20071841 Ver 4_Other Agency Comments_20110815

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
REPLY TO
ATTENTION OF:
August 9, 2011
Regulatory Division
Action ID No.: SAW-2010-00036
Mr. Lew Bleiweis
Asheville Regional Airport Authority
61 Terminal Drive, Suite 1
Asheville, North Carolina 28732
Dear Mr. Bleiweis:
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AUG 1 5 2011
DENR • WATER QUALITY
WET 4j AND S'O'RTER BRANCH
Reference is made to your June 13, 2011, Department of the Army permit application in
which you requested a permit for impacts to 2,076 linear feet of stream channels and 0.9 acre of
wetland for the construction of a parallel taxiway to aid in the rehabilitation of the existing
runway and construction of an air cargo transport facility and associated infrastructure at the
Asheville Regional Airport, in Asheville, Buncombe County, North Carolina. The purpose of
this letter is to provide you with comments received in response to the Public Notice dated
June 24, 2011 and request that additional information be submitted to continue the review of
your permit request.
By letter dated July 22, 2011, the North Carolina Wildlife Resource Commission
(NC)vVRC) provided comments in response to the Public Notice which are attached for your
review. NCWRC noted that the French Broad River near the airport location supports a cool
water fishery to include smallmouth bass and muskellunge. NCWRC acknowledged that the
stream channels proposed for impact are considered poor quality and have been degraded due
to storm water run-off from the airport facility. NCWRC recommended that the proposed
mitigation plans should be supplemented with innovative storm water management practices and
restoration of unstable channel morphology in that area.
We also received comments from the U.S. Fish and Wildlife Service (USFWS) by letter
dated June 27, 2011. The Service does not agree with the use of coal fly ash as fill material,
cited several reasons for their concern, and recommended corrective actions to prevent
groundwater contamination. The USFWS also noted that no federally listed species or their
habitat occurs on the project site and that your obligation under Section 7 of the Endangered
Species Act has been fulfilled.
We have also reviewed the alternatives analysis presented in the permit application and
Draft Environmental Assessment (May 2011). Based on this review, it appears that Parcel G (as
depicted in Figure 2-5 of the Environmental Assessment) may be a viable alternative location for
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the construction of the cargo facility. This alternative location was eliminated due to lack of
access to Old Fanning Bridge Road. We feel this alternative should be explored further so that
we can evaluate its practicability. Based upon Figure 2-8 of the Environmental Assessment,
additional land acquisition was necessary along the parallel runway to make the preferred
alternative feasible. Please provide further information as to feasibility of an access road being
constructed through this recently acquired area which would provide direct access to Fanning
Bridge Road and thereby avoid/reduce impacts at the preferred location. Your response should
also address if additional land would be required and what that cost would be in addition to the
road construction.
We have also reviewed your mitigation plan and believe it is adequate to compensate for
the proposed impacts. As proposed, your mitigation plan is in accordance with the Wilmington
District's Interagency Stream Mitigation Guidelines (2003) and the recently published federal
rule entitled Compensatory Mitigation for Losses of Aquatic Resources (33 CFR Part 332).
The requested information should be submitted within 30 days from the date you receive
this letter. If we do not receive a response, we will assume that you longer wish to pursue this
project and withdraw your permit request. If you have any questions, please contact me at (828)
271-7980, extension 226.
Sincerely,
Tasha McCormick
Regulatory Specialist
Asheville Regulatory Field Office
Enclosures
Copy Furnished w/encls:
Ms. Rebekah Newton
ClearWater Environmental Consultants, Inc.
718 Oakland Street
Hendersonville, North Carolina 28791
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Copies Furnished w/o encls:
Mr. Ian McMillan
North Carolina Division of Water Quality
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center
Raleigh, North Carolina 27699-1650
Mr. Bryan Tompkins
U.S. Fish and Wildlife Service
160Zillicoa Street
Asheville, North Carolina 28801
Mr. David McHenry
Mountain Region Coordinator
20830 Great Smoky Mountain Expressway
Waynesville, North Carolina 28786