed below. The DWQ will require additional information in order to process
your application to impact protected wetlands and/or streams on the subject property. Therefore, unless we
receive five copies of the additional information requested below, we will place this project on hold as
incomplete until we receive this additional information. If we do not receive the requested information, your
project will be formally returned as incomplete. Please provide the following information so that we may
continue to review your project.
Additional Information Requested:
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 concernis
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 have begun.) The Asheville Regional Office
(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.
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
Location: 2321 Crabtree Blvd., Suite 250, Raleigh, North Carolina 27604
Phone: [phone] \ FAX: [phone]
Internet: http:/Iportal.ncdenr.org/web/wgtws
An Equal Opportunity \ Affirmative Action Employer
No thCarolina
Naturally
Asheville Regional Airport Authority
Page 2 of 4
June 29, 2010
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.
e. 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
1,260 linear feet of credits currently available in the 8-digit HUC?
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).
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.
Asheville Regional Airport Authority
Page 3 of 4
June 29, 2010
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 storm water 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 pollution 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 needs at 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, 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:
hi!p:Hportal.ncdenr.orgJweb/wq/ws/su/bmp-manual
The plans cannot be properly reviewed as currently submitted.
Please submit this information within 30 calendar days of the date of this letter. If we do not receive this
requested information within 30 calendar days of the date of this letter, your project will be withdrawn and you
will need to reapply with a new application and a new fee.
Asheville Regional Airport Authority
Page 4 of 4
June 29, 2010
This letter only addresses the application review and does not authorize any impacts to wetlands, waters or
protected buffers. Please be aware that any impacts requested within your application are not authorized (at this
time) by the DWQ. Please call Mr. Ian McMillan or Ms. Amy Chapman at 919-733-1786 if you have any
questions regarding or would like to set up a meeting to discuss this matter.
SIan McMillan, Acting Supervisor
401 Oversight/Express Review Permitting Unit
UM
cc: USACE Asheville Regulatory Field Office
Susan Wilson, DWQ Asheville Regional Office
File Copy
Clement Riddle, CEC, 224 South Grove Street, Suite f, Hendersonville, NC 28792
Filename: 071841 Ver3AshevilleAirportCargoHoldExpansion(Buncombe)On_Hold
■ Complete Items 1, 2, and 3. Also complete
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so that we can return the card to you.
■ Attach this card to the back of the mailpiece,
or on the front If space permits.
1. Article Addressed to:
MR LEW BLEISWEIS 6/29/10
ASHEVILLE REGIONAL AIRPORT
61 TERMINAL DR STE 1
FLETCHER`NC 28732
DWQ07-1841 V3 BUNCOMBE COUNTY
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NC DENR DIVISION OF WATER QUALITY
401 OVERSIGHT/EXPRESS UNIT
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