20071841 Ver 3_More Info Received_20100817

CLearWaLer
ClearWater Environmental Consultants, Inc.
August 13, 2010 wvvw.cwenv.com
Mr. Ian McMillan
NC Division of Water Quality
1650 Mail Service Center
Raleigh, North Carolina 27699
u
U
AUG 1 2010
ENR - WATER OUALI iY
WETLAND
AND STORAWYVATER BRANCH
RE: Request for More Information
Asheville Airport
Buncombe County, North Carolina
Action ID SAW-2010-00036; DWQ Project # 07-1841 Ver. 3
Dear Mr. McMillan,
Please reference the letter dated June 29, 2010 (Attachment A) sent by the NC Division
of Water Quality (DWQ) in response to the permit application submitted by ClearWater
Environmental Consultants, Inc. (CEC), on behalf of Mr. Lew Bleiweis of the Asheville
Regional Airport Authority. The permit application requested written authorization for
the impacts associated with development of the Asheville Airport Cargo Hold Expansion
and associated infrastructure. The comments provided by the DWQ are listed and
discussed below.
DWQ Comment #1: "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 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 US Army Corps of Engineers (Corps) defines the project purpose and need
with input from the applicant. In a letter dated July 19, 2010, the Corps states that
the project's purpose and need as submitted by the applicant is adequate to
continue review of the application. However, the purpose and need for the
previously permitted project remains unchanged.
The North General Aviation development area is designated for general aviation
and corporate users that utilize smaller planes (piston and corporate jet type
aircraft) primarily for business and corporate use, travel, and personal use. The
North General Aviation area is not large enough to facilitate a cargo operation
with the needed truck access and maneuvering room required for trucks and
aircraft. Additionally, it is logistically and operationally beneficial to the airport
224 South Grove Street, Suite F
Hendersonville, NC 28792
828-698-9800 Tel
828-698-9003 Fax
Mr. Ian McMillan
08.13.10
Page 2 of 6
and tenants to separate cargo operations from general aviation and commercial
service operations. Cargo operations require and operate under different FAA and
TSA guidelines than do general aviation and corporate users.
"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."
At the pre-application meeting, members of the DWQ staff were directed to the
Asheville Airport website which includes a master plan summary and associated
maps. The document can be found at the following web address:
<http://www.flyavl.com/component/option,com_docman/Itemid,374/task,cat vie
w/gid,89/>.
"This plan should also give a time estimate of the completion of the previously approved
project (v2)."
The estimated completion date for earth-moving at the North General Aviation
development area is October 2010. Upon completion of grading and filling,
building construction may occur between November 2010 and November 2015.
Estimated timelines are subject to change.
"Based on the vigorous construction at the airport, even during economic downturn,
ARO/DWQ has concerns that the immediate purpose and need of the project may be not
for immediate growth, but most likely for the use of immediately available, low/no cost
fill material."
As stated in the permit application: "The basic project purpose of the proposed
development of the Asheville Airport Cargo Hold Expansion is to provide
facilities for air cargo transport (i.e. FedEx, UPS, etc.). More specifically, the
overall project purpose of the proposed development of the Asheville Airport
Cargo Hold Expansion is to develop air cargo facilities in a location that
facilitates use of existing infrastructure." The US Army Corps of Engineers
(Corps) defines the project purpose and need with input from the applicant. In a
letter dated July 19, 2010, the Corps states that the projects purpose and need as
submitted by the applicant is adequate to continue review of the application.
DWQ Comment #2: Regarding Alternatives Analysis
"a. 61.2 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."
The North General Aviation development area is designated for general aviation
and corporate users that utilize smaller planes (piston and corporate jet type
aircraft) primarily for business and corporate use, travel, and personal use. The
North General Aviation area was never designed for cargo services and is not
large enough to facilitate a cargo operation with the needed truck access and
Mr. Ian McMillan
08.13.10
Page 3 of 6
maneuvering room required for trucks and aircraft. Additionally, it is logistically
and operationally beneficial to the airport and tenants to separate cargo operations
from general aviation and commercial service operations. Cargo operations
require and operate under different FAA and TSA guidelines than do general
aviation and corporate users.
The Certified Cargo Screening Program (CCSP) was established by TSA effective
February 1, 2009, enabling indirect air carriers, shippers, and independent cargo
screening facilities to screen cargo for flights originating in the United States.
Participants are fully regulated and inspected for compliance.
By utilizing a cargo area separate from the air carrier (passenger) operations area,
the Asheville Airport will be able to provide secure storage facilities and conduct
cargo operations that have separate screening requirements from cargo that is
placed on air carrier (passenger) aircraft. This also enables the Asheville Airport
to limit the amount of personnel that have access to cargo areas, passenger areas,
and operational areas of all cargo facilities.
"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 at that time?)
Alternative locations for the cargo facility are thoroughly discussed in the permit
application. Currently, the proposed facility is beyond the area reserved for
possible runway expansion (Area D on Figure 6 of the application); the project
site is located to the west. The cargo area cannot be located to the north or south
for the reasons discussed in the permit application. These reasons included:
issues with access, locations of runway safety areas, land area size constraints,
location of instrument landing system critical areas, etc. Building a cargo facility
that is dependent on access from future development, is an unfeasible proposition.
The cargo facility needs to be autonomous with access from currently available
infrastructure.
"c. 61.2 F- The applicant has discussed that road access 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 is not feasible
must be submitted."
The road referenced in this comment is a single lane gravel service road and is not
meant for everyday travel or cargo trucks. The road is a portion of the Asheville
airport's security and perimeter road used by airport staff and security personnel.
Due to its location within the airport boundary and parallel to the existing runway
and its function as a security and perimeter road, using this gravel roadway as the
primary ingress and egress to the site (Area F) is not practical or safe because of
flying and landing aircraft. Additionally, use of this road network would require
trucks to travel long distances within the active runway corridor and airport. The
logistics of coordinating truck and aircraft traffic is infeasible as portions of the
Mr. Ian McMillan
08.13.10
Page 5 of 6
the Army acting through the Chief of Engineers under section 404(b)(1) of the
Clean Water Act (33 U.S.C. 1344). The Guidelines are applicable to the
specification of disposal sites for discharges of dredged or fill material into waters
of the United States. Sites are defined and reviewed by the regulatory program of
the U.S. Army Corps of Engineers under sections 404(a) and (e) of the Clean
Water Act (see 33 CFR Parts 320, 323 and 325). The DWQ's permit review as
outlined in 15A NCAC 02H .0500 does not include review of the Guidelines as
defined by the EPA and the Corps; therefore, these comments will not be
addressed in this response. The decision and appropriateness to not address these
comments was discussed with Mr. Ian McMillan on July 26, 2010.
DWQ Comment 45: "Public Interest Considerations."
The Corps' public interest review is defined in 33 CFR 320.4. This review must
be completed by the Corps prior to the issuance of any permit. The DWQ's
permit review as outlined in 15A NCAC 02H .0500 does not include public
interest review as defined by the Corps; therefore, these comments will not be
addressed in this response. The decision and appropriateness to not address these
comments was discussed with Mr. Ian McMillan on July 26, 2010.
DWQ Comment #6: "Secondary and Cumulative Effects - Please discuss the effects of
increased traffic, noise, associated infrastructure in this section. The effect of increased
jobs, etc. should also be discussed."
As defined in 15A NCAC 02H.0500, the DWQ's review of cumulative effects is
limited to a determination that the project "[will] not result in cumulative impacts,
based upon past or reasonably anticipated future impacts, that cause or will cause
a violation of downstream water quality standards." This project will not induce
future impacts. As stated in the permit application and summarized here,
agricultural, residential, and infrastructure development is active in the watershed;
however, the current and future development of the area surrounding the airport is
independent of the activities proposed within the boundaries of the Asheville
Regional Airport.
DWQ Comment #7: "Summary - Please provide a projected timeline for completion of
the building and facilities."
The estimated completion date for earth-moving at proposed site is September
2014. Upon completion of grading and filling, building construction may occur
between October 2014 and October 2018. Estimated timeline are subject to
change.
DWQ Comment #8: "Post Construction Stormwater Plans."
Stormwater plans and all associated documentation were submitted with the
permit application. They were remailed and resubmitted directly to the
Mr. Ian McMillan
08.13.10
Page 6 of 6
appropriate reviewer. Stormwater plans were mailed directly from AVCON, the
project engineers, on July 29, 2010 to Ms. Susan Wilson for review. Copies of
the same plans were submitted to Mike Randall with the SWPU and McCray
Coates with the City of Asheville on July 12, 2010.
The applicant believes the information submitted in this package addresses all issues set
forth by the DWQ in their letter dated June 29, 2010. Should you have any questions or
comments concerning this project please do not hesitate to contact me at 828-698-9800.
Sincerely,

Rebekah L. Newton
Project Biologist
RAe, iS&
Principal
Cc: US Army Corps of Engineers - Tasha McCormick
Attachment A
DWQ Response to Public Notice
(dated June 29, 2010)

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NCDENR
North Carolina Department of Environment and Natural Resourco? ! I JUL 0 I MO
Division of Water Quality 6
Beverly Eaves Perdue Coleen H. Sullins Dee Freem<
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Governor Director -
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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 OversighUExpress Review Permitting Unit One
1650 Mail Service Center, Raleigh, North Carolina 27699-1650 NorthCarolina
Location: 2321 Crabtree Blvd., Suite 250, Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Nwhil all y
Internet: http:/Iportal.ncdenr.org/web/wq/ws
An Equal Opportunity 1 Affirmative Action Employer
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.
in. 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:
http://poi-tal.ncdenr.oreweb/M/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.
Since ly,
Ian McMillan, Acting Supervisor
401 Oversight/Express Review Permitting Unit
lJM
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