WQ0000020 Aville Arpt 401 404 Permitting Sept 2008- Mar 2012

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PROGRAM
June 1,2011
Lew Bleiwei
Asheville Airport
61 Terminal Drive Suite I
Fletcher,NC 28732
Expiration of Acceptance:March 1,2012.
Project:Asheville Airport Expansion County:Buncombe
The purpose of this letter is to notify you that the North Carolina Ecosystem Enhancement Program(NCEEP)is willing to accept
payment for impacts associated with the above referenced project. Please note that this decision does not assure that the payment will
be approved by the permit issuing agencies as mitigation for project impacts. It is the responsibility of the applicant to contact these
agencies to determine if payment to the NCEEP will be approved. You must also comply with all other state federal or local
government permits:regulations or.authorizations associated with.the.proposed activity.includiri SL 2009337:An Act Promote
Comneitsatory Miti atg_ion by Private Mitigation-Banks
This acceptance is valid for nine months from the date of this letter and is not transferable. If we have not received a copy of the
issued 404 Permit(401 Certification/CAMA permit within this time frame,this acceptance will expire. It is the applicant's .
responsibility to send copies of the permits to NCEEP. Once NCEEP receives a copy of the permit(s)an invoice will be issued based
on the required mitigation in that permit and payment must be made prior to conducting the authorized work. The amount of the In
Lieu Fee to be paid to NCEEP by an applicant is calculated based upon the Fee Schedule and policies listed at www.nceep.net.
3
Based on the information supplied by you the impacts that may require compensatory mitigation are summarized in the following
table.
River Basin CU Stream(feet) Wetlands(acres) Buffer I Buffer II
Location (Sq.Ft.) (Sq.F
Cold Cool Warm Riparian Non-Riparian Coastal Marsh
Impact French Broad 06010105. 0 2,I 11 0 1.0 0 0 0 0
Credits French Broad 06010105 0 Up to 0 up to 2.0 0 0 0 0
4,333
Upon receipt of.payment,EEP will take responsibility for providing the compensatory mitigation. If the regulatory agencies require
mitigation credits greater than indicated above,and the applicant wants NCEEP to be responsible for the additional mitigation,the
applicant will need to submit a mitigation request to NCEEP for approval prior to permit issuance..The mitigation will be performed
in accordance with the N.C.Department of Environment and Natural Resources' Ecosystem Enhancement Program In-Lieu Fee
Instrument dated July 28,2010.
If you have any questions or need additional information,please contact Kelly Williams at(919)716-1921.
Sincerely,
I
William D.Gilmore,PE
Director
cc: Ian McMillan,NCDWQ Wetlands/401 Unit
Tasha McCormick,USACE-Asheville
Susan Wilson,NCDWQ-Asheville
Rebekah Newton,agent
File
Restor' .. Protects Our Stag
NCDENR
North Carolina Ecosystem Enhancement Program, 1652 Mail Service Center, Raleigh,NC 27699-1652/919-715-0476/www.nceep.net

AT- LA
MCDEMR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H,Sullins Dee Freeman
Governor Director Secretary
October 7,2011
Mr. Lew Bleiweis, Airport Director OCT 0 2011
Asheville Regional Airport Authority
61 Terminal Drive Suite 1 tOG GEId(�
Fletcher,NC 28732 �c.iG"I�`
Re: Asheville Airport Runway Rehabilitation Parallel Taxiway and Cargo Hold Expansion(West)
Buncombe County
DWQ#20071841, Ver.4; USACE Action ID. No. SAW-2010-00036
Ut to French Broad River[040302, 6-(54.5), B]
APPROVAL of 401 Water Quality Certification with Additional Conditions-REVISED
Dear Mr. Bleiweis:
Attached hereto is a copy of Certification No. 3753 issued to Mr. Lew Bleiweis and Asheville Regional
Airport Authority, dated October 7,2011. This Certification replaces the Certification issued to you
on September 30,2011. In addition,you should get any other federal,state or local permits before you
go ahead with your project including(but not limited to) Solid Waste, Sediment and Erosion Control,
Stormwater, Dam Safety,Non-discharge and Water Supply Watershed regulations.
If we can be of further assistance,do not hesitate to contact us.
Sincerely,
"2
Coleen H. Sullins
CHS/kahlUm
Attachments: Certificate of Completion
NCDWQ 401 WQC Summary of Permanent Impacts and Mitigation Requirements
cc: Becky Fox, EPA, 1307 Firefly Road, Whittier,NC 28789
U.S. Army Corps of Engineers,Asheville Regulatory Field Office, Wilmington District, USACOE
Chuck Cranford, DWQ Asheville Regional Office
LI RAslfe ille Regional,Offce�
File Copy
Clement Riddle, CEC,224 South Grove Street, Suite f,Hendersonville,NC 28792
Filename: 071841 ver4AshevilleAirportRunwayRehabilitationParallelTaxiwayAndCargoHoldExpgnsiori_West(BUncombe)4o1 IC'Revised'"
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1 2 2011
Wetlands,Buffets,Storr•water,Compliance and Pe;.nitting Unit(WeBSCaPe) I�:
1650 Mail Service Center,Raleigh,North Carolina 27699-1650
Phone.[phone] FAX 919 rt07-6494 -
nterrn.t:hftp://portal.nc enrorglv.eb/wq/ws '. WATER C,IJALITY Su FION
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AnE ;alOpportunitylAffirm eativeActionEmploy
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Mr.Lew Bleiweis and Ash, Regional Airport Authority
Page 2 of 6
October 7,2011
NORTH CAROLINA 401 WATER QUALITY CERTIFICATION
THIS CERTIFICATION is issued in conformity with the requirements of Section 401 Public Laws 92-
500 and 95-217 of the United States and subject to the North Carolina Division of Water Quality(DWQ)
Regulations in 15 NCAC 2H, Section .0500 to Mr. Lew Bleiweis and Asheville Regional Airport Authority,
have permission to fill or otherwise impact 0.9 acres of 404/wetland and 1,796 linear feet of stream,to
construct the proposed Asheville Regional Airport expansion,which is located at 61 Terminal Drive, in
Fletcher, Buncombe County,North Carolina, pursuant to an application dated June 8, 2011, and received by
the DWQ on June 14, 2011, and by Public Notice issued by the USACE on June 24,2011,and received by
the DWQ on June 24, 2011, and by additional information received on August 30, 2011, and September 15,
2011.
The application and supporting documentation provides adequate assurance that the proposed work will
not result in a violation of applicable Water Quality Standards and discharge guidelines. Therefore,the
State of North Carolina certifies that this activity will not violate the applicable portions of Sections 301,
302,303, 306,307 of PL 92-500 and PL 95-217 if conducted in accordance with the application,the
supporting documentation, and conditions hereinafter set forth.
This approval is for the purpose and design submitted in the application materials and as described in the
Public Notice. If the project is changed,prior to notification a new application for a new Certification is
required. If the property is sold,the new owner must be given a copy of the Certification and approval
letter and is thereby responsible for complying with all conditions of this Certification. Any new owner
must notify the Division and request the Certification be issued in their name. Should wetland or stream
fill be requested in the future, additional compensatory mitigation may be required as described in 15A
NCAC 2H.0506(h)(6)and(7). If any plan revisions from the approved site plan result in a change in
stream or wetland impact or an increase in impervious surfaces,the DWQ shall be notified in writing and
a new application for 401 Certification may be required. For this approval to be valid,compliance with
the conditions listed below is required.
Conditions of Certification:
1. Impacts Approved
The following impacts are hereby approved as long as all of the other specific and general
conditions of this Certification(or Isolated Wetland Permit)are met. No other impacts to
wetlands, streams, and/or buffers,are approved including incidental impacts:
Type of Impact Amount Approved Units Plan Location or Reference
404/Wetland 0.9(acres) Application
Stream 1,796(linear feet) Application
Sediment and Erosion Control:
2. Erosion and sediment control practices must be in full compliance with all specifications
governing the proper design, installation and operation and maintenance of such Best
Management Practices in order to protect surface waters standards:
a. The erosion and sediment control measures for the project must be designed, installed,
operated, and maintained in accordance with the most recent version of the North Carolina
Sediment and Erosioir Control Planninlf;and Design tMamial.

Mr. Lew Bleiweis and As] fe Regional Airport Authority
Page 3 of 6
October 7,2011
b. The design, installation, operation, and maintenance of the sediment and erosion control
measures must be such that they equal, or exceed,the requirements specified in the most
recent version of the North Carolina Sediment and Erosion Control Manual. The devices
shall be maintained on all construction sites, borrow sites, and waste pile(spoil)projects,
including contractor-owned or leased borrow pits associated with the project.
c. Sufficient materials required for stabilization and/or repair of erosion control measures and
stormwater routing and treatment shall be on site at all times.
3. No waste,spoil, solids, or fill of any kind shall occur in wetlands,waters,or riparian areas beyond
the footprint of the impacts depicted in the 404/40 1 Permit Application. All construction activities,
including the design, installation, operation, and maintenance of sediment and erosion control Best
Management Practices, shall be performed so that no violations of state water quality standards,
statutes,or rules occur;
4. Sediment and erosion control measures shall not be placed in wetlands or waters without prior
approval from the Division. If placement of sediment and erosion control devices in wetlands and
waters is unavoidable, design and placement of temporary erosion control measures shall not be
conducted in a manner that may result in dis-equilibrium of wetlands or stream beds or banks,
adjacent to or upstream and down stream of the above structures. All sediment and erosion control
devices shall be removed and the natural grade restored within two(2) months of the date that the
Division of Land Resources or locally delegated program has released the project;
5. Protective Fencing-The outside buffer,wetland or water boundary and along the construction
corridor within these boundaries approved under this authorization shall be clearly marked with
orange warning fencing(or similar high visibility material)for the areas that have been approved to
infringe within the buffer, wetland or water,prior to any land disturbing activities;
Continuing Compliance:
6. Mr. Lew Bleiweis and Asheville Regional Airport Authority shall conduct construction activities
in a manner consistent with State water quality standards(including any requirements resulting
from compliance with section 303(d)of the Clean Water Act)and any other appropriate
requirements of State law and federal law. If the Division determines that such standards or laws
are not being met(including the failure to sustain a designated or achieved use)or that State or
federal law is being violated, or that further conditions are necessary to assure compliance,the
Division may.reevaluate and modify this Certification to include conditions appropriate to assure
compliance with such standards and requirements in accordance with 15A NCAC 2H.0507(d).
Before modifying the Certification,the Division shall notify Mr. Lew Bleiweis and Asheville
Regional Airport Authority, and the US Army Corps of Engineers, provide public notice in
accordance with 15A NCAC 2H.0503 and provide opportunity for public hearing in accordance
with 15A NCAC 2H.0504. Any new or revised conditions shall be provided to Mr. Lew Bleiweis
and Asheville Regional Airport Authority in writing, shall be provided to the United States Army
Corps of Engineers
Act, and shall also become conditions of the 404 Permit for the project;
Mitigation:
7. Compensatory Mitigation Using the Ecosystem Enhancement Program(EEP)
Mitigation must be provided for the proposed impacts as specified in the table below. We
understand that you wish Lo make a payment to the Wetlands Restoration Fund administered by
the INC Ecosystem Enhancement Program(EEP) to meet this mitigation requirement. This has

Mr. Lew Bleiweis and Ast e Regional Airport Authority
Page 4 of 6
October 7,2011
been determined by the DWQ to be a suitable method to meet the mitigation requirement. Until
the EEP receives and clears your check(made payable to: DENR—Ecosystem Enhancement
Program Office),.no impacts specified in this Authorization Certificate shall occur. The EEP
should be contacted at(919) 716-1921 if you have any questions concerning payment into a
restoration fund. The mitigation will be phased as shown in the table below:
T e of Wetland Compensatory Mitigation Required River and Sub-basin Number
Phase#1—Cargo Area
404/Wetlands—riparian 0(acres) French Broad/06010105
Stream(perennial) 1,225(linear feet) French Broad/06010105
Phase#2—Parallel
Taxiway
404/Wetlands—riparian 0.9(acres) French Broad/06010105
Stream(perennial) 571 (linear feet) French Broad/06010105
8. Construction Stormwater Permit NCG010000
Upon the approval of an Erosion and Sedimentation Control Plan issued by the Division of Land
Resources(DLR)or a DLR delegated local erosion and sedimentation control program, an
NPDES General stormwater permit(NCGO10000)administered by DWQ is automatically issued
to the project. This General Permit allows stormwater to be discharged during land disturbing
construction activities as stipulated by conditions in the permit. If your project is covered by this
permit [applicable to construction projects that disturb one(1)or more acres], full compliance
with permit conditions including the sedimentation control plan, self-monitoring, record keeping
and reporting requirements are required. A copy of this permit and monitoring report forms may
be found at: http://
portal.ncdenr.or /c/document library/get file?uuid=d15e7ee8-cb50-443
9dcf-049b001337ac&grounId=38364;
9. Stormwater Management Plan Implementation Procedures(No Further Approval Needed)
• The approved SMP must be constructed and operational before any permanent building or
other structure is occupied at the site. If a development is phased,then the approved SMP for
each future phase must be constructed and operational before any permanent building or other
structure associated with that phase is occupied.
• The approved SMP as well as drainage patterns must be maintained in perpetuity.
• The SMP may not be modified without prior written authorization from the SMP approval
authority. If the SMP falls under another state stormwater program,then a copy of the
approval letter and the modified SMP must be submitted to the 401 Oversight/Express Unit
prior to the commencement of the modifications.
10. Culvert Installation
All work in or adjacent to stream waters shall e conducted to a dry work area. Approved BMP
measures from the most current version of NCDOT Construction and Maintenance Activities manual
(http://www.ncdot.or doh/operations/BMP manuaUdownload/BMP®Manual pdf)
such as sandbags, rock berms, cofferdams and other diversion structures shall be used to prevent
excavation in flowing water.
Culverts required for this project shall be installed in such a manner that the original stream profiles
are not altered. Existing stream dimensions(including the cross section dimensions, pattern, and
longitudinal profile)must be maintained above and below locations -)f each culvert. Culverts shall
be designed and installed to allow fo,-aquatic life movrment as well as to prevent head cutting of

Mr. Lew Bleiweis and Asl le Regional Airport Authority
Page 5 of 6
October 7,2011
the streams. If any of the existing pipes are or become perched,the appropriate stream grade shall
be re-established or, if the pipes installed in a perched manner,the pipes shall be removed and re-
installed correctly.
Culvert(s)shall not be installed in such a manner that will cause aggradation or erosion of the
stream up or down stream of the culvert(s). Existing stream dimensions(including the cross section
dimensions, pattern and longitudinal profile)shall be maintained above and below locations of each
culvert.
Placement of culverts and other structures in waters, streams, and wetlands must be placed below
the elevation of the streambed by one foot for all culverts with a diameter greater than 48 inches,
and 20 percent of the culvert diameter for culverts having a diameter less than 48 inches,to allow
low flow passage of water and aquatic life. Design and placement of culverts and other structures
including temporary erosion control measures shall not be conducted in a manner that may result in
dis-equilibrium of wetlands or streambeds or banks, adjacent to or.upstream and down stream of the
above structures. The applicant is required to provide evidence that the equilibrium shall be
maintained if requested in writing by DWQ.
The establishment of native, woody vegetation and other soft stream bank stabilization techniques
must be used where practicable instead of rip rap or other bank hardening methods. If rip-rap is
necessary, it shall.not be placed in the stream bed, unless specifically approved by the Division of
Water Quality.
Installation of culverts in wetlands must ensure continuity of water movement and be designed to
adequately accommodate high water or flood conditions. ,
Upon completion of the project,the Applicant shall complete and return the enclosed"Certificate of
Completion"form to notify NCDWQ when all work included in the §401 Certification has been
completed. The responsible party shall complete the attached form and return it to the
401/Wetlands Unit of the NC Division of Water Quality upon completion of the project. Please
send photographs upstream and downstream of each culvert site to document correct installation
along with the Certificate of Completion form.
11. Deed Notifications
Deed notifications or similar mechanisms shall be placed on all retained jurisdictional wetlands,
waters and protective buffers in order to assure compliance for future wetland,water and buffer
impact. These mechanisms shall be put in place at the time of recording of the property, or of
individual lots,whichever is appropriate. A sample deed notification can be downloaded from
the 401/Wetlands Unit web site at:
hiip://portal.ncdenr.org/c/document libraryget file?uuid=ef84d0e1-5fc9-4183-87b5-
2f9d7eb152e0&groupId=38364. The text of the sample deed notification may be modified as
appropriate to suit to this project.
12. Stormwater Management
Before any permanent impervious surface(i.e., building,roadway, taxiway, tarmac or other
similar surface) is installed as part of any phase of the project described in this certification,
the applicant must meet all of the following:
• The Stormwater Management Plan(SMP)must be approved in writing by the City of
Asheville. A copy of the approval ietter and approved SMP must be submirted v)the

Mr.Lew Bleiweis and Asti e Regional Airport Authority
Page 6 of 6
October 7,2011
Division prior to installation of any impervious surface within the project site. If the,
project is phased,then the approved SMP for each phase must be submitted to the
Division prior to installation of any impervious surfaces associated with that phase.
• The approved stormwater best management practices(BMPs)must be constructed and
operational before any permanent building or other structure is occupied or becomes
operational. If the project is phased,then the approved BMPs for each future phase must
be constructed and operational before any permanent building or other structure
associated with that phase is occupied or becomes operational.
• The approved SMP, phased or otherwise, as well as drainage patterns must be maintained
in perpetuity.
• The SMP may not be modified without prior written authorization from the SMP
approval authority.
13. Certificate of Completion
Upon completion of all work approved within the 401 Water Quality Certification or applicable
Buffer Rules, and any subsequent modifications, the applicant is required to return the attached
certificate of completion to the Wetlands, Buffers, Stormwater,Compliance and Permitting Unit
(WeBSCaPe),North Carolina Division of Water Quality, 1650 Mail Service Center, Raleigh,NC,
27699-1650.
Also,this approval to proceed with your proposed impacts or to conduct impacts to waters as
depicted in your application shall expire upon expiration of the 404 or CAMA Permit.
If this Certification is unacceptable to you,you have the right to an adjudicatory hearing upon written
request within sixty(60)days following receipt of this Certification. This request must be in the form of a
written'petition conforming to Chapter 150B of the North Carolina General Statutes and filed with the
Office of Administrative Hearings, 6714 Mail Service Center, Raleigh,N.C. 27699-6714. If
modifications are made to an original Certification,you have the right to an adjudicatory hearing on the
modifications upon written request within sixty(60)days following receipt of the Certification. Unless
such demands are made,this Certification shall be final and binding.
This the 7t'day of Octob 2 11
DIVI ONO W ER LITY
oleen H. Sullins
3753
CHS/kah/Um

=A
NCD NR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H.Sullins Dee Freeman
Governor Director Secretary
North Carolina Division of Water Quality
401 Water Quality Certification
Summary of Permitted Impacts and Mitigation Requirements
In accordance with 15A NCAC 2H.0500,Mr. Lew Bleiweis and Asheville Regional Airport Authority,have
permission to fill or otherwise impact 0.9 acres of 404/wetland and 1,796 linear feet of stream,to construct the
proposed Asheville Regional Airport expansion,which is located at 61 Terminal Drive, in Fletcher,Buncombe
County,North Carolina. All activities associated with these authorized impacts must be conducted with the
conditions listed in the attached Permit transmittal letter. THIS CERTIFICATION IS NOT VALID WITHOUT
THE ATTACHMENTS.
COMPENSATORY MITIGATION REQUIREMENTS,ECOSYSTEM ENHANCEMENT PROGRAM
DWQ PROJECT#: 20071841,Ver.4
NC EEP NAME: Asheville Airport Expansion
LOCATION: Asheville
COUNTY: Buncombe
BASIN/SUB BASIN: French Broad/06010105
As required by 15A NCAC 2H.0500,and the conditions of this Certification,you are required to compensate for
the above mitigable impacts through the restoration,creation,enhancement or preservation of wetlands,surface
waters and riparian buffers as outlined below prior to conducting any activities that impact or degrade the waters of
the state.
Note: Acreage requirements proposed to be mitigated through the Ecosystem Enhancement Program must be
rounded to one-quarter acre increments and linear foot requirements must be rounded up to the nearest
foot according to 15 2R.0503(b).
Impacts Mitigation
1.259 Acres Riparian Wetlands 1.259 Acres Riparian Wetlands
1,076 Linear Feet of Stream 1,796 Linear Feet of Stream
One of the options you have available to satisfy the compensatory mitigation requirement is through the payment of
a fee to the Wetlands Restoration Fund per NCAC 2R.0503. If you choose this option,please sign this form and
mail the form along with a copy of your 401 Certification or Buffer Approval to the Ecosystem Enhancement
Program at the address below. An invoice for the appropriate amount of payment will be sent to you upon receipt
of this form. PLEASE NOTE,THE ABOVE IMPACTS ARE NOT AUTHORIZED UNTIL YOU RECEIVE
NOTIFICATION THAT YOUR PAYMENT HAS BEEN PROCESSED BY THE ECOSYTEM ENHANCMENT
PROGRAM.
Signature Date
ECOSYSTEM FUN ANCRA4
1652 Mail Service Center
RALEIGH,N.C.27699-1652
[phone]
Filename:071841 Ver4AshevilleAirportRunwayRehabilitationParallelTaxiwayAndCargoHoldExpansion_West(Buncombe)401_IC_EEP
/etl:nds,Buffers,Storm!vater,Compliance and Permitting Unit(WeBSCaPe)
650 Mail Service Center,Raleigh,North Carolina 27699-16b0
hone:919-801-6301 1 FAX:[phone]
der et:htlp:/rrortal.ncdenr.orgh:eb"�vq/vve
n ECLla!Oppr`,tunity 1 Affirniativa Action E•nployer

401 Water Quality Certification
Regional Office Comments
Project number: ' 07-1841 V4 �Region: Asheville r�`Date K 09-27-11
Project name:, Asheville Airport Runway Rehab '. Staff Chuck Cranford
Regional Office Supervisor: Keith Haynes
❑ Issue as submitted
CJ1 Issue with conditions listed below
Requested°Action: ❑ Request additional information
❑ Return to applicant
❑ Deny project
1. Stormwater Management
Before any permanent impervious surface (i.e., building, roadway,
taxiway, tarmac or other similar surface) is installed as part of any
phase of the project described in this certification, the applicant must
meet all of the following:
° • The Stormwater Management Plan(SMP) must be approved in
writing by the City of Asheville. A copy of the approval letter
and approved SMP must be submitted to the Division prior to
installation of any impervious surface within the project site. If
the project is phased,then the approved SMP for each phase
must be submitted to the Division prior to installation of any
impervious surfaces associated with that phase.
Comments; • The approved stormwater best management practices (BMPs)
must be constructed and operational before any permanent
building or other structure is occupied or becomes operational.
If the project is phased, then the approved BMPs for each future
phase must be constructed and operational before any
permanent building or other structure associated with that phase
is occupied or becomes operational.
• The approved SMP,phased or otherwise, as well as drainage
patterns must be maintained in perpetuity.
• The SMP may not be modified without prior written
authorization from the SMP approval authority.
Also, include any standard IP conditions you see fit.
Version 1
S:\SWP\Buncombe\401s\Non-DOT\AshevilleAirport\AVL Airport 07-1841 V4\Regional Office Comments.9.27.1 Ldoc

Le rWa ra
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C1earWater Environmental Consultants,Inc. ;
August 26, 2011 www.cwenv.com
,:.
Mr. Ian McMillan
NC Division of Water Quality
1650 Mail Service Center
Raleigh,North Carolina 27699
RE: Request for More Information
Asheville Airport
Buncombe County,North Carolina
Action ID SAW-2010-00036; DWQ Project# 07-1841 Ver. 4
Dear Mr. McMillan,
Please reference the letter dated August 5, 2011 (Attachment A) sent by the NC Division
of Water Quality (DWQ) in response to the permit application submitted by C1earWater
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 runway maintenance and construction of air cargo facilities in
a location that facilitates use of existing infrastructure. The comments provided by the
DWQ are listed and discussed below.
DWQ Comment #1: "'Impact #8' is proposed for construction of a stormwater pond.
The application indicates that City of Asheville (COA) requirements related to
construction in a floodway are forcing these impacts to occur. Please provide
documentation of any decision communicated by the COA that confirms this statement.
Additional option to address stormwater management needs must be considered that
avoid `Impact#8'."
As originally proposed, the stormwater detention basin west of Old Fanning
Bridge Road was partially in the Federal Emergency Management Agency
(FEMA) designated floodway and 100-year floodplain. The initial comments
regarding the location of this stormwater basin were provided by Ms. Dana
Perkins of the Federal Aviation Administration (FAA) during review of the Draft
Environmental Assessment (drafted by Ms. Laura Stevens of The LPA Group).
Ms. Perkins indicated that airport development actions must avoid the floodplain
if a practicable alternative exists (per Executive Order 11988 and US Department
of Transportation (DOT) Order 5650.2). If no practicable alternative exists,
actions in a floodplain must be designed to minimize adverse impact to the
floodplain's natural and beneficial values. Ms. Perkins would agree that the Draft
Environmental Assessment adequately addressed the Executive and DOT Orders
if the governing stormwater authority (the City of Asheville) provided
224 South Grove Street,Suite F
Hendersonville,NC 28792
828-698-9800 Tel
828-698-9003 Fax

i
• The Stormwater Management Plan(SMP)must be approved in writing by
the City of Asheville. A copy of the approval letter and approved SMP must
be submitted to the Division prior to installation of any impervious surface
within the project site. If the project is phased, then the approved SMP for
each phase must be submitted to the Division prior to installation of any
impervious surfaces associated with that phase.
• The approved stormwater best management practices (BMPs)must be
constructed and operational before any permanent building or other structure
is occupied or becomes operational. If the project is phased,then the
approved BMPs for each future phase must be constructed and operational
before any permanent building or other structure associated with that phase is
occupied or becomes operational.
• The approved SMP,phased or otherwise, as well as drainage patterns must
be maintained in perpetuity.
• The SMP may not be modified without prior written authorization from the
SMP approval authority.
The above condition allows stream impacts to occur upon issuance of the 401 Water
Quality Certification and is acceptable to the AVL.
The DWQ requested that the AVL examine additional alternatives for the location and
configuration of the stormwater basin west of Old Fanning Bridge Road.
Recommendations from the COA and DWQ for the new basin included avoiding the
stream channel impacts and avoiding the floodway (if possible). After additional
evaluation, it was determined that the basin could be divided and reconfigured. The
attached modified site plan illustrates a new stormwater basin ;design that follows the
recommendations of the DWQ and COA. The new basin design eliminates Impact #8
from the project (2801inear feet). Total new impacts for the project site are 1,796 linear
feet of stream impact and 0.9 acre of wetland impact(no change).
The AVL respectfully request the. permit application be modified to reflect the
elimination of Impact#8 (280 linear feet) as discussed above.
Please do not hesitate to contact me at 828-698-9800 should you have any questions or
comments concerning this project.
Respectfully,
1`x-ODJ'-{' '
Rebekah L.Newton R. Clement Riddle,P.W.S
Project Biologist Principal
Copy Furnished:
NC Division of Water Quality; Asheville Regional Office—Chuck Cranford

i
7
Mr.Ian McMillan
08.26.11
Page 2 of 4
concurrence with the stormwater basin location. Ms., Stevens coordinated with
Mr. Chuck Watson, the City of Asheville Floodplain Administrator, regarding the
location of the stormwater basin. During a personal communication via-phone on
March 29, 2011 between Ms. Stevens and Mr. Watson, Mr. Watson (citing City of
Asheville Regulations 7-12-1) indicated that if no practicable alternative exists
then encroachment onto the 100-year floodplain is permissible under the City of
Asheville Regulations as long as fill remains a minimum of 10 feet outside of the
floodway.
It was determined that a practicable alternative for removing the stormwater
detention basin out of the floodway did exist; however, there were no practicable
alternatives for removing the basins out of the 100-year floodplain. The
stormwater detention basin was redesigned to avoid encroachment into the
floodway, however, complete avoidance of impacts to the 100-year floodplain
were not practicable due to site limitations associated with the proposed cargo
area, as well as FAA design standards for the runway safety area (RSA)
associated both with the temporary runway/parallel taxiway and with the existing
runway. In explanation, the fill slope that, encroaches into the floodplain is
associated with the minimum allowable RSA dimensions for the temporary
runway. Additionally, the shape and size limitations of the proposed cargo site
necessitate locating the stormwater detention basin on the opposite side of Old
Fanning Bridge Road. After the above mentioned coordination with Mr. Watson
at the City of Asheville, Ms. Perkins approved the Draft Environmental
Assessment with encroachments into the 100-year floodplain. The Findings of
No Significant Impact was issued on August 19, 2011.
Because the stormwater detention pond proposal is in accordance with the Region
4 Guideline for Reconciling Stormwater Management and Water Quality
Resource Protection Issues (EPA 2004) and no practicable alternative exists, the
AVL respectfully requests that the location of the stormwater detention basin be
reevaluated and approved as it is proposed.
DWQ Comment 42: "Stormwater Management Plan (SMP) — Project approval is not
possible without documentation that a SMP has been approved by the COA."
This statement is incorrect. The DWQ memorandum dated August 20, 2007
states that: "Any 401 Certification approved under this scenario shall be
conditioned so that the proposed activity shall not commence until such time that
the appropriate local approval has been granted." Therefore, project approval can
be granted without documentation of the approved Stormwater Management Plan
(SMP) by the City of Asheville. Ms. Rebekah Newton of CEC spoke with Mr.
Ian McMillan of the DWQ-Raleigh Office on August 12, 2011. Mr. McMillan
confirmed that "DWQ Comment 42" is incorrect and clarified the statement by
saying that the approval can be granted but that impacts can not occur until the
DWQ is provided with documentation that the SMP has been approved.
AVCON, the project Engineers, will be submitting a SMP to the City of

Mr.Ian McMillan
08.26.11
Page 3 of 4
Asheville. The DWQ, City of Asheville, and AVCON are working together to
provide appropriate documentation to the DWQ regarding approval of the SMP.
The DWQ will be provided a copy of the approval letter upon receipt.
DWQ Comment 43: "Potential Mitigation— The stream located at the south-west corner
of the Airport property (adjacent to NC HWY 280) is severely downcut and heavily
influenced by stormwater from the airport property. During the onsite meeting(March 9,
2010), NCDWQ and NCWRC both expressed that restoration/stabilization of this channel
should be part of the application package. No plans for this stream segment have been
submitted. A complete stream stabilization/restoration plan should be developed and
submitted for mitigation credit as part of this application."
Restoration of stream channels within existing airport boundaries is difficult and
proves complicated. On-site restoration and preservation has proven unsuccessful
at other airport expansions in North Carolina. For instance, vegetation height
restrictions limit vegetation that can be planted in the restored areas.
Additionally, undisturbed woody buffers have the potential to attract wildlife to
the area. Wildlife is a threat to airport safety if animals move onto the runway or
fly within plane flight patterns. Additionally, because of an airport's large
footprint and significant financial commitment, airport expansions need to be
adjacent to existing facilities, limiting space for on-site mitigation. It is common
for airports to continually expand due to demand for passenger or cargo services;
or change in aviation standards and runway needs. For these reasons, off-site
mitigation is more practicable; restoration or preservation of stream channels
within airport property is rarely proposed.
The US Army Corps of Engineers has reviewed the proposed mitigation plan and
has stated that they believe the plan is "adequate to compensate for the proposed
impacts". The have also stated that the proposed 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 DWQ was a part of the interagency
team that developed the Stream Mitigation Guidelines and routinely accepts
payment into the NC Ecosystem Enhancement Program (EEP) as compensatory
mitigation for projects of this type. Ms. Rebekah Newton of CEC spoke with Mr.
Ian McMillan of the DWQ-Raleigh Office on August 12, 2011. Mr. McMillan
indicated that payment into EEP is an acceptable form of mitigation and is in
compliance with the published guidelines.

Mr.Ian McMillan
08.26.11
Page 4 of 4
The applicant believes the information submitted in this package addresses all issues set
forth by the DWQ in their letter dated August 5, 2011. 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 R. Lmentddle,
Project Biologist Principal
Cc: NC D1visonyof-Water Quality-AshevilleChuc Cxanford
US Army Corps of Engineers—Tasha McCormick

Attachment A
DWQ Request for Additional Information
(dated August 5, 2011)

M®VR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H.Sullins Dee Freeman
Governor Director Secretary
August 5,2011
DWQ Project#07-1841,Ver. 4
Buncombe County
CERTIFIED MAIL:RETURN RECEIPT REQUESTED
Mr.Lew Bleiweis,Airport Director
Asheville Regional Airport Authority
61 Terminal Drive,Suite 1
Fletcher,NC 28732
Subject Property: Asheville Regional Airport Runway Rehabilitation,Parallel Taxiway and
Cargo Hold Expansion
Ut to French Broad River[030402,6-(54.5),BJ
REQUEST FOR MORE INFORMATION
Dear Mr.Bleiweis:
On June 14 2011,the Division of Water Quality(DWQ)received your application dated June 8,2011,
with Public Notice issued June 24,2011,and received by the DWQ on June 24,2011,to impact or fill 0.9
acres of 404/wetland and 2,076 linear feet of stream associated with rehabilitation of the existing runway
and development of a cargo facility with associated infrastructure at the existing Asheville Regional
Airport. The DWQ has determined that your application was incomplete and/or provided inaccurate
information as discussed below. The DWQ will require additiondf 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:
1. "Impact#8"is proposed for construction of a stormwater pond.The application indicates that
City of Asheville(COA)requirements related to construction in a floodway are forcing these
impacts to occur. Please provide documentation of any decision communicated by the COA that
confirms this statement.Additional options to address stormwater management needs must be
considered that avoid"Impact#8".
2. Stormwater Management Plan(SMP)—Project approval is not possible without documentation
that a SMP has been approved by the COA.
3. Potential Mitigation—The stream located at the South-west corner of the Airport Property
(adjacent to NC HWY 280)is severely downeut and heavily influenced by stormwater from the
airport property. During the onsite meeting(March 9,2010),NCDWQ and NCWRC both
expressed that restoration/stabilization of this channel should be part of the application package.
No plans for this stream segment have been submitted. A complete stream stabilization/
Wetlands,Buffers,Stonnwater,Compliance and Permitting Unit(WeBSCaPe)
1650 Mail Service Center,Raleigh,North Carolina 27699-1650 T�TOn..1.i1e�1, 1
Phone:[phone] FAX:[phone]. iV O1Carohna.
Interne[:http://por[al.ncdenr.orghNeb/Wq/ws
An Equal OpportunityI Affirmative Action Employer

Asheville Regional Airport Authority
Page 2 of 2
August 5,2011
restoration plan should be developed and submitted for mitigation credit as part of this
application.
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 returned and
you will need to reapply with a new application and a new fee.
This letter only addresses the application review and does not authorize any impacts to wetlands,waters or
protected buffers. Please be aware that any i;a pacts requested within your application are not authorized(at
this time)by the DWQ. Please call Ms.Karen Higgins or Mr.Ian McMillan at 919-807-6300 if you have
any questions regarding or would like to'set up a meeting to discuss this matter.
Sincerely,
Karen Higgins,Wetlands,Buffers,Stormwater,
ompliance and Permitting(WeBSCaPe),Supervisor
KH/ijm
cc: USACE Asheville Regulatory Field Office
Chuck Cranford,DWQ Asheville Regional Office
File Copy
Clement Riddle,CDC,224.South Grove Street, Suite f,Ilendersoriville,NC 28792
Filename: 07f 844Ve:4AshevilleRegionaWrportRuuwayPcbabilitationParallelTaxiwayA.1dCarboHoldExpansion(Buncombe)On_Y,old

Lear ater
U SEP 1 9 2011 i
WATER CUALITYS�CTION
C1earWater Environmental Consultants,Inc. _ ASHEVILLE REGIONAL 0=} 10E www cwenucom 5G � Fro w
September 14 2011 "'``
Ms. Tasha McCormick
US Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue,Room 208 ! a
Asheville,North Carolina 28801-2638
SEP Mr. Ian McMillan
NC Division of Water Quality � ��-0UALITY�
lN9SANDSTpi
1650 Mail Service Center
Raleigh,North Carolina 27699
RE: Asheville Regional Airport
Asheville Airport Cargo Hold Expansion and Parallel Taxiway
Buncombe County,North Carolina
Action ID 2010-00036
DWQ Project#07-1841,Ver. 4
Ms. McCormick and Mr. McMillan,
The Asheville Regional Airport Authority (AVL), AVCON, Inc., and C1earWater.
Environmental Consultants, Inc. (CEC) met with the City of Asheville (COA) and the
NC Division of Water Quality (DWQ) on September 12, 2011 to discuss stormwater
requirements at the proposed Asheville Airport Cargo Hold Expansion and Parallel
Taxiway (West Expansion)project site. The AVL requested the meeting so that the COA
and the DWQ could discuss option for review and approval of the required stormwater
management plan (SMP) and options for conditioning the 401 Water Quality
Certification so that the project could move forward while remaining within the bounds
of each agency's rules and regulations. The DWQ also asked to discuss Impact #8
(impact associated with the stormwater basin west of Old Fanning Bridge Road).
The DWQ has drafted the following condition to be included in the 401 Water Quality
Certification:
1. Stormwater Management
Before any permanent impervious surface (i.e.,building,roadway,taxiway,
tarmac or other similar surface), is installed as part of any phase of the project
described in this certification,the applicant must meet all of the following:
224 South Grove Street,Suite F
Hendersonville,NC 28792
829-698=9800-Tel---- —
828-698-9003 Fax

• The Stormwater Management Plan(SMP)must be approved in writing by
the City of Asheville. A copy of the approval letter and approved SMP must
be submitted to the Division prior to installation of any impervious surface
within the project site.If the project is phased,then the approved SMP for
each phase must be submitted to the Division prior to installation of any
impervious surfaces associated with that phase.
• The approved stormwater best management practices (BMPs)must be
constructed and operational before any permanent building or other structure
is occupied or becomes operational. If the project is phased,then the
approved BMPs for each future phase must be constructed and operational
before any permanent building or other structure associated with that phase is
occupied or becomes operational.
• The approved SMP,phased or otherwise, as well as drainage patterns must
be maintained in perpetuity.
• The SMP may not be modified without prior written authorization from the
SMP approval authority.
The above condition allows stream impacts to occur upon issuance of the 401 Water
Quality Certification and is acceptable to the AVL.
The DWQ requested that the AVL examine additional alternatives for the location and
configuration of the stormwater basin west of Old Fanning Bridge Road.
Recommendations from the COA and DWQ for the new basin included avoiding the
stream channel impacts and avoiding the floodway (if possible). After additional
evaluation, it was determined that the basin could be divided and reconfigured. The
attached modified site plan illustrates a new stormwater basin design that follows the
recommendations of the DWQ and COA. The new basin design eliminates Impact #8
from the project (280 linear feet). Total new impacts for the project site are 1,796 linear
feet of stream impact and 0.9 acre of wetland impact(no change).
The AVL respectfully request the. permit application be modified to reflect the
elimination of Impact#8 (280 linear feet) as discussed above.
Please do not hesitate to contact me at 828-698-9800 should you have any questions or
comments concerning this project.
Respectfully,
Rebekah L.Newton R. Clement Riddle,P.W.S
Project Biologist Principal
Copy Furnished:
NC Division of Water Quality; Asheville Regional Office—Chuck Cranford

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T age Check List
Date: 6/15/2011 Project Name: Asheville Airport Runway Rehab
DWQ#: 07-1841 Ver 4, F >.,:z,;,,;
Cqy t . $uncog.Lbre
To:' 401 Staff, Asheville Regional Office 6 2011
60-day Processing Time: 6/14/2011 — $ / FCTION
11wArER QUALITY AL OF I
i' AS -VILLF REGiONAI OFFICE
I
From: Ian McMillan 919 Telephone: [phone] y {
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❑ Restoration Project NOT for mitigation issued by RO (copy to Eric/Tammy for comments)
❑ NON-EEP mitigation project; Issued by RO (copy to Eric/Tammy for comments)
❑ EEP full Delivery project; issued by RO (copy to Eric/Tammy for comments)
❑ EEP design-Bid Build; issued by CO (copy to RO for comments)
A.This is an IP and will be issued out of the Central Office
Comments: As per our discussion regarding revision of the triage and delegation processes,
please review the attached file. Note that you are the first reviewer, so this file will need to be
reviewed for administrative as well as technical details. If you elect to place this project on
hold,please ask the applicant to provide your requested information to both the Central Office in
Raleigh as well as the Asheville Regional Office. As we discussed, this is an experimental,
interim procedure as we slowly transition to electronic applications. Please apprise me of any
complications you encounter, whether related to workload, processing times, or lack of a
"second reviewer" as the triage process in Central had previously provided. Also, if you think
of ways to improve this process, especially so that we can plan for the electronic applications, let
me know. Thanks!

�1
Individual Permit Application for --— Q �
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U.S. Army Corps of Engineers �NR
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Section 404 Permit etlan
and
North Carolina 401 Water Quality Certification
June 2011 ,
Applicant:
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Asheville Regional Airport Authority
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JUN 16 2011
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REGIONAL A I R P O R R WATER QUALITY SECTION '
ASH EVILLE REGIONAL OFFICE
^'"R:1t\`.�s:irjnlF,viiS.:s:..u,:::sA�.,cw.,..',:•a:;.�:.....s;.r.;....,....A..c'r;14.:w.,.•.a
Attn: Lew Bleisweis
61 Terminal Dr, Ste 1
Fletcher,NC 28732
Prepared by:
Clearwater Environmental Consultants,Inc.
224 South Grove Street, Suite F
Hendersonville,North Carolina 28792
828-698-9800
�1 •

C LIEARWATER ENVIRONM ENTAL CONSULTANTS, ffNC.
Department of the Army
Wilmington District, Corps of Engineers
Attn:Ken Jolly, Chief Regulatory Division
PO Box 1890
Wilmington,North Carolina 28402-1890
-and-
NC Division of Water Quality
Attn: Cyndi Karoly
1650 Mail Service Center
Raleigh,NC 27699-1650
1, the current landowner/managing partner of the property identified below,hereby
authorize ClearWater Environmental Consultants,Inc. (CEC) to act on my behalf as my
agent during the processing of permits to impact Wetlands and Waters of the US that are
regulated by the Clean Water Act and the Rivers and Harbors Act.
CEC is authorized to provide supplemental information needed for permit processing at
the request of the USAGE or DWQ.
Property Owner of Record: Asheville Regional Airport Authority
Property Owner Address: 61 Terminal Drive, Ste 1
Fletcher, NC 28732
Phone number: (828) 684-2226
Property Location: Hwy280 (Airport Road) w ��
OwnerManaging partner Signature: Lew Bleiweis, Airport Director
Date: April 14, 2010
718 Oakland Street
Hendersonville, Nodh Carolina 28791
Phone; 828-698-9800 Fax: [phone]
www.cwenv.com

of - Ica 41 V �}
APPLICATION FOR DEPARTMENT OF THE,ICE ARMY PERMIT O14113 APPROVAL NO.0710.003
(33C R 325) Expires October 1996
Public reporting burden for this collection of information is estimated to average 5 hours per response,including the time for reviewing instructions,searching existing
data sources,gathering and maintaining the data needed,and completing and reviewing the collection of information. Send comments regarding this burden estimate or
any other aspect of this collection of information,including suggestions for reducing this burden,to Department of Defense,Washington.Headquarters Service
Directorate of Information Operations and Reports,1215 Jefferson Davis Highway,Suite 1204,Arlington,VA 22202-4302;and to the Office of Management and
Budget,Paperwork Reduction Project(0710-0003),Washington,DC 20503. Please DO NOT RETURN your form to either of those addresses. Completed
applications must be submitted to the District Engineer having jurisdiction over the location of the proposed activity.
PRIVACY ACT STATEiVIENT
Authority: 33 USC 401,Section 10;1413,Section 404. Principal Purpose: "These laws require permits authorizing activities in,or affecting,navigable waters of the
United States,the discharge of dredged or fill material into waters of the Untied States,and the transportation of dredged material for the purpose of dumping it into
ocean waters. Routine Uses: Information provided on this form will be used iri evaluating the application for a permit. Disclosure: Disclosure of requested information
is voluntary. If information is not provided,however,,the permit application cannot be processed nor can a permit be issued.
One set of original drawings or good reproducible copies which show,the location and character of the proposed activity must be attached to this application(see sample
drawings and instructions)and be submitted to the District Engineer having jurisdiction over the location of the proposed activity. An application that is not completed
in full will be returned.
(ITEMS 1 THRU 4 7'0 BE Il.LED BY THE CORPS)
1,APPLICATION NO. 2. FIELD OFFICE CODE 3.DATE RECEIVED 4.DATE APPLICATION RECEIVED
(ITEMS BELOW TO BE EE LLED BY APPLICANT)
5.APPLICANT'S NAME 8.AUTHORIZED AGENT'S NAME&TITLE(an agent is not required)
Asheville Regional Airport Authority C1earWater Environmental Consultants.Inc.
Attn: Mr.Lew Bleiweis,Airport Director ATTN: Mr.R.Clement Riddle
6.APPLICANT'S ADDRESS 9.AGENT'S ADDRESS.
61 Terminal Drive,Suite 1 224South Grove Street,Suite F
Fletcher,North Carolina 28732 Hendersonville,North Carolina 29792
7.APPLICANT'S PHONE NOS.W/AREA CODE 10.AGENT'S PHONE NOS.W/AREA CODE
a. Residence N/A a. Residence N/A
b. Business [phone] b. Business [phone]
11. STATEMENT OF AUTHORIZATION
I hereby authorize,R.Clement Riddle and C1earWater Environmental Consultants,Inc.,to act on my behalf as my agent in the processing of this application and to
furnish,upon request,supplemental information in support of this permit application.
APPLICANT'S SIGNATURE DATE
12.PROJECT NAME-OR TITLE(see instructions)
Asheville Airport Runway Rehabilitation,Parallel Taxiway,and Cargo Hold Expansion(West.Expansion)
13. NAME OF WATERBODY,IF KNOWN(if applicable)
Unnamed tributaries to the French Broad River. 14.PROJECT STREET ADDRESS(if applicable)
Old Funning Bridge Road
15.LOCATION OF PROJECT
The project site is located south of Asheville,adjacent.to existing airport facilities
in Buncombe County,North Carolina.
16.OTHER LOCATION DESCRIPTIONS,IF'KNOWN,(see"Directions to the Site"below)
In.general,the site is bordered to the north and east by the existing airport,to the south by Airport Road,and to the west by the French Broad River.
17.DIRECTIONS TO THE SITE
To access the site from Asheville,take 1-26 East to Exit 40(Airpon Road/NC Highway 280). Tom right(south)onto Airport Road and continue approximately 1.25
miles. Past the airport,turn right(north)onto Old Fanning Bridge Road. The project site is to the right(east)of Old Fanning Bridge Road.
Q12�90
2,JUAL
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18. Nature of Activity(Description of project,include all features)
The project will include the development of land adjacent(immediately west)to the existing airport facility for the rehabilitation of the existing runway,
construction of a parallel taxiway,and cargo facilities. See attached description.
19. Project Purpose(Describe the reason or purpose of the project,see instructions)
The purpose of the proposed project is to conduct much needed runway maintenance without disrupting- airport operations. Additionally, the project
purpose includes file construction of air cargo facilities in a location that facilitates use of existing infrastructure.
See attached description.
USE BLOCKS 20-22 IF DREDGED AND/OR FILL MATERIAL IS TO BE DISCHARGED
20. Reason(s)for Discharge
The proposed activities are necessary to provide a level fill pad that is at grade with tine existing infrastructure at the airport_ This fill pad is necessary for
development of the proposed parallel taxiway and cargo facility. See attached description
21. Type(s)of Material Being Discharged and the Amount of Each Type in Cubic Yards
Material being discharged will be.in the form of culverts,clean fill dirt,and coal fly ash. See attached description.
22. Surface Area in Acres of Wetlands or Other Waters Filled(see instructions)
Approximately 2,076 linear feel of stream channel and 0.9 acre of wetland will be impacted by the development at the project site. See attached
description.
23. is Any Portion of the Work Already Completed? Yes ❑ No ® IF YES,DESCRIBE THE COMPLETED WORK
24. Addresses of Adjoining Property Owners,Lessees,Etc.,Whose Property Adjoins the Waterbody(If more than can be entered here,please attached
a supplemental list).
See attached list.
25. List of Other Certifications or Approvals/Denials Received from other Federal,State or Local Agencies for Work Described in This Application,
AGENCY TYPE APPROVAL* IDENTIFICATION M DATE APPLIED DATE APPROVED DATE DENIED
None.
26. Application is hereby made for a permit or permits to authorize the work described in this application. I certify that the information in this
application is complete and,@ccurate. I fill-tiler certify thatl possess the authority to undertake the work described herein or am acting as tite duly
authorized agentot the applicart.
11 t -�II
SIGNATURE:OI APPLICANT DATE SIGNATURE OF AGENT DATE
The application must be sighed by the person who desires to undertake the proposed activity(applicant)or it may be signed by a duly authorized agent if
the statement in block I t has been filled out and signed.
18 U,S,C.Section 1001 provides that: Whoever,in any manner within the jurisdiction of any department or agency of the United States knowingly and
willfully falsifies,conceals,or covers up any trick,scheme,or disguises a material fact or makes any false,fictitious or fraudulent statements or entry,shall
be fined not more than$10,000 or imprisoned not more than live years or both.

Adjoining Property Owners
Claude A. Lance City of Asheville
655 Old Fanning Bridge Road Post Office Box 7148
Fletcher,North Carolina 28732 Asheville,North Carolina 28802
Henderson County Brightstar Association,Inc.
100 N. King Street 2 Memory Lane
Hendersonville,North Carolina 28792 Norwalk, Connecticut 06853
Brite Stars, LLC David O. Kachman
2 Memory Lane 35 Bran Rick Lane
Rowayton, Connecticut 08653 Arden,North Carolina 28704
Roger Pinner James D. Elmore
78 Pinner Road 22 Li Jim Jo Lane
Arden,North Carolina 28704 Arden,North Carolina 28704
Peter Hall Jeffrey Eaton
63 Mountain.View Drive 31 Bran Rick Lane
Arden,North Carolina 28704 Arden,North Carolina 28704

TABLE OF CONTENTS
1.0 INTRODUCTION TO PROJECT...................................................................................1
1.1 Project Location........................................................................................................................................1
1.2 Jurisdictional Waters.................................................................................................................................1
2.0 BACKGROUND AND PRIOR PROJECT HISTORY.................................................3
3.0 EXISTING SITE CONDITIONS.....................................................................................5
3.1 Streams and Wetlands...............................................................................................................................5
3.2 Soils...........................................................................................................................................................5
3.3 Fish and Wildlife Use of the Project Site..................................................................................................5
3.4 Threatened and Endangered Species.........................................................................................................6
3.5 Cultural Resources....................................................................................................................................6
4.0 PROJECT PURPOSE.......................................................................................................8
5.0 PROPOSED PROJECT DEVELOPMENT....................................................................9
5.1 Cargo Area Plans.......................................................................................................................................9
5.2 Rehabilitation of the Existing Runway Using a Parallel Taxiway............................................................9
6.0 DISCUSSION OF ALTERNATIVES............................................................................11
6.1 Avoidance-Cargo Area.........................................................................................................................12
6.2 Avoidance-Rehabilitation of the Existing Runway Using a Parallel Taxiway.....................................15
6.3 Minimization and Justification of Impacts..............................................................................................20
6.4 Alternatives Conclusion..........................................................................................................................25
7.0 CONCEPTUAL MMGATION PLAN.........................................................................26
7.1 NC Ecosystem Enhancement Program(EEP).........................................................................................26
8.0 US ENVIRONMENTAL PROTECTION AGENCY 404(b)(1)GUIDELINES........27
8.1 Factual Determination.............................................................................................................................27
8.2 Potential Impacts on Physical and Chemical Characteristics of the Aquatic Ecosystem........................27
8.3 Potential Impacts to Biological Characteristics of the Ecosystem...........................................................29
8.4 Potential Impacts on Special Aquatic Sites.............................................................................................30
8.5 Potential Effects on Human Use Characteristics.....................................................................................31
8.6 Summary.................................................................................................................................................32
9.0 PUBLIC INTEREST CONSIDERATIONS..................................................................33
9.1 Conservation............................................................................................................................................33
9.2 Economics...............................................................................................................................................33
9.3 Aesthetics...........................................................................................................................6..........6.........33
9.4 General Environmental Concerns....................................................................................6..............6....6...34
9.5 Wetlands...........................................6......6............6....6..........................................................6..................34
9.6 Historic Properties..........................................................................................................................6.....-34
9.7 Fish and Wildlife Values.........................................................................................................................34
9.8 Flood Hazards..........................................................................................................................6..............35
9.9 Floodplain Values.............................................................................................................6.....................35
9.10 Land Use.................................................................................................................................................36
9.11 Navigation...............................................................................................................................................36
9.12 Shore Erosion and Accretion.......................................................................................................6...........36
9.13 Recreation...............................................................................................................................................36
9.14 Water Supply and Conservation.....................................................................................................6........36
9.15 Water Quality(Stormwater Management)..............................................................................................37
9.16 Energy Needs..........................................................................................................................................37
9.17 Safety.......................................................................................................................................................37
9.18 Food and Fiber Production......................................................................................................................37
9.19 Mineral Needs...................................................................................................................:.....................37
9.20 Considerations of Property Ownership...................................................................................................37
9.21 Needs and Welfare of the Public.............................................................................................................37
i

10.0 SECONDARY AND CUMULATIVE EFFECTS.........................................................38
11.0 SUMMARY......................................................................................................................39
LIST OF FIGURES
1. Vicinity Map
2. USGS Topographic Map
3. Stream and Wetland Map
4. Soils Map
5. Impact Map/Site Plan
6. Alternatives Map
LIST OF APPENDICES
Appendix A Cultural Resources Documentation
Appendix B NC EEP.Acceptance Letter
ii

1.0 INTRODUCTION TO PROJECT
The applicant, Asheville Regional Airport (AVL),proposes to construct a parallel taxiway
to aid in the rehabilitation of the existing runway. AVL also proposes to construct an air
cargo facility with associated infrastructure. The project, known as the Asheville Airport
Runway Rehabilitation, Parallel Taxiway, and Cargo Hold Expansion (West Expansion),
will include the development of land adjacent(west)to the existing airport facility.
1.1 Project Location
The West Expansion will be located south of Asheville and immediately west of
the existing airport in Buncombe County, North Carolina. A site vicinity map is
included for review (Figure 1). To access the site from Asheville, take I-26 East
to Exit 40 (Airport Road/NC Highway 280). Turn right(south)onto Airport Road
and continue approximately 1.25 miles. Past the airport, turn right (north) onto
Old Fanning Bridge Road. The project site is to the right (east) of Old Fanning
Bridge Road. One stormwater facility will be located to the left (west) of Old
Fanning Bridge Road. In general, the site is bordered to the north and east by the
existing airport, to the south by Airport Road, and to the west by the French
Broad River. A USGS topographic map is included for review(Figure 2).
1.2 Jurisdictional Waters
The majority of the airport property was delineated in November and December
of 2009 and April, November, and December of 2010 by C1earWater
Environmental Consultants, Inc. (CEC). A "Notification of Jurisdictional
Determination" was issued by the US Army Corps of Engineers (Corps) on
January 22, 2010 and February 9, 2011 under Action ID 2010-0036. A stream
and wetland map showing the approved delineation is included for review(Figure
3). Streams and wetlands within the Asheville Regional Airport North General
Expansion project boundary (Action ID 2007-03766-311) were delineated in June
of 2007 and March of 2008 by Carolina Wetland Services.
Jurisdictional streams within the property boundary are unnamed tributaries to the
French Broad River. The French Broad River is a navigable-in-fact water at the
Wilson Bridge east of Brevard. The unnamed tributaries are classified by the NC
Division of Water Quality (DWQ) as class `B" waters. There are also
jurisdictional wetlands and open waters (associated with the Broadmoor Golf
Links)located within the property boundary.
The site contains the following amounts of jurisdictional waters within the
property boundary:
Project Boundary Totals
Feature Amount Unit
Stream 16,629 linear feet
Wetlands 5.15 acres
Open Water 1.1 acres
1

An "Existing Site Conditions" section (Section 3.0) has been included in this
application for review and further describes the jurisdictional waters on site.
2

2.0 BACKGROUND AND PRIOR PROJECT HISTORY
The applicant received a permit for stream and wetland impacts on November 19, 2008
associated with the Asheville Regional Airport North General Expansion Project. The
Action ID associated with this project is 2007-03766-311.
An on-site jurisdictional determination meeting for the previously proposed Asheville
Airport Cargo Hold Expansion project area was held on December 9, 2009 with Ms. Liz
Hair of the Corps and Mr. Kevin Howell of the Asheville Regional Airport. The Corps
issued a "Notification of Jurisdictional Determination" on January 22, 2010 (Action ID
2010-0003 6).
A pre-application meeting was held for the Asheville Airport Cargo Hold Expansion
project on March 9, 2010. And, a subsequent permit application was submitted in April
of 2010. The project was put on Public Notice from May 20 to June 18, 2010. AVL
received comments in response to the Public Notice on July 19, 2010 and responded to
the comments on August 13, 2010. During this time, AVL was told by the Federal
Aviation Administration (FAA) that funding may become available for a runway
rehabilitation and parallel taxiway project during the next funding cycle. On September
2, 2010, an agency meeting was held at the Corps office to discuss the parallel taxiway
project and its effect on the Asheville Airport Cargo Hold Expansion project which was
still active at the time of the meeting. As a result of the agency meeting, the Corps and
the DWQ asked that AVL withdraw the active permit application and reapply for the
permit with the cargo area and West Expansion combined into a single application. The
Asheville Airport Cargo Hold Expansion project was withdrawn/retumed by the Corps
and the DWQ in October of 2010. Additionally, the Corps asked that the entire AVL
property be delineated as a part of the West Expansion. The property was delineated and
an on-site meeting to verify the delineation was held on February 1, 2011. The Corps
issued a "Notification of Jurisdictional Determination" for the remainder of the site on
February 9, 2011 (Action ID 2010-0036). The table below summarizes the project
history.
Date Action
March 9, 2010 Pre-application meeting for cargo facility.
April 2010 Submittal of permit application for cargo
facility.
May 20-June 18,2010 Public Notice comment period for cargo
facility.
July 19,2010 AVL received comments in response to the
Public Notice.
August 13,2010 AVL responds to comments.
September 2, 2010 Agency meeting held to discuss the parallel
taxiway.
Application for the cargo facility is
October 2010 withdrawn/returned by the Corps and
DWQ.
3

February 1,2011 Site verification for airport property.
February 9, 2011 Corps issues Notification of Jurisdictional
Determination.
4

3.0 EXISTING SITE CONDITIONS
The project site consists of existing AVL facilities and infrastructure, grassed areas
maintained by the airport and adjacent to the existing runway, small pockets of wooded
area, agricultural test plots for the NC Department of Agriculture's Mountain
Horticultural Corps Research Station, the Asheville Police Department gun range, and the
Broadmoor Golf Links. The site is relatively flat with an average elevation of
approximately 2,100 feet above mean sea level (MSL).
3.1 Streams and Wetlands
Perennial and intermittent streams are located within the project area. These streams
originate in close proximity to the toe-of-slope of existing AVL development, and are
moderately to severely affected by sediments. They are all unnamed tributaries to the
French Broad River and are classified by the DWQ as class`B"waters.
Wetland habitat types observed within the AVL: property boundary include:
forested, shrub scrub (dominated by woody vegetation less than 20 feet in height),
and herbaceous wetlands. Common species identified in on-site wetland habitats
include: red maple, tag alder (Alnus serrulata), sedges (Carex spp.), ironwood
(Carpinus caroliniana), smooth rush (Juncus effuses), Joe-pye weed (Eupatorium
spp), jewelweed (Impatiens capensis), smartweed (Polygonum spp.), black willow
(Salix nigra), elderberry (Sambucus 6 canadensis), and woolgrass (Scirpus
cyperinus).In general,the wetlands on-site are in fair condition.
3.2 Soils
The project site is located within the Mountains physiographic region of North
Carolina and more specifically the Broad Basins Ecoregion. Soils in this
ecoregion are characterized as mostly deep, well-drained, loamy to clayey
Ultisols, although there are variations between the uplands, the high and low
terraces, and the floodplains. Soil series present on site include: Arkaqua,
Bradson, Biltmore, Clifton, Dillard, Evard, French, Hemphill, Hayesville, Iotla,
Kinkora, Kanuga, Rosman, Statler, Tate, Udorthents,Unison, and Urban Land. A
soils map and legend have been attached for review(Figure 4).
3.3 Fish and Wildlife Use of the Project Site
Wildlife species inhabiting the site are limited to small mammals,.birds, and
aquatic species that may be present in the small streams on site. The airport
property is surrounded by a 16-foot high wildlife fence and a heavily maintained
grass safety area. For airport safety, this fence restricts large wildlife from
entering the airport property. Aural impacts from airplane traffic also limits the
amount of wildlife utilizing the area. Although site-specific studies and
inventories documenting species utilization of the West Expansion project area
have not been conducted by CEC, general observations of wildlife use were
recorded during the stream/wetland delineation and habitat evaluations.
5

3.4 Threatened and Endangered Species
Recent database information for listed species was acquired from the US Fish and
Wildlife Service (FWS) and the NC Natural Heritage Program (NHP) database in
December of 2010 and June of 2011 concerning the existence or potential
existence of federally or state listed species within 5 miles of the Asheville
Regional Airport. The NHP database identifies 0 element occurrences (EO) for
species with a Federal status of threatened or endangered within a 5-mile radius of
the project site.
During a desktop survey, the preferred habitat type for each listed species in
Buncombe and Henderson County was identified and compared to the known
habitat type identified within the airport property boundary: riparian forest,
mixed pine/hardwood forest, mixed upland hardwood forest, mountain mixed
pine forest, herbaceous cover, streams, and wetlands. Species were then
categorically excluded from the field survey based on their preferred habitat and
the commonality of the preferred habitat and the existing habitat.
The field surveys for this project were conducted in November and December of
2009; and April,November, and December of 2010. Potential fauna were identified
to the taxonomic unit level necessary to determine if the observed specimen is a
protected species. Flora were identified to the lowest taxonomic level readily
discernible in the field during the time of survey.
No Federally threatened or endangered species were observed on site during the
site visits. It is the opinion of CEC that Federally threatened and endangered
species will not be directly impacted by development at the Asheville Regional
Airport.
Although no federally listed species were identified during the surveys, because
of the transitory nature of some of the listed species and the particular flower and
fruiting periods of some plants, it is possible that species populations and
locations may change over time. Therefore, any potential findings at a later date
will be fully investigated and coordinated with appropriate agencies to prevent
potential adverse impacts.
The FWS did not provide comments during the Public Notice comment period for
the Asheville Airport Cargo Hold Expansion project.
3.5 Cultural Resources
A desk review of the National Register of Historic Places records maintained by the
NC State Historic Preservation Office (SHPO) indicates four historic properties
within 5 miles of the West Expansion project area: The Meadows (NPS Reference
# 80002847) located approximately 2.8 miles from AVL, the Mills River Chapel
(NPS Reference# 88002660) located approximately 3.4 miles from AVL, the Bent
Creek Campus of the Appalachian Forest Experiment Station (NPS Reference
#93000373) located approximately 4.5 miles from AVL, and the Demens-
6

Rumbough-Crawley House (NPS Reference # 82003435) located approximately
4.5 miles from AVL. It is the opinion of CEC that activities taking place within the
project boundary will not affect the integrity of the historic sites. The SHPO will be
notified via Public Notice about the projects and will be given the opportunity to
comment on the project and its potential affects on archaeological and cultural
resources.
A Phase I archaeological survey was conducted by TRC for the Asheville Regional
Airport North General Expansion project boundary (Action ID 2007-03766-311)
on September 24 and 26, 2008. The archaeological survey"identified no artifacts
or other indications of an archaeological site". It was recommended by TRC that
"no further archaeological work be required"in connection with the project.
During the Public Notice comment period for the Asheville Airport Cargo Hold
Expansion project, the ECBI and SHPO recommended that a comprehensive
survey of previously undisturbed portions of the project area be conducted to
identify any significant archaeological remains at the site. Based on
conversations with the Corps on July 21, 2010, the scope of the survey was to
include a 50-foot wide stream buffer on both sides of the impacted streams and
two areas of excavation reserved for stormwater facilities. The applicant
contracted with TRC to conduct a comprehensive survey at the site; field work
took place on August 11-13 and 16, 2010.
The "Management Summary for Intensive Archaeological Survey for Proposed
Additions to Asheville Regional Airport" dated August 23, 2010 from TRC was
submitted to the Corps on August 27, 2010. A copy of this summary was also
submitted to the SHPO and ECBI for their review. Site investigations by TRC
recovered one artifact described as a non-diagnostic prehistoric chert flake. The
isolated find was "recommended ineligible for the National Register of Historic
Places" and at the recommendation of TRC,no further work is required. By letter
dated September 27, 2010, SHPO concurred with this conclusion. To date, the
ECBI has not commented on the management summary. All correspondence
relating to cultural resources is included for review(Appendix A).
Additional impact area has been added to the project as a part of the West
Expansion; however, it is the opinion of CEC that additional cultural resource
investigations not be required. Two archaeological surveys have been conducted.
Both surveys identified no significant archaeological site and recommended no
further archaeological work in association with the projects. Both surveys note the
highly disturbed nature of the soils and site in general which resulted in the lack of
any significant find. Site and soil conditions are the same in the additional impact
area associated with construction of the parallel taxiway which in the opinion of
CEC would yield similar survey results. Unless new information leads to additional
concern about significant sites on AVL property, the applicant is not proposing
additional cultural resource surveys.
7

4.0 PROJECT PURPOSE
The purpose of the proposed project is to conduct much needed runway maintenance
without disrupting airport operations. Additionally, the project purpose includes the
construction of air cargo facilities in a location that facilitates use of existing
infrastructure.
8

5.0 PROPOSED PROJECT DEVELOPMENT
The proposed project includes the rehabilitation of the existing runway aided by the
construction of a parallel taxiway. Additionally, the proposed project includes the
construction of a cargo area which includes a small taxiway, cargo apron, a
warehouse/cargo building, truck loading docks and associated infrastructure. The cargo
area can be constructed without completion of the parallel taxiway and runway
rehabilitation. AVL proposes to complete impacts in 2 phases (issued concurrently in 1
authorization). Phase 1 will include impacts for the cargo area and associated
infrastructure (to take place immediately after permit issuance) and Phase 2 will include
impacts associated with rehabilitation of the existing runway (estimated to begin in
2013). Stream and wetland impacts for both phases total 2,076 linear feet and 0.9 acre.
Due to the time it will take to complete this project, AVL is requesting a 10-Year permit
authorization.
5.1 Cargo Area Plans
The applicant proposes to permanently impact 1,505 linear feet of stream channel
to achieve the previously stated project purpose through the development of the
proposed cargo facility and associated infrastructure. The cargo area can be
constructed without completion of the parallel taxiway and runway rehabilitation.
There are 3 permanent stream impacts associated with development of the cargo
area. Impacts have been identified on the site plan, which is enclosed for review
(Figure 5c). Upland fill areas for the project will include fly ash from the
Progress Energy power plant at Lake Julian in Buncombe County. All fly ash fill
material will be handled, utilized, and placed in accordance with rules and
regulations outlined in 15A NCAC 13B administered by the State of North
Carolina. Only clean fill material (including culverts and French drains) will be
used to fill streams and wetlands; fly ash will not be used in these areas. The
cargo area also includes a stormwater pond west of Old Fanning Bridge Road.
Construction of the stormwater pond includes stream impacts. Permanent fill
impacts associated with facility construction are listed in the table below.
Stream
Impact LF
6 850
7 '375
8 280
Total 1,505
5.2 Rehabilitation of the Existing Runway Using a Parallel Taxiway
AVL proposes to permanently impact 575 linear feet of stream and 0.9 acres of
wetland to achieve the previously stated project purpose through the construction
of a parallel taxiway (used as a temporary runway) that will aid in the
rehabilitation of the existing runway. There are 5 permanent stream and wetland
impacts associated with development of the parallel taxiway. Impacts have been
identified on the site plan, which is enclosed for review (Figure 5b). Upland fill
9

areas for the project will include fly ash from the Progress Energy power plant at
Lake Julian in Buncombe County. All fly ash fill material will be handled,
utilized, and placed in accordance with rules and regulations outlined in 15A
NCAC 13B administered by the State of North Carolina. Only clean fill material
(including culverts and French drains) will be used to fill streams and wetlands;
fly ash will not be used in these areas. Permanent fill impacts associated with
parallel taxiway construction are listed in the table below.
Stream Wetland
Impact LF Impact Acre
2 421 1 0.12
4 150 3 0.27
Total 571 5 0.51
Total 0.9
10

6.0 DISCUSSION OF ALTERNATIVES
This discussion of alternatives is submitted by the applicant to assist the Wilmington
District, Corps in evaluating the application for authorization to discharge dredged or fill
material into waters of the United States, including wetlands, under Section 404 of the
Clean Water Act, 33 U.S.C. § 1344 at the AVL West Expansion in Buncombe County,
North Carolina.
An analysis of the Section 404(b)(1) Guidelines (Guidelines) requirements for
consideration of alternatives as required by 40 C.F.R. 230.10(a) is set forth below.
The Guidelines' alternatives requirements provide that "no discharge of dredged or fill
material shall be permitted if there is a practicable alternative to the proposed discharge
which would have less adverse impact on the aquatic ecosystem, so long as the
alternative does not have other significant adverse environmental consequences." [See
40 C.F.R. 230.10(a) (emphasis added).] The record must contain "sufficient information
to demonstrate that the proposed discharge complies with the requirements of Section
230.10(a) of the Guidelines. The amount of information needed to make such a
determination and the level of scrutiny required by the Guidelines is commensurate with
the severity of the environmental impact (as determined by the functions of the aquatic
resource and the nature of the proposed activity) and the scope/cost of the project." [See
Corps/EPA Memorandum to the Field "Appropriate Level of Analysis Required for
Evaluating Compliance with Section 404(b)(1) Guidelines Alternatives Requirements,"p.
2, dated August 23, 1994, hereinafter the "Memorandum."] As noted in the
Memorandum on pages 3-4, the 404(b)(1) Guidelines "only prohibits discharges when a
practicable alternative exists which would have less adverse impact on the aquatic
ecosystem." [See Memorandum.] "If an alleged alternative is unreasonably expensive to
the applicant, the alternative is not practicable." [See Guidelines Preamble, "Economic
Factors,"45 Federal Register 85343 (December 24, 1980).]
Practicable alternatives for the project are those alternatives that are "available and capable
of being done after taking into consideration costs, existing technology, and logistics in
light of overall project purposes." [See 40 C.F.R. 230.10(a)(2).] Clarification is provided
in the Preamble to the Guidelines on how cost is to be considered in the determination of
practicability. An alternative site is considered "available" if it is presently owned by the
applicant or "could reasonably be obtained, utilized, expanded or managed in order to
fulfill the basic purpose of the proposed activity."40 C.F.R. § 230.10(a)(2).
The intent is to consider those alternatives, which are reasonable in terms of the overall
scope and cost of the proposed project. The term economic [for which the term "costs"
was substituted in the final rule] might be construed to include consideration of the
applicant's financial standing, or investment, or market share, a cumbersome inquiry
which is not necessarily material to the objectives of the Guidelines.
11

The Environmental Protection Agency (EPA) 404(b)(1) Guidelines state that, "we have
chosen instead to impose an explicit, but rebuttable presumption that alternatives to
discharges in special aquatic sites are less damaging to the aquatic ecosystem, and are
environmentally preferable." Of course, the general requirements that impacts to the
aquatic system not be acceptable also applies. This presumption "...contains sufficient
flexibility to reflect circumstances of unusual cases" (249 Fed. Reg., 85339, December
24, 1980). It is clear from these stipulations that a preferable alternative may allow
filling in certain wetland areas and subsequent mitigation and/or management of other
areas.
6.1 Avoidance—Cargo Area
The applicant was willing to considered sites other than the proposed project site
for development of the proposed cargo facilities at the airport. A set of criteria
was developed to aid in the search for a site and ultimate selection of a site.
6.1.1 Site Criteria—Cargo Area
A. Location—Airfield Access
In order to meet the stated project purpose, the cargo area must be
located in close proximity to the airfield, in an area that would
provide operationally feasible access to the runway by cargo
planes.
B. Site Availability and Land Use Compatibility
The cargo facility must be sited on existing airport property in a
location that does not hinder existing airport functions or
development of the parallel taxiway.
C. Site Accessibility
The cargo facility needs to be easily accessible to cargo trucks
including convenient off-site road access.
6.1.2 Project Alternatives—Cargo Area
The project as proposed, along with eight alternatives, were considered
when determining the most practical alternative. A map which includes
alternative locations within existing airport property is included for review
(Figure 6).
A. Areas North of Existing Runway
Two areas identified as "A" on Figure 6 were evaluated for
consideration for this project. Road access for cargo trucks could
easily be provided from Pinner Road; however, cargo plane access
would present significant challenges. The area immediately north
of the existing runway (labeled as "C") is a runway safety area. A
runway safety area is designed to reduce the risk of damage or
injury if an airplane overshoots or undershoots a landing. For this
reason, obstructions (airport infrastructure, buildings, parked
12

aircraft, etc.) are not permitted in this area. Without the use of the
runway safety area, Area A (to the east) becomes isolated from the
runway. Runway access is critical because cargo planes must land
and taxi to specific cargo hold areas which must be separated from
passengers and passenger cargo. Additionally, the airport is
proposing the parallel taxiway as a part of this project. This future
taxiway would be to the west of the existing runway. Area"A" (to
the west)needs to be reserved as a runway safety area.
Because access to and from the runway is an absolute necessity for
this project (Criteria A) and the project must be sited in an area
that will not hinder development of the parallel taxiway, areas
north of the existing runway labeled as "A" were excluded as
probable locations for this project.
B. Area East of Existing Runway
The area identified as `B" on Figure 6 was evaluated for
consideration for this project. Area `B" is the location of the
Asheville Regional Airport North General Expansion Project
which is currently under construction. Cargo facilities should be
separated from general aviation activities due to differing site
requirements (Criteria B). Cargo operators use larger planes that
require dedicated, secure areas for loading and unloading between
the ground facility and the aircraft. Pavement design and
geometrical requirements differ greatly for cargo facilities when
compared to general aviation. Therefore, cargo facilities can not be
co-located with general aviation and Area `B" was excluded as a
probable location for this project.
C. Area Immediately North of Existing Runway
The area identified as "C" on Figure 6 was evaluated for
consideration for this project. Area "C" is a runway safety area
and an instrument landing system (ILS) critical area. A runway
safety area is designed to reduce the risk of damage or injury if an
airplane overshoots or undershoots a landing. The ILS critical area
must remain clear as planes approach the airport for landing.
Buildings, vehicles, or other planes in the ILS broadcast path could
cause incorrect information to be transmitted to pilots. For
obvious safety reasons, buildings and airport infrastructure can not
be located in runway safety areas or ILS critical areas (Criteria B).
Location"C"was excluded as a probable location for this project.
D. Area West of the Existing Runway
The area identified as "D" on Figure 6 was evaluated for
consideration for this project. Construction of a parallel taxiway is
proposed in this location. Because of the linear nature of the
13

airport property and location of existing infrastructure, Area "D"
must be reserved for parallel taxiway construction (Criteria B).
Because of the addition of a parallel taxiway as a part of the
proposed project, location"D"was excluded as a probable location
for the cargo area.
E. Area South of the Existing Runway
The area identified as "B" on Figure 6 was evaluated for
consideration for this project. Area "C" is a runway safety area
and an ILS critical area. A runway safety area is designed to
reduce the risk of damage or injury if an airplane overshoots or
undershoots a landing. The ILS critical area must remain clear as
planes approach the airport for landing. Buildings, vehicles, or
other planes in the ILS broadcast path could cause incorrect
information to be transmitted to pilots. For obvious safety reasons,
buildings and airport infrastructure can not be located in runway
safety, areas or ILS critical areas (Criteria B). Location "E" was
excluded as a probable location for this project.
F. Area West of the Existing Runway
The area identified as "F" on Figure 6 was evaluated for
consideration for this project. Runway access could be provided
for this area; however, road access for large cargo trucks would
present a challenge (Criteria C). The existing roadway system
would require truck traffic to travel approximately 4 miles via
Pinner Road, Glen Bridge Road, and Bradley Branch Road to
access I-26 from the north or necessitate construction of a new
road to access Old Fanning Bridge Road approximately- 1 mile
south. Road access is not practical for this location. Because of
road access, location "F" was excluded as a probable location for
.this project.
G. Area Southwest of Existing Runway
The area identified as "G" on Figure 6 was evaluated for
consideration for this project. A portion of Area "G" is west of
Old Fanning Bridge Road. This area was eliminated because of
the inability to transport planes across the road (Criteria A). Area
"G" east of Old Fanning Bridge Road is isolated from the runway
because of the runway safety area(Criteria B). Although Area"G"
could be accessed through portions of Area"D", Area"D"is being
reserved for the parallel taxiway (Criteria B). Additionally, this
Area"G"is small and streams and wetlands`exist in this area. Due
to the size of Area "G" east of the road, stream and wetland
impacts could not be avoided in this location. Because of runway
access, size, and stream and wetland impacts, location "G" was
excluded as a probable location for this project.
14

H. No-Build
The proposed cargo area will provide the necessary improvements
to accommodate the growing air cargo demand for the Western
North Carolina(WNC) region. The project as proposed can not be
completed without the stream impacts applied for in this
application. If the project is not completed, the demands for air
cargo in WNC will not be met.
I. Project As Proposed
The project as proposed meets the stated project purpose and is
within the project selection criteria listed above. The proposed
project site area has access to existing roads fit for large cargo
trucks and access to the existing runway and airport facilities.
Construction within the proposed project area will not hinder
existing airport activities and is not in a runway safety area or ILS
critical area. Wetlands impacts associated with the cargo area have
been completely avoided and stream impacts have been reduced to
the minimum amount necessary to complete development. The
cargo area as proposed is the most feasible and least damaging
practical alternative.
6.2 Avoidance—Rehabilitation of the Existing Runway Using a Parallel Taxiway
The applicant was willing to considered several different development options for
the rehabilitation of the existing runway. A set of criteria was developed to aid in
the selection of development options.
6.2.1 Development Criteria—Parallel Taxiway
A. Continuance of AVL Services
The rehabilitation of the existing runway and construction of the
parallel taxiway needs to provide for the continuance of services at
AVL.
B. Correction of Non-Standard Separation and Gradient
Development at the site needs to correct the non-standard
separation between the existing taxiway (Taxiway A) and the
runway, along with the non-standard longitudinal gradient at the
ends of the runway.
C. Maintenance of Safe Airport Operation
Operation of the AVL during construction must be done in a safe
manner which is in compliance with FAA recommendations.
D. Improvement of Pavement Condition
Rehabilitation of the existing runway needs to address the
deteriorating condition of the runway pavement.
15

6.2.2 Proiect Alternatives—Parallel Taxiwav
A. Runway Rehabilitation with Full-time Closure
This alternative would close the runway, and the airport, for 150 calendar
days (approximately 5 months) and cost approximately $8,966,000 to
construct. The existing runway pavement would be ground down, or
milled, leaving the remaining runway sub-base exposed. Any cracks or
other pavement distresses that are present in the runway sub-base would
be repaired, and a new asphalt pavement overlay would be applied to the
existing runway and grooved (Criteria D). The modification to airport
design standard involving the runway longitudinal gradient would be
corrected with the pavement overlay if possible (Criteria B).
This alternative is not reasonable since it would close the airport for
approximately 5 months (Criteria A). Airport operations from both
general aviation and commercial users would be negatively impacted,
which would affect the economy of the Asheville area as well as reduce
transportation options to and from the Asheville region. The nearest
airport to Asheville with commercial air service is Greenville Spartanburg
International Airport, which is 64 miles south, taking approximately 1
hour and 10 minutes to reach by car. Other nearby airports with
commercial service are Bristol Johnson Kingsport Airport in Blountville,
Tennessee, McGhee Tyson Airport south of Knoxville, Tennessee, and
Charlotte International Airport, in Charlotte, North Carolina, all of which
take between an 1.5 to 2.5 hours to reach by car from Asheville.
This would disrupt the operations of the commercial air carriers during
and after this 5-month closure period. Most major airlines would not want
their operations stopped for this amount of time since it would result in
economic impacts to their companies and employees. As a whole, the
economic impacts to the airport would be substantial, as the airport
directly employs 289 people, including 62 employees of the Asheville
Regional Airport Authority, 70 car rental employees, 85 airline
employees, 57 FBO aircraft maintenance employees, and 16 restaurant
employees.
Similarly, general aviation users would have to use another airport in the
area during this time. The Hendersonville-Winkler Airport (OA7) is
located in Hendersonville, North Carolina, 15 miles south of AVL, taking
approximately 20 minutes to reach by car. Although it is the nearest
general aviation airport, it has a runway of 3,075 feet by 40 feet, operates
with displaced thresholds on both ends of the runway, and has a pavement
strength of 10,000 pounds. Therefore, it would not be able to support all
of the general aviation aircraft currently operating at AVL.
16

This alternative also fails to remedy the non-standard separation that exists
between the Taxiway A centerline and runway centerline (Criteria B).
Due to the substantial local and regional economic and air traffic impacts
of closing the airport, the negative effect to both general aviation and
commercial aircraft operations at the Airport, and failure to remedy non-
standard conditions, this alternative was eliminated from further
consideration.
B. Runway Rehabilitation with Nighttime Closure
In that this is also a rehabilitation project, the airfield layout and safety
areas would remain unchanged. Under this alternative however, the
existing runway would be rehabilitated without closing the airport. To
accomplish this,the runway would be closed at night between the hours of
midnight and 5 A.M. for construction, and normal airport operations
would be allowed during the remaining hours of the day. Construction of
this alternative would be anticipated to take 370 days (approximately 12
months) due to the limited 5 hour timeframe for construction each day, as
compared to approximately 5 months under the Runway Rehabilitation
with Full-time Closure Alternative. The estimated cost for this alternative
is$11,672,000.
Under this alternative, the existing pavement would be rehabilitated
(Criteria D) as with the full-time closure alternative and the modification
to airport design standard involving the runway longitudinal gradient
would be corrected with the pavement overlay if possible(Criteria B).
While this alternative keeps the runway open during construction, it would
still impact airport operations between midnight and 5:00 A.M.
Approximately 5% of daily airport operations (or 9 flights) occur between
10:00 P.M. and 7:00 A.M. Due to the single runway configuration at
AVL, if flights come in late, or an airplane needs to land at the airport for
emergency reasons, this alternative would pose problems (Criteria A). In
addition, it is widely recognized that nighttime construction results in
difficult construction phasing and a lower quality of construction due to
the limited work hours (5-hour increments that include ramp up, mill
runway surface, pave, core, trench and run conduit for lighting, paint
temporary pavement markings, and shut down; with the need for the
airfield to be fully operational upon the contractor's departure each
morning). Nighttime construction activity would also result in a greater
temporary noise impact on neighboring residential areas than that
occurring during daytime hours when many residents would be away from
their homes. Finally, this alternative fails to fix the non-standard
separation that exists between the Taxiway A centerline and runway
centerline (Criteria B). For these reasons, this alternative was eliminated
from further consideration.
17

C. Runway Rehabilitation/Reconstruction in Place and Construction of a
New Parallel Taxiway
Under this alternative, a new 8,000-foot by 100-foot taxiway would be
constructed over a 3-year period on the western side of the airport
property. The alternative evaluated in the 2009 rehabilitation and
reconstruction report called for the new taxiway centerline to be located
400 feet from the existing runway centerline to meet FAA airport design
standards. However, upon further evaluation, it was noted that a proposed
new taxiway to Runway 16-34 centerline separation of 475 feet would
allow for future reconstruction of the runway, with a 75-foot shift west to
bring the existing Runway 16-34 to Taxiway A centerline separation into
compliance with the FAA airport design standards.
The runway would remain in place and be rehabilitated/reconstructed
under this alternative; however the non-standard separation would not be
corrected (Criteria B). It is not considered feasible for this amount of
financial investment to be made on new runway and taxiway pavements
without correcting the existing Runway 16-34 to Taxiway A centerline
separation. Thus, this alternative was eliminated from further
consideration.
D. Runway Construction While Using Taxiway A as a Temporary
Runway
Taxiway A, which is a full-parallel taxiway located between the runway
and terminal area, would be widened from 75 feet to 100 feet, and striped,
signed, and lighted for use as a temporary runway. Under this alternative,
aircraft operations would be moved to this temporary runway. The
existing runway would be reconstructed and moved 75 feet to the west to
correct the non-standard separation between the runway and Taxiway A.
The runway would have new airfield lighting systems, striping, and
signage. The navigational aids (NAVAIDS) would be relocated to
accommodate the 75-foot runway shift to the west. Once the runway
reconstruction is completed, airport operations would be moved back to
the runway and Taxiway A would return to its original use.
This alternative was eliminated from further consideration due to a variety
of safety issues relating to operations at the airport (Criteria C). Using
Taxiway A as a temporary runway would move airport operations in very
close proximity to the airport terminal and other landside facilities. There
would not be adequate space for the runway safety area and runway object
free areas. Employee and rental car parking lots would be located within
the runway safety area, and gradient constraints would be present that
would pose problems for construction of the runway safety area. The
terminal apron, a portion of the T-hangar area, and parking lots would be
located within the runway object free area. In addition, aircraft would
have to use the temporary runway to taxi to and from the terminal apron,
18

which would also pose safety issues and is generally not recommended by
the FAA. This is not considered a viable alternative.
E. Runway Reconstruction While Using a New Parallel Taxiway as a
Temporary Runway—Project As-Proposed
This alternative would construct a new parallel taxiway to the west of the
runway that would be 8,000 feet in length and 100 feet wide. It would be
constructed over a 3-year period. The new taxiway centerline would be
475 feet from the existing runway centerline to exceed FAA airport design
standards (Criteria B). This new taxiway would be striped, lighted, and
signed for use as a temporary runway for approximately 12 months while
the existing runway would be reconstructed. Airport operations and
services would not be suspended during the construction (Criteria A) and
the temporary runway would be far enough away from existing facilities
to not cause safety concerns (Criteria C).
The existing runway would be removed and a new base, sub-base, and
overlay would be constructed 75 feet to the west of the existing runway
(Criteria D). This new runway would meet FAA airport design standards,
including correction of the longitudinal gradient so that the first and last
quarter of the runway would meet the 0.5 percent gradient(Criteria B).
Once the runway reconstruction was finished, airport operations would
move back to the primary runway and the new parallel taxiway would be
designated as a taxiway. This alternative is anticipated to take a total of 4
years to construct and cost approximately$69,554,000.
F. No Action
The runway was visually and geotechnically evaluated to determine the
current pavement condition. See Section 6.3.2 below for detailed
information. As of December 2008, the runway pavement at AVL had a
weighted Pavement Condition Index (PCI) of 50, with the center section
having a lower PCI(42)than the end sections (54), significantly below the
satisfactory PCI of 70 or higher. Based on the N icroPAVER model, the
PCI is anticipated to decrease rapidly by 2013, with the weighted PCI of
the runway pavement being 35, or very poor condition, and in need of
reconstruction.
The airport layout plan lists the existing 325-foot centerline to centerline
separation between Taxiway A and Runway 16-34 as a modification of
FAA airport design standard that was approved on August 16, 1978. The
other approved modification of FAA airport design standards is that the
longitudinal grade of the runway does not meet 0.5 percent in the first and
last quarter of the runway. This modification was also approved on
August 16, 1978. Under the no-action alternative, these modified
standards would not be addressed (Criteria B). The FAA requires
19

federally obligated airports to address non-standard design conditions
when associated projects are initiated. By not addressing the
modifications to standards under the no-action alternative, existing airfield
design issues would not be improved.
6.3 Minimization and Justification of Impacts
6.3.1 Cargo Facility
AVL has received multiple inquiries from air cargo companies within the
previous two years, most recently in March of 2011, and has been a short-listed
location for one of their proposed facilities. With its 8,001-foot long runway,
AVL is the, best equipped airport in WNC to serve the air cargo market.
Furthermore, the airport has excellent access to I-26 for north-south transport,
with Interstate 40 less than 10 miles away, providing for east=west transport.
Asheville is centrally located along the east coast and also in close proximity to
the region's major business centers of Knoxville, Greenville, Charlotte, Atlanta,
and Raleigh. AVL is an essential part of the economic development of the area
and air cargo activity provides an opportunity for growth at the airport. The
proposed project would plan for air cargo transport facilities in a location that best
utilizes existing infrastructure and developable airport property.
The proposed cargo facility will provide the necessary improvements to
accommodate the growing air cargo demand for the WNC region. AVL is the
only FAA air traffic control towered airport in WNC, as well as, the only FAA
part 139 certificated airport and the only airport equipped to adequately serve this
market. AVL is an essential part of the economic development of the area and air
cargo is a growing component for the airport and region.
The air cargo facility must have direct access to the runway and taxiway system at
AVL as well as access to the surrounding public roadway infrastructure for the
safe and efficient movement of aircraft, trucks, and other ground vehicles. FAA
design criteria dictate the separation between airfield movement areas such as
runways and taxiways as well as the separation of the aircraft apron areas from
the connecting taxiway. Additionally, the cargo site should be segregated from
the general aviation area and commercial service areas of the airport for security
and operational reasons.
AVL has a need to expand in order to meet the needs of the regional aviation
industry. Airport property is linear in nature and limited by the existing
boundaries of the French Broad River, Interstate 26, and NC Highway 280. Due
to the limited real estate available for aviation use with access to taxiways,
runway systems, and public roadways, the proposed development area is the
airport's best alternative and most feasible development parcel to accommodate
the proposed cargo area.
20

I
It is the purpose of this project to meet the economic development needs of the
Asheville, Buncombe County and WNC by providing airside access to both the
airfield and public roadway systems with an approximately 10-acre site to
accommodate an approximately 189,000-square foot aircraft apron,
approximately 50,000 square feet of building, and approximately 200,000 square
feet of roadway and parking. The proposed layout has been designed to meet FAA
design criteria.
The proposed stormwater pond west of Old Fanning Bridge Road will impact
jurisdictional stream channels. This stormwater pond was originally designed to
avoid the stream channel and the proposed location of the stormwater pond was
discussed with the City of Asheville. However, by designing the stormwater pond
to avoid streams and wetlands, the only remaining practicable location was within
the floodway of the French Broad River. The City of Asheville requires that
stormwater facilities be located out of the floodway. As a result of this
requirement, the stormwater pond has been redesigned but in doing so causes
unavoidable impacts to the stream channel. Developable land at the southern end
of the airport is at a premium and the most practical location for stormwater pond
is west of Old Fanning Bridge Road. Upon completion of the cargo facility the
entire stream channel upslope of the stormwater pond will be impacted.
6.3.2 Runway Rehabilitation and Parallel Taxiway
The proposed project will address the critical pavement deterioration and non-
standard design issues on Runway 16-34. The rehabilitated runway will meet
FAA criteria for pavement condition while addressing existing FAA non-standard
design issues and minimizing operational impacts to the airport from
construction/rehabilitation.
The need for the proposed runway improvements was recognized as a result of
recent airfield evaluations that identified deficient runway pavement and lighting
systems (lighting systems are not discussed in this application). Improvements to
the runway have prompted addressing the FAA non-standard design
modifications. Inquiries by prospective air cargo tenants have highlighted the
need for the associated cargo apron project.
In 1958, Runway 16-34 was constructed at a length of 6,500 feet and a width of
150 feet. Aircraft operations at AVL began in 1961. A 1,500-foot runway
extension was completed in 1979, bringing Runway 16-34 to its current
dimensions: 8,001 feet long by 150 feet wide. Although four runway overlays
have been completed since it was originally constructed (1969, 1979, 1987, and
most recently in 1995),the runway has never been reconstructed.
According to the FAA:
Failure to replace deteriorating pavement increases airport maintenance
costs and can result in damage to aircraft propellers and engines, pooling
21

of water and ice deposits, and eventually potholes that can damage landing
gear. Airfield lighting cables and fixtures deteriorate with age, resulting in
dim and unreliable lighting if they are not replaced. Reconstruction is
included in the National Plan of Integrated Airport Systems (NPIAS) when
normal maintenance procedures are no longer economical and effective.
In 2009, a Runway 16-34 Rehabilitation/Reconstruction — Phase I Runway and
Lighting Condition Assessment was completed as part of AVL's Pavement
Management Program. The runway was visually and geotechnically evaluated to
determine the current pavement condition. The 2009 report also provides a
detailed evaluation of the existing airfield lighting and signage systems and
discussion of the runway to taxiway separation standards. The results of this 2009
report are discussed below.
An evaluation of the Runway 16-34 pavement and its associated airfield lighting
system was completed in 2009 (actual pavement inspection date was December 2,
2008). The 2009 study of airfield pavements was conducted using procedures
provided in FAA AC 17 150/5380-63, Guidelines and Procedures for
Maintenance of Airport Pavements, and in accordance with ASTM D 5340
Standard Method for Airport Pavement Condition Index Surveys. Both of these
guidelines use the Pavement Condition Index method of visually assessing and
quantifying pavement condition. The PCI for airport pavements was originally
developed by the US Army Corps of Engineers and has been adopted by the FAA.
PCI is a numerical rating index between 0 and 100 of the pavement's surface
condition, which provides a measure of functional performance. The pavement
condition assessment includes the division of airfield pavement into "sections"
based first on type of use (i.e. runway, taxiway, or apron), then based on
pavement structure, existing condition, or airfield traffic distribution (i.e. the keel,
or center 50-to 75-foot portion of runway is separated from outer sections due to
higher traffic usage). Each airfield section is then further divided into "sample
units:"
A PCI is assessed for each sample unit and then the average PCI for the section is
calculated. An area-weighted process is used to calculate the combined rating for
multiple sections when determining an' overall_ weighted PCI of the runway,
taxiway, or apron. This weighted calculation is done by multiplying each section
PCI by its area (square footage), adding it to the same calculation of all other
sections for that facility (i.e. runway, taxiway, or apron), and then dividing the
sum by the total square footage of the facility.
As depicted in the tables below, pavements with PCI values ranging from 60 to
100 typically will benefit from preventative maintenance; such as crack sealing
and surface treatments. Pavements with a PCI of 40 to 60 may require major
rehabilitation, such as an overlay. When the PCI value falls below 40,
reconstruction is the only viable alternative due to the substantial degradation of
the pavement structure. By definition, pavements with PCI values above 86 rated
22

as "Good" and below 10 are rated as "Failed." Satisfactory pavements are
considered to be those with a PCI of 71 or higher.
RIX
Pavement Condition Index C Re air Needed
86-100(Good)
71-85(Satisfactory) Preventative Maintenance
56-70(Fair)
41-55(Poor)
Major Rehabilitation
26-40(Very Poor)
11-25(Serious) Reconstruction
0-10(Failed)
SOURCES:FAA AC 150/5380-6,Guidelines and Procedures for Maintenance of Airport
Pavements and Roy D.McQueen.
w
Rang Definition
86-100 GOOD:Pavement has minor or no distresses and should require only routine maintenance.
71-85 SATISFACTORY: Pavement has scattered low-severity distresses that should require only
routine maintenance.
56-70 FAIR: Pavement has a combination of general low-and medium-severity distresses. Near-
term maintenance and repair needs may range from routine to major.
POOR:Pavement has low-,medium-,and high-severity distresses that probably cause some
41-55 operational problems. Near-term maintenance and repair needs may range from routine up
to a requirement for reconstruction.
VERY POOR:Pavement has predominantly medium-and high-severity distresses that cause
26-40 considerable maintenance and operational problems. Near-term maintenance and repair
needs will be intensive in nature.
11-25 SERIOUS:Pavement has mainly high-severity distresses that cause operational restrictions;
immediate repairs are needed.
0-10 FAILED:Pavement deterioration has progressed to the point that safe aircraft operations are
no longer possible;coin lete reconstruction is required.
=SOURCEAS TM D4350,Standard Method for Airport Pavement Condition Index Surveys,2004
Based on the results of the 2009 Pavement Evaluation, Runway 16-34 has an
overall weighted PCI average of 50, which is considered "Poor" and falls below
the desired level of 70. More specifically, the center section of the runway has a
23

weighted PCI average of 42, while the outside portions of the runway have a
weighted PCI average of 54.
The MicroPAVER computer model results also indicate that Runway 16-34
would be anticipated to deteriorate rapidly to a level of"Very Poor"by year 2013,
with a weighted PCI average of 35 (weighted PCI of 27 for the center section and
39 for the outside portions). Based on this PCI evaluation, runway reconstruction
would be considered necessary for safe operations to continue at AVL.
Included as part of the 2009 detailed pavement evaluation, non-destructive testing
(NDT) was also completed to evaluate the support properties of the airfield
pavement subgrade, which is the soil that forms the foundation for pavement
structures and provides the necessary support for pavement and the imposed
loads. The NDT measures the structural properties of pavement by simulating the
effect of moving aircraft loads. The NDT results indicated that the subgrade
would adequately accommodate existing and projected aircraft operations.
Runway 16-34 also underwent geotechnical testing to determine the physical
properties of the pavement section. The geotechnical testing used the California
Bearing Ratio (CBR) to measure the conditions and resistance of the subgrade;
the higher the CBR readings, the stronger the subgrade and the less thick the
pavement design that is required. Laboratory results indicate that two-thirds of the
borings would achieve CBR values greater than the recommended CBR value of
17. Therefore, the existing subgrade at AVL was determined to be adequate now
and in the future.
Based on the results of the NDT and geotechnical subgrade testing, the 2009
pavement evaluation recommended to mill Runway 16-34 and apply overlay to a
depth of 2.5 to 3 inches.
Airport design standards are continuously developed and revised in support of one
of the FAA's critical functions, which is maintaining safe operating conditions at
airport facilities throughout the national aviation system. In the NPIAS, the FAA
identifies certain public-use airports that are eligible to receive Federal Airport
Improvement Program (AIP) grants due to their importance to the national
aviation system. Upon accepting AIP grants, these airports agree to meet FAA
guidelines for facility improvements. Commonly referenced FAA airport design
standards address physical layout characteristics, such as runway/taxiway
separation dimensions. There are also design standards to address material
characteristics, including pavement, wiring, and luminance of lights. Both of
these broad design-standard categories, physical layout and material
characteristics, apply to the proposed project.
An important consideration in the scope of the proposed project results from the
existing Modifications of Standards regarding the runway centerline to taxiway
centerline separation distance of 325 feet and the runway grade not meeting a
24

maximum longitudinal gradient of 0.5 percent in the first and last quarter of the
runway. The FAA requires federally obligated airports to address non-standard
design conditions when associated projects are initiated. Therefore, the
rehabilitation project must also include consideration of the existing separation
between the centerlines of Runway 16-34 and Taxiway A, as well as correction of
the longitudinal grade of the runway.
Regarding the design standards to address material characteristics, a significant
portion of the funding provided through the AIP is for the reconstruction of
existing NPIAS-airport facilities. NPIAS funding of airport reconstruction
projects accounts for about 22 percent of the overall program.
The reconstruction category includes the replacement or rehabilitation of
"pavement and lighting systems that have deteriorated due to weather or use and
that have reached the end of their useful lives." Typically rehabilitation of
pavement occurs on a 15-to 20-year cycle.
In accordance with FAA AC 150-5380-6b, Guidelines and Procedures for
Maintenance of Airport Pavements, a pavement maintenance program must be in
place in order for Federal funds to be requested for a pavement
replacement/reconstruction project. Furthermore, for any project to replace or
reconstruct pavement, 49 U.S.C. §47105 requires that airport sponsors provide
assurances to the FAA that they have implemented an effective pavement
maintenance management program.
6.4 Alternatives Conclusion
This discussion of alternatives, together with the documents submitted by the
applicant in support of the 404 Permit, shows that the project complies with the
Guidelines. As this analysis clearly demonstrates the project is designed to avoid
and minimize impacts to the site to the maximum extent practicable while
maintaining a rational project design.
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7.0 CONCEPTUAL ARTIGATION PLAN
Upon completion and implementation of practical avoidance and minimization efforts,
2,076 linear feet of stream channel and 0.9 acre of wetland associated with the
development of the West Expansion are unavoidable. The following mitigation plan is
provided in support of this permit application; the mitigation measures are described
below.
7.1 NC Ecosystem Enhancement Proaram (EEP)
AVL proposes to mitigate for unavoidable impact(2,076 linear feet of stream and
0.9 acre of wetland) at a 1:1 ratio through payment into the EEP in-lieu fee
program. By letter dated June 1, 2011, EEP has indicated they are willing to
accept payment for impacts associated with development at AVL and up to 4,222
linear feet of stream and 2 acres of wetlands. The acceptance letter is enclosed for
review (Appendix B). AVL proposes to pay into EEP (or an approved mitigation
bank)in phases, as well.
Phase 1 will include mitigation for 1,505 linear feet of stream impacts for the
cargo area and associated infrastructure (to take place immediately after permit
issuance) and Phase 2 will include mitigation for 571 linear feet of stream impacts
and 0.9 acre of wetland impacts associated with rehabilitation of the existing
runway (estimated to begin in 2013). Prior to impacts occurring in Phase 2,AVL
will provide an updated acceptance letter to the Corps.
26

8.0 US ENVIRONMENTAL PROTECTION AGENCY 404(b)(1) GUIDELINES
The EPA interim regulations providing guidance for specification of deposit on sites for
dredge and fill material were published on September 17, 1993, in 40 C.F.R. 230 per
Section 404(b)1. Sub-Parts A through I pertain to dredge and fill permits, and apply to
project sites similar to this project.
Sub-Part D presents a summary of compliance criteria for the 404(b)(1) guidelines. This
section references and defines practicable alternatives and indicates that a dredge and fill
permit shall not be issued if practicable alternatives exist. Alternatives reviewed, detailed
in Section 6.0, were assessed for compliance with 404(b)(1) guidelines.
Additional EPA guidance is presented related to general regulatory criteria, wildlife
value, and human health guidelines. The discharge of dredge and fill material is
considered permittable under these guidelines if the discharge activity: does not
contribute to violation of state water quality standards; does not violate toxic effluent
standards; does not jeopardize the continued existence of species listed as threatened and
endangered pursuant to the federal Endangered Species Act of 1973 and subsequent
amendments; does not cause degradation to any marine sanctuaries; does not contribute
to significant degradation of "waters of the United States;" does not adversely affect
human health as it pertains to water supply; does not adversely impact wildlife, the food
chain, and special aquatic sites; does not contribute to the discharge of pollutants that
may affect the food web; does not have negative effects on the productivity of the aquatic
ecosystem, or their physical values; and does not have adverse_impacts on recreation,
aesthetic, or economic values. Additionally, the applicant is required to minimize
potential adverse impacts on the aquatic ecosystem.
8.1 Factual Determination
The Corps is required to determine both potential short-term and long-term effects
of a proposed discharge of dredge and fill material on the physical, chemical, and
biological components of an aquatic environment.
8.2 Potential Impacts on Physical and Chemical Characteristics of the Aquatic
Ecosystem
Sub-Part C of the 40 C.F.R. 230 guidelines lists six physical and chemical
characteristics that must be assessed during the permit review, and the effects of
which must be determined to be minimal on the aquatic ecosystem.
8.2.1 Substrate
Fill material will be placed in jurisdictional streams and wetlands. Any
discharge will consist of suitable fill material and will not include any
trash, debris, car bodies, asphalt, etc. The fill material will also be free of
toxic pollutants in toxic amounts. Proper sediment and erosion control
devices will be installed prior to and during construction to ensure that the
bottom elevation of remaining streams and wetlands on the property will
not change.
27

Upland fill areas for the project will include fly ash from the Progress
Energy power plant at Lake Julian in Buncombe County. All fly ash fill
material will be handled, utilized, and placed in accordance with rules and
regulations outlined in 15A NCAC 13B administered by the State of North
Carolina. Only clean fill material will be used to fill streams and
wetlands; fly ash will not be used in these areas.
8.2.2 Suspended Particulate/Turbidity(Sediment and Erosion Control)
During construction activities on the site, there may be a minimal increase
in suspended particulates that may lead to increased turbidity downstream.
However, the increase is anticipated to be minimal and temporary due to
the installation and maintenance of proper sediment and erosion control
measures during construction and shortly thereafter. A stormwater plan
will also be implemented on site; this plan has been submitted to the City
of Asheville for review and approval.
8.2.3 Water Quality
The proposed discharge of dredge and fill material should not cause
increased chemical contamination levels within the aquatic ecosystem.
Specifically, changes in clarity, color, odor, and taste of water in addition
to possible chemical contamination shall be minimized or reduced. All
discharges of dredge and fill material will be controlled with sediment and
erosion control measures. A stormwater plan will also be implemented on
site; this plan has been submitted to the City of Asheville for review and
approval. Fill for the project will include fly ash from the Progress Energy
power plant at Lake Julian. A minimum 50-foot buffer will be maintained
around all streams not proposed for impact. The stream and buffer
locations will be ground-truthed and delineated in the field with orange
plastic construction fencing or similar material. Field verification of the
stream locations and 50-foot buffer will provide clear boundaries for the
placement of fill dirt. Fill will not be placed within 50 feet of any
unimpacted stream. By State rule 15A NCAC 13B, fly ash is not
permitted within 50 feet of stream channels. All fly ash fill material will
be handled, utilized, and placed in accordance with applicable rules and
regulations. Only clean fill material will be used to fill streams and
wetlands; fly ash will not be used in these areas.
The applicant will be concurrently applying for a DWQ Water Quality
Certification.
8.2.4 Current Patterns in Water Circulation
The discharged fill material will modify current water circulation patterns
by obstructing flow, changing direction or velocity of water, and changing
velocity or flow of circulation in the channels proposed for impact;
however, water circulation and patterns will be re-established in the
stream channels provided as mitigation.
28

8.2.5 Normal Water Fluctuations
The discharge of fill material associated with this project.is not anticipated
to have any significant effect on the downstream hydrologic regimes.
8.2.6 Salinity
Because this project is located inland and away from tidally influenced
waters and wetlands, no modification to the salinity of on-.site or adjacent
waters is expected.
8.3 Potential Impacts to Biological Characteristics of the Ecosystem
Sub-Part D of the 40 C.F.R. 230 guidelines specifies three areas of concern in
which disposal of dredge and fill material can affect the biological components of
the ecosystem. These components are threaten and endangered species, fish,
crustaceans,mollusks, other aquatic organisms in the food web, and wildlife.
8.3.1 Threatened or Endangered Species
Recent database information for listed species was acquired from the US
Fish and Wildlife Service (FWS) and the NC Natural Heritage Program
(NHP) database in December of 2010 and June of 2011 concerning the
existence or potential existence of federally or state listed species within 5
miles of the Asheville Regional Airport. The NHP database identifies 0
element occurrences (EO) for species with a Federal status of threatened
or endangered within a 5-mile radius of the project site.
The field surveys for this project were conducted in November and
December of 2009; and April,November, and December of 2010. Potential
fauna were identified to the taxonomic unit level necessary to determine if
the observed specimen is a protected species. Flora were identified to the
lowest taxonomic level readily discernible in the field during the time of
survey.
No Federally threatened or endangered species were observed on site
during the site visits. It is the opinion of CEC that Federally threatened
and endangered species will not be directly impacted by development at
the Asheville Regional Airport.
The FWS did not provide comments during the Public Notice comment
period for the Asheville Airport Cargo Hold Expansion project.
8.3.2 Fishes, Crustaceans, Mollusks, and other Aquatic Organisms in the
Food Web
Discharges of dredge and fill material can alter the food web by impacting
animals such as invertebrates that make up the basis of a food chain. The
release of contaminants or an increase in turbidity has the potential to
29

negatively affect certain aspects of the food web. Such releases may also
potentially increase the levels of exotic species.
Impacts to primary food chain production within the waters of the US and
wetlands will occur on the project site; however, food chain production
will be re-establish over time in the streams and wetlands provided as
mitigation. Net impacts to primary food chain production are expected to
be minimal.
8.3.3 Other Wildlife
The discharge of dredge and fill material has the potential to negatively
effect breeding and nesting areas, escape cover, travel corridors, and
preferred food sources for resident and migrant wildlife species.
Although some evidence of wildlife usage was apparent on site, because
the project area is within close proximity to an existing airport facility,
which is surrounded by a wildlife fence and grassed safety area, wildlife
habitat is minimal and many wildlife species are restricted from the site.
Noise pollution, denuded vegetation, and anthropogenic activity make this
area less desirable for resident and migrant wildlife. While a loss of
wildlife habitat for stream-dependent and wetland species may result from
construction of the project, the proposed mitigation will compensate for
any minor loss of habitat.
8.4 Potential Impacts on Special Aquatic Sites
Sub-Part E of the 40 C.F.R. 230 guidelines addresses considerations for potential
impacts on special aquatic sites, which include: sanctuaries and refuges,
wetlands,mud flats, vegetated shallows, coral reefs, and riffle-pool complexes.
8.4.1 Sanctuaries and Refuges
The discharge of dredge and fill material has the potential to negatively
effect adjacent sanctuaries and wildlife refuges by impacting water
quality, decreasing wildlife habitat, increasing human access, and creating
the need for frequent maintenance activity, resulting in the establishment
of undesirable plant and animal species, which can change the balance of
habitat type. There are no sanctuaries or refuges in the project vicinity;
therefore, impacts to sanctuaries or refuges will not occur as a result of
development of the West Expansion.
8.4.2 Wetlands
The discharge of dredge and fill material has the potential to adversely
effect wetlands including wetland substrate, hydrology, and vegetation.
Discharges can lead to a loss of wetland values, such as wildlife habitat,
flood storage, and groundwater recharge. The discharge of fill material
will impact 0.9 acre of wetlands on site. Approximately 4.25 acres of
wetlands have been avoided; totaling 82 percent of total wetlands on site.
30

The applicant will make payment into the EEP in-lieu fee program to
offset impacts to wetlands.
8.4.3 Mud Flats
Discharges of dredge and fill material has the potential to negatively effect
mud flats that exist along inland lakes,ponds, and riverine systems. There
are no mud flat communities within the project boundary; therefore, loss
of these ecosystems will not occur as a result of development of the West
Expansion project.
8.4.4 Vegetated Shallows
Vegetated shallows are permanently inundated areas that contain rooted
aquatic vegetation. This type of habitat generally exists within estuarine
and marine environments; and some freshwater lakes and rivers. No
vegetated shallow habitats exist within the project boundary; therefore, no
impacts to this ecosystem will occur as a result of development of the
West Expansion project.
8.4.5 Coral Reefs
Coral reefs typically exist within marine ecosystems. Coral reefs do not
exist within the project boundary; therefore, no impacts to this ecosystem
will occur as a result of development of the West
8.4.6 Riffle-Pool Complexes
Discharge of dredge and fill material into or upstream of riffle-pool
complexes has the potential to negatively affect water quality and wildlife
value. Fill has the potential to be placed into riffle-pool complexes. Any
permanent impact to riffle-pool complexes will be mitigated for through
the proposed mitigation plan.
8.5 Potential Effects on Human Use Characteristics
Sub-Part F of the 40 C.F.R. 230 guidelines address potential effects on human use
of wetlands and waterways. Factors including water supply, recreational and
commercial fisheries, water-related recreation, aesthetics, and parks and similar
preserves are considered within this portion of the guidelines. No effects on
human use characteristics are anticipated as a result of the proposed development
of the West Expansion project.
8.5.1 Municipal and Private Water Supply
The public water supply will not increase or decrease as a result of the
proposed.activities.
8.5.2 Recreational and Commercial Fisheries
Discharges of dredge and fill material has the potential to negatively effect
recreational and commercial fisheries. Opportunity for recreational and
commercial fisheries is not present on site. The amount and quality of
31

recreational and commercial fisheries will not increase or decrease as a
result of the proposed activities.
8.5.3 Water-Related Recreation
Proposed activities will not increase or decrease waterborne recreation
within the project vicinity.
8.5.4 Aesthetics
Aesthetically, the West Expansion will be similar to other facilities
currently present within the airport property boundary. The facility will be
designed in a manner that is consistent with the existing facilities at the
site. The project is not expected to diminish the aesthetic value of the area
or cause disharmony from an aerial or neighboring view.
8.5.5 Parks, National and Historical Monuments, National Beach Shores,
Wilderness Areas,Research Sites, and Similar Preserves
No areas as described above will be affected by the proposed activities.
8.6 Summary
Based on the EPA guidelines identified within 40 C.F.R. 230, and enumerated
herein, a number of potential environmental impacts have been presented and
subsequently addressed. The proposed permanent impact to 2,076 linear feet of
streams and 0.9 acre of wetland will not cause any off site adverse impacts.
Mitigation offered through payment in to the EEP will compensate for any on-site
impacts.
32

9.0 PUBLIC INTEREST CONSIDERATIONS
When reviewing this application, the Corps is required to consider the project in terms of
the public interest. In considering the public interest, the Corps must evaluate the
probable impacts of the project and evaluate the "benefits which reasonably may be
expected to occur,from the proposal against reasonably foreseeable detriments." In
balancing these interests, the Corps must consider the public and private need for the
proposed project, the practicability of using reasonable alternative locations, and the
extent and permanence of the beneficial and/or detrimental impacts of the project. The
Corps also considers the following public interest factors:
conservation, economics, aesthetics, general environmental concerns,
wetlands, historic and cultural resources, fish and wildlife values, flood
hazards, floodplain values, land use, navigation, shore erosion and
accretion, recreation, water supply and water quality, energy needs, safety,
food and fiber production, mineral needs, and considerations of the
property ownership.
Pursuant to 33 C.F.R. 323.6, a determination that the project is not contrary to the public
interest must be achieved before permit issuance. Public interest considerations are listed
in 33 C.F.R. 320.4(a)(1)and are discussed below.
Furthermore, the Corps regulations state that a permit will be granted unless the district
engineer determines that it would be contrary to the public interest.
The applicant has extensively evaluated these factors through the planning process and
believes that the proposed project is clearly in the public interest.
9.1 Conservation
The applicant is not proposing preservation as a component of the project;
however, those projects completed by the EEP in association with this
project will be preserved in perpetuity.
9.2 Economics
The project will provide an overall benefit to the local economy of
Buncombe County. During and upon completion of construction, the site
will provide job opportunities associated with the development,
maintenance, and operation of the proposed facilities. The appropriate
economic evaluations have been completed and the project as proposed is
economically viable.
9.3 Aesthetics
Aesthetically, the West Expansion will be similar to other facilities
currently present within the airport property boundary. The facility will be
designed in a manner that is consistent with the existing facilities at the
33

site. The project is not expected to diminish the aesthetic value of the area
or cause disharmony from an aerial or neighboring view.
9.4 General Environmental Concerns
Other than stream and wetland impacts, proposed development activities
will have no significant identifiable impacts upon other environmental
components.
9.5 Wetlands
The discharge of dredge and fill material has the potential to adversely
effect wetlands including wetland substrate, hydrology, and vegetation.
Discharges can lead to a loss of wetland values, such as wildlife habitat,
flood storage, and groundwater recharge. The discharge of fill material
will impact 0.9 acre of wetlands on site. Approximately 4.25 acres of
wetlands has been avoided; totaling 82 percent of total wetlands on site.
The applicant will make payment into the EEP in-lieu fee program to
offset impacts to wetlands.
9.6 Historic Properties
A desk review of the National Register of Historic Places records
maintained by the NC State Historic Preservation Office (SHPO) indicates
four historic properties within 5 miles of the Asheville Airport Cargo Hold
Expansion project area: The Meadows (NPS Reference # 80002847)
located approximately 2.8 miles from AVL, the Mills River Chapel (NPS
Reference # 88002660) located approximately 3.4 miles from AVL, the
Bent Creek Campus of the Appalachian Forest Experiment Station (NPS
Reference#93000373) located approximately 4.5 miles from AVL, and the
Demens-Rumbough-Crawley House (NPS Reference # 82003435) located
approximately 4.5 miles from AVL. It is the opinion of CEC that activities
taking place within the project boundary will not affect the integrity of the
historic sites. The SHPO will be notified via Public Notice about the
projects and will be given the opportunity to comment on the project and its
potential affects on archaeological and cultural resources.
9.7 Fish and Wildlife Values
Riparian and wetland areas provide habitat for many types of wildlife
because of their diverse and productive plant communities, complex
structure, and close proximity to surface water. Wildlife may be
permanent residents of riparian and wetland areas or occasional visitors
that use the areas for food,water, or temporary shelter.
Food availability varies with the type of vegetation in riparian and wetland
areas, but includes fruit, seed, foliage, twigs, buds, insects, and other
invertebrates. Trees and shrub produce a variety of foods that are eaten by
many animals and may be especially important sources of nutrition during
34

the winter months. Grasses and herbaceous vegetation provide seeds and
forage both within riparian and wetland areas and along the forest border.
The stream environment provides moving water for many animals to
drink, feed, swim, and reproduce. Water is also available on the moist
vegetation and in wetlands that are often associated with riparian areas.
These areas, both permanent and temporary, are especially important for
amphibians and macro-invertebrates.
Riparian and wetland areas provide a sheltered environment for many
species of animals to feed, rest, and reproduce. Animals use these areas to
seek shelter from extreme weather and to escape predators and human
activity. Riparian and wetland areas may also provide important travel
corridors for some species, and are frequently used as stop-over points for
migratory birds.
Although some evidence of wildlife usage was apparent on site, because
the project area is within close proximity to an existing airport facility
wildlife habitat is minimal. Noise pollution, denuded vegetation, and
anthropogenic activity make this area less desirable for resident and
migrant wildlife. While a loss of wildlife habitat for stream-dependent
species may result from construction of the project, the proposed
mitigation should compensate for any lost functions and values.
9.8 Flood Hazards
It is likely that some tributaries on the property will flood occasionally due
to natural fluctuations in weather patterns that increase precipitation. The
proposed activities associated with the West Expansion are not expected to
significantly increase or decrease the natural rate of flooding at the site or
downstream.
9.9 Floodulain Values
Based on data from the State of North Carolina, through FEMA's
Cooperating Technical Community partnership initiative, 100-year
floodplains associated with the French Broad River are located within the
AVL property boundary. The proposed construction footprint encroaches
into FEMA Zone AE. Zone AE is defined as an area with a one-percent
annual chance of flooding for which base flood elevations have been
determined by detailed hydraulic analyses and shown at selected intervals
within the zone.
The proposed construction footprint associated with the proposed project
would encroach into the 100-year floodplain. Clean earthen fill (not fly
ash)from the proposed construction footprint would impact approximately
5.6 acres of floodplains. Two extended-detention stormwater basins are
35

located within this 5.6-acre encroachment area. The proposed project
would not impact the floodway.
Since the floodplains within the proposed construction footprint are
located in a FEMA Zone AE, FEMA will require either a Conditional
Letter of Map Revision (CLoMR) or a Statement of No Impact for the
proposed project. Detailed hydrologic studies would be completed during
future design phases of the project, as required by 23 CFR 650, Subpart A,
Location and Hydraulic Design of Encroachment on Floodplains, as well
as coordination with the Buncombe County Flood Administrator to ensure
the project will meet state and federal requirement.
9.10 Land Use
The proposed project will be in compliance with local zoning regulations
and ordinances. The project is consistent with surrounding land use and
development.
9.11 Navigation
All tributaries within the West Expansion project boundary are tributaries
to the French Broad River. The.French Broad River is a navigable-in-fact
water at the Wilson Bridge east of Brevard. The project will not have
direct effects on the.French Broad River; therefore, activities proposed as
a part of the West Expansion are not likely to effect navigation.
9.12 Shore Erosion and Accretion
The project should have minimal effects on erosion and runoff. An erosion
control plan will be implemented as part of the construction plan for the
project. During the construction process, BMPs will be followed. These
BMPs may include the construction of swales, erosion and sediment control
structures, turbidity barriers, and other measures that will prevent sediment
transport off the project site and into other waters. Use of devices such as
silt screens, staked hay bales, temporary grassing, wind rowing of
vegetation, and other mechanisms to prevent turbidity may be employed. A
post-construction stormwater plan will also be implemented as apart of this
project.
9.13 Recreation
Proposed activities will not increase or decrease waterborne recreation on
site or in the project vicinity.
9.14 Water Supply and Conservation
The public water supply will not increase or decrease as a result of the
proposed activities.
36

9.15 Water Quality(Stormwater Management)
The stormwater management plan for this site has been submitted to the
City of Asheville for review and approval.
The applicant will be concurrently applying for a NC Division of Water
Quality Water Quality Certification.
9.16 Enerpy Needs
Activities associated with the West Expansion, during construction and at
full operation, are not expected to significantly increase energy demands
beyond the capacity of the local facility. Energy will not be produced as a
result of the proposed activities.
9.17 Safety
The proposed project will be designed with the maximum possible
considerations for public safety. The proposed activities will not increase or
decrease public safety.
9.18 Food and Fiber Production
The proposed activities will not increase or decrease food and fiber
production.
9.19 Mineral Needs
The project fulfills no current mineral needs. No mining activities are
proposed as part of the West Expansion.
9.20 Considerations of Property Ownership
The applicant owns the property proposed for development and has the
inherent right to develop the land in a reasonable and responsible manner,
which includes adhering to all Federal, State, and local regulations.
Property Owner of Record:
Asheville Regional Airport Authority
61 Terminal Dr, Ste 1
Fletcher,NC 28732
9.21 Needs and Welfare of the Public
The project will positively address the needs and welfare of the public by
expanding and improving the existing airport facilities at the Asheville
Regional Airport in Buncombe County,North Carolina.
37

10.0 SECONDARY AND CUMULATIVE EFFECTS
The West Expansion project site is located within the French Broad River Subbasin 04-03-
02. Approximately 75 percent of this subbasin is forested and the total land mass includes
approximately 806 square miles (516,000 acres). The project area is comprised of
approximately 195 acres (0.3 square miles). All of the land mass included within the
project site accounts for less than 0.03 percent of the land mass of the basin. These
percentages alone, limit significant cumulative effects on the watershed. Past activities
within the subbasin include logging; agricultural, commercial and residential development;
and road building. Agricultural and residential development, and road building in.the
vicinity remains active; continued and future development of the watershed is independent
of activities proposed at AVL. Impacts within the project boundary include the
construction of a parallel runway, rehabilitation of the existing runway, and construction of
a cargo facility. Stream and wetland impacts are necessary for the construction at the site.
Activities associated with the West Expansion should not result in a significant impairment
of the water resources on site or interfere with the productivity and water quality of the
existing aquatic ecosystem.
38

11.0 SU AWRY
The development of the West Expansion involves the construction of a parallel taxiway,
rehabilitation of the existing runway, and construction of a cargo facility. Alternatives
have been evaluated and the project "As Proposed" is the least damaging practical
alternative which meets the project purpose. Potential impacts to the physical and
chemical characteristics of the ecosystem, biological characteristic of the ecosystem,
impacts on special aquatic sites, and potential effects on human use characteristics will be
minimal. The project is not contrary to the public interest and will aid in the continued
growth of the Asheville Regional Airport and Buncombe County.
39

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224 South Grove Street,Suite F Figure 2a
Hendersonville,North Carolina 28792

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224 South Grove Street,Suite F Figure 2b
Hendersonville,North Carolina 28792

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Hendersonville,North Carolina 28792

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AIRPORT PROJECT AREA
PROJECT AREA 198 ACRES 100-YEAR FLOOD ZONE
o STREAMS
TOTAL STREAM 16.629 LF .aa ®,
v WETLANDS DESIGNED BY:
TOTAL WETLANDS 5.15 ACRES_
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DATE FEBRUAR`R2010
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North Carolina Department of Cultural Resources
State Historic Preservation Office
Peter B.Sandbeck,Administrator
Beverly Eaves Perdue,Governor Office of Archives and History
Linda A.Carlisle,Secretary Division of Historical Resources
Jeffrey J.Crow,Deputy Secretary David Brook,Director
September 27,2010
Rebekah Newton
C1earWater Environmental Consultants,Inc.
224 South Grove Street
Suite F
Hendersonville,NC 28792
Re: Taxiway, Cargo Apron,Warehouse Building,Truck Loading Docks and Infrastructure,
Asheville Regional Airport,Buncombe County,ER 10-0930
Dear Ms.Newton:
Thank you for your letter of August 27,2010, transmitting the Management Summary by Tasha Benyshek for
the archaeological survey of the above project.
During the course of the survey,one site, 31BN958,was located within the project area.Ms.Benyshek has
recommended that no further archaeological investigation be conducted in connection with this project.We
concur with this recommendation since the project will not involve significant archaeological resources and
look forward to receiving the full report of the archaeological survey.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and 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,
please contact Renee Gledhill-Earley,environmental review coordinator;at 919-807-6579. In all future
communication concerning this project,please cite the above-referenced tracking number.
Sincerely,
Peter Sandbeck
cc: Tasha Benyshek,TRC
US Army Corps of Engineers,Asheville
Location:109 East Jones Street,Raleigh NC 27601 Mailing Address:4617 Mail Service Center,Raleigh NC 27699-4617 Telephone/Fax:[phone]-6599

1--
os stem rt
PROGRAM
March 24,2010
Kevin Howell
Asheville Airport
61 Terminal Drive,Suite 1
Fletcher,NC 28732 Expiration of Acceptance: December 24,2010
Project:Asheville Airport Expansion(second request) County: Buncombe
The purpose of this letter is to notify you that the North Carolina Ecosystem Enhancement Program(NCEEP)is willing to accept
payment for impacts associated with the above referenced project. Please note that this decision does not assure that the payment will
be approved by the permit issuing agencies as mitigation for project impacts. It is the responsibility of the applicant to contact these
agencies to determine if payment to the NCEEP will be approved. You must also comply with all other state,federal or local
kovernment permits,regulations or authorizations associated with the proposed activity including SL 2009-337• An Act to Promote
Compensatory Mitigation by Private Mitigation Banks.
This acceptance is valid for nine months from the date of this letter and is not transferable. If we have not received a copy of the
issued 404 Permit/401 Certification/CAMA permit within this time frame,this acceptance will expire. It is the applicant's
responsibility to send copies of the permits to NCEEP. Once NCEEP receives a copy of the permit(s)an invoice will be issued based
on the required mitigation in that permit and payment must be made prior to conducting the authorized work. The amount of the In
Lieu Fee to be paid to NCEEP by an applicant is calculated based upon the Fee Schedule and policies listed at www.neeep.net.
Based on the information supplied by you the impacts that may require compensatory mitigation are summarized in the following
table.
River CU Stream(feet) Wetlands(acres) Buffer I Buffer II
Basin Location (Sq.Ft,) (Sq.Ft.)
Cold Cool Warm Riparian Non-Riparian Coastal Marsh
Impact French 06010105 0 1,260 0 0 0 0 0 0
Broad
Credits French 06010105 0 2,520 0 0 0 0 0 0
Broad
Upon receipt of payment,EEP will take responsibility for providing the compensatory mitigation. If the regulatory agencies require
mitigation credits greater than indicated above,and the applicant-warits NCEEP to be responsible for the additional mitigation,the
applicant will need to submit a mitigation request to NCEEP for approval prior to permit issuance. The mitigation will be performed
in accordance with the Memorandum of Understanding between the N,C.Department of Environment and Natural Resources and the
U.S.Army Corps of Engineers dated November 4, 1998.
If you have any questions or need additional information,please contact Kelly Williams at(919)716-1921.
Sincerely,
'3Kv-W
Willia Gilmore,PE
Director
cc: Ian McMillan,NCDWQ Wetlands/401 Unit
Tasha McCormick, USACE-Asheville(AID 2010-0036)
Susan Wilson,NCDWQ-Asheville
Rebekah Newton,agent
File
RP.stoY ... ... Protects Ow State, �
1�CDENR
North Carolina Ecosystem Enhancement Program, 1652 Mail Service Center, Raleigh, NC 27699-1652/919-715-0476/www,nceep.net

ARCHAEOLOGICAL SURVEY FOR PROPOSED ADDITIONS
TO THE ASHEVILLE REGIONAL AIRPORT,
BUNCOMBE COUNTY, NORTH CAROLINA
DRAFT REPORT
Submitted to:
ASHEVILLE AIRPORT AUTHORITY
61 Terminal Drive, Suite 1
Fletcher,North Carolina 28732
By:
TRC ENVIRONMENTAL CORPORATION
50101 Governors Drive,Suite 250
Chapel Hill,North Carolina 27517
Authored by:
Michael Nelson
September 2010

ABSTRACT
TRC Environmental Corporation(TRC)has completed an archaeological survey of four areas that will be
affected by proposed additions to the Asheville Regional Airport, Buncombe County, North Carolina.
The survey areas were identified by Asheville Regulatory Office of the U.S. Army Corps of Engineers
(COE) as requiring survey to satisfy regulatory requirements, and are located at the south end of the
airport.The areas include: a ca. 0.9 acre south of the existing runway(Area 1),areas extending 50 feet on
either side of two small streams east of NC 280 (Areas 2 and 3), and a ca. 6.0-acre area southwest of Old
Fanning Bridge Road(NC 280)(Area 4).
This study was conducted to produce information on the presence and location of significant
archaeological sites on the tract,in order to comply with Section 106 of the National Historic Preservation
Act and so that the information could be considered for planning purposes. The survey meets the
standards established by the North Carolina State Historic Preservation Office(SHPO)and Office of State
Archaeology(OSA). The field survey was conducted on August 11-13 and 16, 2010 by Michael Nelson
and Chris Pettyjohn;the background study was conducted on August 4,2010 by Heather Olson.
The survey included systematic 20-m interval shovel testing across the four areas as well as a visual
inspection of the ground surface for possible evidence of above ground cultural remains. A total of 139
shovel tests were excavated during the survey, including 28 shovel tests in Area 1,37 tests in areas 2 and
3, and 74 shovel tests in Area 4. As the project areas had not been staked, in some cases the survey
coverage extended a short distance outside the area boundaries in order to ensure that the coverage was
complete; in addition, the Area 4 survey was inadvertently extended across the large wetland area to the
bank overlooking the French Broad River.
A single isolated find(31BN958) consisting of a single prehistoric lithic artifact was found along the east
bank of an unnamed intermittent drainage (Area 2) north of Old Fanning Bridge Road(NC 280) (Figure
1.2). This isolated find is recommended ineligible for the National Register of Historic Places (NRHP).
No other non-modem cultural remains were encountered within the current project boundaries, and no
further archaeological investigations of the defined project areas are recommnended.
This report is organized in the following way. Chapter 2 provides information on the natural
environment, and Chapter 3 presents a summary of the culture history of the project region, including
information on local history and previous research in the area. Chapter 4 specifies the research goals and
methods, and the results of the background research and survey are presented in Chapter 5. The
conclusions and recommendations are provided in Chapter 6, which is followed by a list of references
cited.
i

ACKNOWLEDGMENT'S
The authors would like to thank Lew Bleiweis, Sherman Starks, Rita Yanz and Pat Garren of the
Asheville Regional Airport for their support of this project. Rebekah Newton of Clearwater
Environmental is also thanked for her assistance.
For TRC, Michael Nelson and Chris Pettyjohn conducted the survey. The background research was
conducted by Heather Olson. Artifact analysis was completed by Michael Nelson, and Matt Pare and
Brenda Magouirk-Nelson produced the graphics.
iii

CONTENTS
ABSTRACT...................................................................................................................................................i
ACKNOWLEDGMENTS
FIGURES....................................................................................................................................................vrr
TABLES......................................................................................................................................................ix
1.INTRODUCTION....................................................................................................................................1
2.ENVIRONMENTAL SETTING..............................................................................................................3
PROJECTSETTING............................................................................................................................3
PHYSIOGRAPHY, GEOLOGY,HYDROLOGY,AND SOILS........................................................3
MODERNCLIMATE..........................................................................................................................6
FLORAAND FAUNA.........................................................................................................................6
3. CULTURAL BACKGROUND................................................................................................................9
PREHISTORIC OVERVIEW..............................................................................................................9
Paleoindian Period(ca. 10,000-8000 B.C.)................................................................................10
Archaic Period(ca. 8000-700 B.C.)............................................................................................10
Woodland Period(ca. 700 B.C.-A.D. 1000)................................................................................12
Mississippian Period(ca.A.D. 1000-1540)................................................................................15
HISTORIC CHEROKEE OCCUPATION.........................................................................................16
Pre-Removal Cherokee Occupations..........................................................................................16
Post-Removal Cherokee Occupations........................................................................................18
REGIONAL HISTORIC OVERVIEW..............................................................................................18
BuncombeCounty......................................................................................................................18
HendersonCounty......................................................................................................................20
AshevilleAirport History....................................................................................................... 21
PREVIOUS ARCHAEOLOGICAL RESEARCH.............................................................................21
4.RESEARCH GOALS AND METHODS ...............................................................................................23
RESEARCHGOALS.........................................................................................................................23
RESEARCHMETHODS...................................................................................................................23
BackgroundResearch.................................................................................................................23
Archaeological Field Methods....................................................................................................23
ArtifactAnalyses........................................................................................................................24
NRHP Eligibility Evaluations....................................................................................................24
5.RESULTS...............................................................................................................................................25
BACKGROUNDRESEARCH..........................................................................................................25
Previously Identified Resources.................................................................................................25
HistoricMaps of the Project Area..............................................................................................25
ARCHAEOLOGICAL FIELD SURVEY..........................................................................................26
31BN958 (Isolated Find 1).........................................................................................................30
6. SUMMARY AND RECOMMENDATIONS.........................................................................................31
REFERENCESCITED...............................................................................................................................33
v

FIGURES
I.I.Location of the project areas and site 31BN958,Buncombe County,North Carolina..........................2
2.1.View to north across Area 1.......................................................::..........................................................4
2.2.View to southwest along intermittent drainage in Area 2......................................................................4
2.3.View to east across south side of Area 3. ..............................................................................................5
2.4.View to north across Area 4...................................................................................................................5
5.1.The project area and vicinity as shown on the 1907 Henderson County soils map.............................27
5.2.The project area and vicinity as shown on the 1938 Henderson County road map......:......................27
5.3:Location of project areas and site 31BN958,Buncombe County,North Carolina..............................28
5.4.Detailed map of project areas and site 31BN958.................................................................................29
vii

TABLES
3.1. Generalized Cultural Chronology for the American Indian Occupation of Western North
Carolinathrough 1838*........................................................................................................................9
5.1.Previously Recorded Archaeological Sites within One Mile of Project Areas....................................25
ix

1. INTRODUCTION
TRC Environmental Corporation(TRC)has completed an archaeological survey of four areas that will be
affected by proposed additions to the Asheville Regional Airport, Buncombe County, North Carolina.
The survey areas were identified by Asheville Regulatory Office of the U.S. Army Corps of Engineers
(COE) as requiring survey to satisfy regulatory requirements, and are located at the south end of the
airport.The areas include: a ca. 0.9 acre south of the existing runway(Area 1), areas extending 50 feet on
either side of two small streams cast of NC 280 (Areas 2 and 3), and a ca. 6.0-acre area southwest of Old
Fanning Bridge Road(NC 280)(Area 4) (Figure 1.1).
This study was conducted to produce information on the presence and location of significant
archaeological sites on the tract,in order to comply with Section 106 of the National Historic Preservation
Act and so that the information could be considered for planning purposes. The survey meets the
standards established by the North Carolina State Historic Preservation Office(SETO)and Office of State
Archaeology(OSA). The field survey was conducted on August 11-13 and 16, 2010 by Michael Nelson
and Chris Pettyjohn;the background study was conducted on August 4,2010 by Heather Olson.
The survey included systematic 20-m interval shovel testing across the four areas as well as a visual
inspection of the ground surface for possible evidence of above ground cultural remains. A total of 139
shovel tests were excavated during the survey,including 28 shovel tests in Area 1, 37 tests in areas 2 and
3, and 74 shovel tests in Area 4. As the project areas had not been staked, in some cases the survey
coverage extended a short distance outside the area boundaries in order to ensure that the coverage was
complete; in addition, the Area 4 survey was inadvertently extended across the large wetland area to the
bank overlooking the French Broad River.
A single isolated find(31BN958) consisting of a single prehistoric lithic artifact.was found along the east
bank of an unnamed intermittent drainage (Area 2) north of Old Fanning Bridge Road (NC 280). This
isolated find is recommended ineligible for the National Register of Historic Places (NRHP). No other
non-modem cultural remains were encountered within the current project boundaries, and no further
archaeological investigations of the defined project areas are recommended.
This report is organized in the following way. Chapter 2 provides information on the natural
environment, and Chapter 3 presents a summary of the culture history of the project region, including
information on local history and previous research in the area. Chapter 4 specifies the research goals and
methods, and the results of the background research and survey are presented in Chapter 5. The
conclusions and recommendations are provided in Chapter 6; which is followed by a list of references
cited.

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2. ENVIRONMENTAL SETTING
PROJECT SETTING
The intensive survey covered four separate parcels (arbitrarily labeled as Areas 1, 2, 3, and 4) located at
the south end of the Asheville Regional Airport property in Buncombe County, North Carolina (see
Figure 1.1).Three of the four areas (Areas 1-3) are situated on the east side of Old Fanning Bridge Road
(NC 280)with Area 4 on the west side of the road.Area 1 is located in an open field approximately 920 ft
west of the south end of the existing airport runway and covers approximately 0.9 acres (Figure 2.1).
Areas 2 and 3 extend for 50 feet on either side of two small streams on the east side of the road. The
smaller of those areas(Area 2) is south of an existing construction staging area and access gate.It follows
alongside an intermittent drainage and covers approximately 400 ft x 100 ft (Figure 2.2). The larger
drainage area (Area 3) measures approximately 900 ft x 100 ft, and is north of the staging area/access
gate (Figure 2.3).Both drainages flow west/southwest to the French Broad River. The largest of the four
areas (Area 4)is situated across a large open field(ca. 6 acres)and is bounded by the edge of a low-lying
wetland in the middle of the field to the west/southwest and by Old Fanning Bridge Road to the
east/northeast(Figure 2.4).
All of the surveyed areas are relatively flat,with the exception of a small knoll in the northwest comer of
Area 4 (the ca. 6.0 acre tract). Areas 1, 3, and 4 are in open grass fields, and are moderately to heavily
disturbed from past activities (i.e., grading). The area along the smaller stream (Area 2) is moderately
wooded with mixed hardwoods and pine with a light understory.
PHYSIOGRAPHY,GEOLOGY,HYDROLOGY,AND SOILS
The study area is situated in the Blue Ridge province of the Appalachian Mountains, within the
intermountain plateau(Asheville Basin)physiographic subdivision(Goldston et al. 1954:3),which is the
largest intermountain basin in the Blue Ridge.In North Carolina,the Blue Ridge stretches from the Unaka
and Great Smoky Mountains in the west to the Blue Ridge escarpment,which borders the Piedmont at the
Brevard fault in the east(Orr and Stuart 2000:21-20).The Blue Ridge Province is traditionally described
as the area between the Brevard fault zone and the Blue Ridge fault systems, and is characterized by
thrust sheets with separate tectonic histories (Hatcher and.Goldberg 1991).The intermountain plateau is a
broad valley on either side of the French Broad River that is characteristically rolling and hilly with an
average elevation of 2,300 ft above mean sea level(AMSL) (Goldston et al. 1954:4).
Geologically,the project area is contained within the Blue Ridge.Belt(NCGS 1985).The Blue Ridge Belt
is an area that has a similar complex geologic history characterized by metamorphosed sedimentary and
igneous rock that have been transformed by the intense pressures and temperatures related to internal
plate tectonics.The project area falls within the Ashe Metamorphic Suite and Tallulah Falls Formation as
mapped by the North Carolina Geological Survey [NCGS] (1985), and consists of younger rocks (543-
900 my) than the basement rocks, which are biotite gneisses and amphibolites representing the oldest
rocks in the region (900-1600 my). The project area is within an area mapped as containing
metagraywacke, "...interlayered and gradational with mica schist, muscovite-biotite gneiss and rare
graphitic gneiss" (NCGS 1985). Important materials in prehistoric times that were locally available were
quartz, quartzite, and mica, all occurring in the general area. Soapstone outcrops also occur, but are not
plentiful. During the late 19"' and early 20`h centuries, such minerals as garnet, olivine, and mica were
mined in the western North Carolina Mountains.

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The project area is drained by the two small unnamed drainages (one which is intermittent) that were
included within Areas 2 and 3). The two drainages flow west to the French Broad River which is located
approximately 900 to 1200 feet southwest of the southernmost and northernmost areas surveyed,
respectively. The French Broad's headwaters are in Transylvania County to the south. From there, it
flows north and west through Henderson,Buncombe,and Madison counties before entering Tennessee.In
Tennessee,the French Broad heads west and south,joining with the Holston River just cast of Knoxville
to form the Tennessee River. The Tennessee River flows west and south into Alabama and then turns
north back into Tennessee, continuing north into Kentucky and eventually joining the Ohio River. The
Ohio River flows west into the Mississippi River,which empties into the Gulf of Mexico to the south.
Soils across the four separate areas surveyed were slightly variable, although most are well-drained or
moderately well drained. Within Area 1, the small ca. 0.9 acre open field at the south end of the runway,
the soils are Udorthants which are characterized as a deep well drained sandy clay loam. Along the
smaller drainage (Area 2) soils were either Unison loam, which is a well drained loam found on stream
terraces, or part of the Kanuga-Swannanoa complex, which are moderately to poorly drained soils also
found on stream terraces. Area 3, the westernmost drainage, consisted of Dillard loam (1-5%), a
moderately well drained deep loam to clay loam found along stream terraces. Area 4, the largest area
surveyed, was comprised of either Dillard loam (1-5%) or Statler loam (1-5%), which is also a deep
moderately well-drained loamy soil found on stream terraces. The wetland section of the large field just
south of the project area is marked by Hemphill loam (0-3%) which is found primarily in depressions
along stream terraces. (NRCS 2010).
MODERN CLIMATE
The climate of Buncombe County is temperate and humid, but is generally cooler than other parts of the
state found at lower altitudes. Summers are normally cool and short, while winters are fairly cold
(Goldston et al. 1954:8-9). Asheville averages 37 inches of precipitation a year(Orr and Stuart 2000:25).
The spring and fall months receive the most precipitation, while summer months are the driest.
Temperature and precipitation records indicate that the growing season lasts for about 190 days,
extending from the beginning of April through mid-October (Goldston et al. 1954:9-10). Accumulation
of snowfall in the mountains can average 10-14 inches per year, however, this can be misleading since
one storm might produce nearly a foot of snow, while other years little accumulation occurs (Orr and
Stuart 2000:25).
FLORA AND FAUNA
The study area is located in the Southern Appalachians section of the Oak-Chestnut Forest region(Braun
1950).Prior to 1920 and the blight, chestnut(Castanea dentata) dominated the region,but a great mix of
species including tulip poplar(Liriodendron tulipifera),ash(Fraxinus spp.),hemlock(Tsuga spp.),white
basswood (Tilia spp.), buckeye (Aesculus spp.), oak (Quercus spp.), red maple (Acer rubrum), walnut
(Juglans nigra), wild cherry (Prunus serotina), birch (Betula spp.), and beech (Fagus grandifolia) could
be found in the valleys, coves and along sheltered mountain slopes (Holmes 1911:38). Little or no
primary forest vegetation remains in this section of the region due to the blight,logging, and other human
activity(see Braun 1950:199).Presently,oak and pine(Pinus spp.) are the most common species with red
maple, locust (Gleditsia spp.), black gum (Nyssa sylvatica), sourwood (Oxydendrum arboreum), and
dogwood(Corpus spp.)all common as well on the intermountain plateau(Orr and Stuart 2000:36-37).
In addition to arboreal species,the forests supported a variety of undergrowth species. The latter included
several varieties of edible berries, such as blackberries and raspberries (Rebus spp.) and huckleberries
6

(Gaylussacia spp.), as well as numerous other species used for food and medicinal purposes by both the
Cherokee and later Euro-American settlers(Mooney and Olbrechts 1932; Oliver 1989:29).
The varied forests in the area would have supported a substantial and diverse fauna during and prior to
Euro-American settlements. Potential game species include white-tailed deer (Odocoileus virginianus),
black bear (Ursus americanus), elk (Cervus elaphus), raccoon (Procyon lotor), opossum (Didelphis
marsupialis), gray squirrel(Sciurus carolinensis), and fox squirrel (Sciurus niger). Other species present
include beaver (Castor canadensis), gray fox (Urocyon cinereoargenteus), otter (Lutra canadensis),
muskrat (Ondatra zibethica), mink (Mustela vison), wolf(Canis sp.) panther or mountain lion (Felis
concolor) and bobcat (Lynx rufus) (Shelford 1963). Avian species of possible economic importance
included turkey (Meleagris gallopavo) and smaller species; other species may have been valuable non-
food resources as well. The French Broad River and its tributary streams would have provided a variety of
fish,including catfish(letaluridae), sunfish(Centrarchidae),and largemouth(Micropterus salmoides)and
smalhnouth (Micropterus dolomieui) bass, while brook trout (Salvelinus fontinalis) were present in
upland tributaries.
7

3. CULTURAL BACKGROUND
PREHISTORIC OVERVIEW
This chapter presents a generalized overview of the prehistoric and historic period occupations of the
study area and western North Carolina. Much of the earlier part of the cultural sequence for the region is
based on Coe's (1964) investigations of the prehistoric cultures of North Carolina, coupled with more
recent research across the mountains in Tennessee (e.g.,Davis 1990; Kimball 1985). The later prehistory
and historic native American occupations of western North Carolina have been discussed by various
researchers, including Dickens (1976), Keel (1976), contributors to Mathis and Crow (1983) and Moore
(1986),Riggs(1988, 1996, 1999);Riggs and Rodning(2002),and Ward and Davis(1999).
The prehistory of western North Carolina can be divided into four basic time and cultural periods. These
periods—Paleoindian, Archaic, Woodland, and Mississippian—relate to both social and technological
factors. Several authors (e.g., Dickens 1976:10; Keel 1976:18; Ward and Davis 1999; Wetmore 2002)
divide some or all of these periods into phases, some of which overlap in time and name but vary in
precise definition(Table 3.1).
Table 3.1.Generalized Cultural Chronology for the American Indian Occupation of Western North Carolina
through 1838*
Period Phase Chronology
Historic Cherokee Late Qualla A.D. 1700-1838
Protohistoric Middle Qualla A.D.1500-1700
Mississippian Early Qualla A.D.1400-1500
Late Pisgah** A.D.1200-1400
Early Pisgah** A.D.1000-1200
Late Woodland Undefined(Napier/Woodstock?) A.D.800-1000
Undefined(Cane Creek/Late Swift Creek?) A.D.600-800
Middle Woodland Connestee A.D.200-600 T
Pigeon 200 B.C.-A.D.200
Early Woodland Swannanoa 1000?-200 B.C.
Late Archaic Otarre 1500-1000 B.C.
Savannah River 3000-1500 B.C.
Middle Archaic Guilford 4000-3000 B.C.
Morrow Mountain 6000-4000 B.C.
Stanly 6000-5500 B.C.
Early Archaic LeCroy 7000-6000 B.C.
Kirk/Palmer 7500-7000 B.C.T
Big Sandy 8000-7500 B.C.
Paleoindian Undefined(Hardaway-Dalton?) 9000-8000 B.C.
Clovis 10,000-9000 B.C.
Pre-Paleoindian Undifferentiated Unknown
T represents overlap into a later culture period. *Adapted from several sources including Rodning (2004),
Stanyard(2003),and Ward and Davis(1999). **The Hiawassee and upper Little Tennessee River Valleys appear
to contain Early and Middle Mississippian ceramic types that are more related to the Woodstock,Etowah, and
Savannah cultural sequence of north Georgia(see Riggs and Kimball 1996).
9

Paleoindian Period(ca.10,000-8000 B.C.)
The Paleoindian period represents the earliest well documented human occupation of the Southeast. Key
diagnostic artifacts of this period are fluted and unfluted lanceolate projectile points; a variety of flake
tools, such as endscrapers, gravers, retouched blades, and burins, are also found. Almost all of the
Paleoindian materials found in the region have come from surface contexts, and as a result few data are
available concerning regional subsistence or social organization (Anderson 1990). Hunting of late
Pleistocene megafauna is inferred based on evidence from other areas, although direct evidence for use of
animals of any kind is rare in the Southeast. Most, if not all, Paleoindian populations probably relied
extensively on other animal and plant foods as well (Meltzer and Smith 1986; Purrington 1983).
Paleoindian projectile points are exceedingly rare occurrences in the North Carolina mountains.
Paleoindian populations were generally highly mobile,and settlements are thought to have included small
temporary camps and less common base camps that were occupied by loosely organized bands.
Paleoindians selected high-quality lithic materials for tools, and many sites are linked to important source
areas. Keel (1976:17) suggests that the earlier Clovis phase (pre-9000 B.C.) populations may have been
confined to south of an east-west line at the latitude of Asheville because of permafrost to the north. The
later Paleoindian phase appears to include Dalton(Goodyear 1982) and perhaps Hardaway (Ward 1983)
points and related cultures, although both types of artifacts are also very rare in the Appalachian Summit
region(Purrington 1983).
Archaic Period(ca.8000-700 B.C.)
The Archaic period began with the onset of Holocene,post-glacial climatic conditions in the East, and has
been subdivided into three subperiods: Early, Middle, and Late. Diagnostic projectile points are the
primary criteria used to identify and date distinct Archaic manifestations.As a whole,the Archaic may be
seen as a relatively long and successful foraging adaptation, with subsistence based on hunting, fishing,
and the collection of wild plant resources. The period is also marked by a general increase in the density
and dispersal of archaeological remains, more regionally distinct tool forms, and the increased use of
locally available lithic raw materials. Group size gradually increased during this period, culminating in
relatively large populations by the end of the period. While Archaic groups no doubt used a variety of
materials to fashion utilitarian and other items, lithics are all that remain on almost all sites in the
southeast due to lack of preservation in acidic soils. Architectural evidence is rare, indicating that most
structures were not substantial constructions. Few Archaic sites have been the focus of intensive
excavation in the Appalachian Summit(but see Purrington 1981; Shumate et al. 2000, 2001; Webb et al.
2005), although several Archaic sites have been investigated in eastern Tennessee in the Tellico area(e.g.
Chapman 1981)and in the North Carolina Piedmont(Coe 1964).
Early Archaic (ca. 8000-6000 B.C.). During the Early Archaic period, the mixed coniferous forests
present in much of the Southeast were replaced by mixed hardwood communities dominated by oak,
hemlock, beech, and maple (Claggett and Cable 1982:212). A modern faunal assemblage was in place
following the extinction of the Pleistocene megafauna. Diagnostic markers of the Early Archaic period in
western North Carolina and eastern Tennessee include side-notched Big Sandy projectile points and later
Palmer-Kirk projectile points (ca. 8000-6800 B.C.). Palmer-Kirk projectile points are fairly common and
widespread oceurrences in the area,but are sparse compared to Middle and Late Archaic types. Bifurcate-
based points such as the St. Albans, LeCroy, and Kanawha types (ca. 6900-5800 B.C.) are also found in
the area (Kimball 1985), but appear to occur more rarely in the mountains than Kirk forms as is the case
in northern Georgia and eastern Tennessee (Kimball 1996; Stanyard 2003). However, a survey near
Asheville by an amateur archaeologist (Henry 1992) documented more bifurcates than Kirks, perhaps a
reflection of better survey coverage up a smaller tributary(Kimball 1996). Other tools that occur on Early
10

Archaic sites include knives, adzes, end and side scrapers, drills, perforators, and expedient tools
(Stanyard 2003).
Low regional population densities and a continued high degree of group mobility are inferred for this
period in the mountains, where most known sites are located in high upland areas, and over 90% of
projectile points found are of non-local chert(Bass 1975);however, site burial in the floodplains could be
largely masking Archaic period use of these landforms (see Benyshek 2007a; Benyshek and Webb 2004;
Kimball 1991; Webb et al. 2005). The nature of more general land use patterns and. strategies for
technological organization remain the subjects of discussion. To the west in Tennessee, Kimball (1996)
has proposed an ongoing change from logistical (relatively more permanent base camps used from which
a variety of other satellite camps and specialized use sites were accessed) to residential mobility patterns
(wholesale moving frequently within zones to map onto resources) during the later Early Archaic period,
perhaps as a result of the first signs of warning climatic conditions. Kimball (1996:173) notes that
settlement patterns for bifurcate and Kirk groups were different, with more bifurcate sites found on T1
terraces and islands compared to Kirk sites,which are more dispersed on various landforms, suggesting a
change in foraging strategy in the latter Early Archaic. Regardless, based on current data, generally
compared to later periods, a high degree of mobility occurred in the Early Archaic and use of the
Appalachian Summit was less permanent than seen in eastern Tennessee.
Middle Archaic (ca. 6000-4000 B.C.). During the Middle Archaic, the cool,moist conditions of the early
Holocene are generally considered to have given way to the wanner, drier climate of the Mid-Holocene
Hypsithennal interval(although there is increasing evidence that the Mountains may have seen increased
rainfall during this period[e.g.,Leigh 2002]).Extensive estuarine marshes and riverine swamps began to
emerge in coastal regions as sea levels ceased their post-Pleistocene rise by 3000 B.C. The northern
hardwoods vegetational matrix in those regions was replaced by an oak-hickory forest, which was in turn
replaced by a southern hardwoods-pine forest characterized by the species occupying the region today
(Claggett and Cable 1982:212-216; Delcourt and Deleourt 11983, 1985). Subsistence economies became
increasingly diversified, particularly evident in the Mid-South and lower Midwest during the Shell
Mound Archaic,where riverine settings were chosen more often for occupation(Sassaman 1996).
The Middle Archaic witnessed the first substantial occupation in the Smoky Mountains (Bass 1975:109).
Based on site file data, a marked increase in number of sites is evident from the Early to the Middle
Archaic periods in Georgia and the Carolinas in general (Anderson 1996) and Morrow Mountain
projectile points increase markedly compared to earlier types in western North Carolina(Leftwich 1999).
Three subperiods recognized in most of North Carolina are identified by the presence of Stanly(ca. 6000-
5000 B.C.),Morrow Mountain (ca. 5000-4200 B.C.), and Guilford(ca. 4200-3500 B.C.)projectile points,
following the classic Archaic sequence first identified by Coe (1964). Archaeologically, the transition
from the Early Archaic to the Middle Archaic is characterized by the appearance of stemmed rather than
notched projectile points, and an increased incidence of groundstone tools. Reliance on locally available
quartz and quartzite, rather than higher quality non-local chert, for stone tools increased in the
Appalachian Summit and other areas, such as other parts of the North Carolina, northern Georgia and
South Carolina.Atlatl weights make their first appearance in the archaeological record during the Middle
Archaic, found in Stanly contexts at Doerschuk. Stone net sinkers also first make their appearance. The
use of expedient stone tool technology predominates during the Middle Archaic, even with fonnal tools
(Stanyard 2003).
Settlement pattern theories for the Middle Archaic Morrow Mountain peoples based on Sassaman's
(1983) and Blanton and Sassaman's (1989) studies in South Carolina, involve foragers snapping onto
resources until depleted and then moving on (sinilar to Binford's [1980] residential mobility). This is
based on the redundant generalized and expedient stone tool technology utilizing local material, small site
size and wide distribution in various landscape settings, lack of evidence for occupations of duration, and
11

no discernable substantial trade networks (Stanyard 2003:48-49). Morrow Mountain sites are frequently
encountered in the uplands of western North Carolina (e.g., Purrington 1981) and also on smaller
drainages (Yu 2001) and in floodplains of major rivers, and are sometimes buried (e.g. Benyshek and
Webb 2004; Webb et al. 2005). Bass (1975) found half of the Middle Archaic sites in the uplands, with
the others in valleys and coves. If further settlement pattern data were amassed from the Appalachian
Summit, similar conclusions would likely emerge concerning Morrow Mountain populations in the
mountains, as suggested by survey data in the Little Tennessee River valley where a dispersed settlement
pattern was identified and larger sites found on terraces were not at all typical(Davis 1990).
Late Archaic (ca. 4000-1000 B.C.). Like Middle Archaic sites, Late Archaic sites are common in the
study area, although few have been the primary focus of archaeological investigations. The lower
Southeast in general saw an increase in sites from the Middle to Late Archaic, and most researchers agree
that a population increase is reflected in these data(Anderson 1996).During the Late Archaic period,sites
occur in a wide range of environmental zones although most major settlements were in riverine or
estuarine settings (Bass 1975; Ward 1983). In particular, many Late Archaic sites in the Smoky
Mountains region appear to be situated near quartzite sources (Bass 1975:77; 'Shumate and Kimball
2001). The existence of formal base camps occupied seasonally or longer is inferred, together with a
range of smaller resource-exploitation sites, such as hunting,fishing, or plant collecting stations (Claggett
and Cable 1982; Ward 1983). Grinding implements, polished stone tools, and carved soapstone bowls
become fairly common, suggesting increased use of plant resources, and possibly changes in subsistence
strategies and cooking technologies. Although regional evidence is minimal, the first experiments with
horticulture probably occurred at this time,with the cultivation of plants such as squash(Cucurbita pepo),
sunflower(Helianthus sp.), and Chenopodium(Cowan 1985; Ford 1981;Smith 1989).
Late Archaic occupations in the Appalachian Summit region are marked by a variety of large-to small-
stemmed points. The most prominent and recognizable of these is the Savannah River Stemmed type, a
large, broad-bladed, square stemmed point that appears ca. 3000 B.C. and lasts to ca. 1500 B.C.
Subsequent Late Archaic sites frequently contain slightly smaller stemmed points of the -Iddins
Undifferentiated Stemmed or Otarre Stemmed types (Ward and Davis 1999:71). Size reduction of these
stemmed forms, on the average, is clearly indicated over the course of the Late Archaic/Early Woodland
in the region(Oliver 1981, 1985).At Warren Wilson and at the Iddins site,the most common feature type
during the Late Archaic is the rock-filled pit (Chapman 1981; Keel 1976). Towards the end of the Late
Archaic fiber tempered pottery appears in the coastal regions (Sassaman 1993), but is very rare in the
Appalachian Summit. Evidence for trade increases in the Late Archaic compared to the Middle Archaic,
indicated by the presence of soapstone, slate, and rarely olivine outside their source areas (Chapman
1985).
Woodland Period(ca.700 B.C.-A.D. 1000)
The Woodland period began as early as 1000 B.C. and continued until the appearance of the Mississippian
adaptation, around A.D. 1000. Across the eastern Woodlands the period is marked by the appearance of
widespread pottery use, a greatly increased role for horticulture in subsistence economies, and an
elaboration of mortuary ceremonialism,including the appearance of burial mounds.
Early Woodland (ca. 1000-200 B.C.). Initial Woodland occupations are generally thought to reflect a
largely unchanged continuation of Late Archaic lifeways coupled with the first widespread introduction
of ceramics.The earliest Early Woodland manifestation in the project area is the Swannanoa phase,which
dates ca. 1000-200 B.C.One date available for western North Carolina from a probable feature containing
a portion of a Swannanoa fabric impressed conoidal pot; that uncorrected date is 2120±40 B.P. with a 2-
sigma range of 350-50 B.C. (Benyshek and Webb 2006; Reimer et al. 2004). The hallmark of the Early
Woodland is the distinctive thick, crushed quartz or coarse sand tempered fabric impressed ceramics.
12

Cord marked,plain, check stamped and simple stamped wares are also thought to occur late in the Early
Woodland period(Keel 1976:260-266; Ward and Davis 1999:140-143;Wetmore 2002:254-257).Vessel
forms consist of unrestricted conical pots and simple bowls. Eastern Tennessee's Watts Bar and northern
Georgia's Kellogg phases are similar stylistically to Swannanoa materials, as are Vinette ceramics from
as far away as eastern New York(Ward and Davis 1999:142).
Early Woodland projectile points consist of smaller stemmed point forms (including Otarre/Gypsy and
Swannanoa stemmed) that are the terminal expressions of the large stemmed point tradition associated
with the Late Archaic. Large triangular varieties are first seen in this period, including Transylvania and
Garden Creek types, which are morphologically equivalent to Badin and Yadkin Piedmont types (Keel
1976; Oliver 1985). Although Swannanoa site distributions have not been thoroughly documented, it is
apparent that the settlement pattern included both large floodplain sites, such as Warren Wilson, Garden
Creek, and Tuckasegee, along with numerous small upland extractive camps. Direct evidence is lacking,
but it seems likely that the Early Woodland inhabitants of the region were engaged in at least some degree
of horticulture(Ward and Davis 1999:145).Based on evidence at Phipps Bend in eastern Tennessee,deer,
elk, and turkey were the animals primarily hunted in the Early Woodland (Lafferty 1981). To date, no
Early Woodland structures have been definitely identified in the region.
Middle Woodland (ca. 200 B.C.-A.D. 600). The Middle Woodland period is characterized by intensified
long-distance trade throughout the Eastern Woodlands,and there is increasing evidence that some western
North Carolina groups participated in the Hopewell exchange network (Chapman and Keel 1979; Keel
1976; Wetmore 2002:263). Sites with Middle Woodland components that have been the focus of
intensive investigations in the region include Garden Creek in Haywood County (Keel 1976), Biltmore
Mound in Buncombe County (Kimball and Shumate 2003; Kimball et al. 2004), Ela in Swain County
(Wetmore 1989),Harshaw Bottom in Cherokee County(Robinson 1989),Tuckasegee in Jackson County
(Keel 1976), the Tyler-Loughridge site in McDowell County (Robinson 1996), the Cherokee EMS site in
Swain County(Benyshek 2007b),the Bent Creek site in Buncombe County(Shumate and Kimball 2006),
the Macon County Airport site, and the Icehouse Bottom site in Monroe County in eastern Tennessee
(Chapman 1973;Cridlebaugh 1981).
Bass(1975:81)reports that while over 50 percent of Middle Woodland sites in his sample occurred on the
floodplain,40 percent were located above the valley in coves and on benches.Numerous large and small
sites dating to this period have been found, suggesting periodic aggregation and dispersion or some kind
of a village/base camp—specialized resource extraction station settlement dichotomy. By Connestee times,
however, sites have been demonstrated to occur most oflen in the floodplains and a higher percentage are
present on the first rise above the river than in the preceding Pigeon or Swannanoa phases(Wetmore et al.
2000).
Horticulture also is thought to have become increasingly important during this period, although mast
resources remain the most visible dietary contributor. Possible late Middle Woodland cultigens in the
region include maygrass, little barley, sumpweed, maize, squash, and perhaps Chenopodium (Benyshek
2007b; Chapman and Crites 1987; Crites 2004; Robinson 1989).Evidence for the use of animal resources
is scarce from Middle Woodland sites in the area, save Biltmore Mound where preservation is excellent.
Faunal information from the Connestee phase mound area may not be representative of overall diet and
utilization due to the probable ceremonial activities including feasting that took place there, but no
information is available from the village site to date. The assemblage is dominated by terrestrial species
(white-tailed deer, turkey,box turtle, raccoon, squirrel)with aquatic resources (fish, mussels) used much
less frequently(Whyte 2004).
Diagnostic early Middle Woodland ceramics in western North Carolina include the Pigeon series, which
Keel (1976:256-260) defines as including check stamped, simple stamped, plain, brushed, and
13

complicated stamped varieties with crushed quartz temper. Vessel forms include conical jars,
hemispherical bowls, and tetrapodal and shouldered jars with flaring/everted rims. Pigeon ceramics are
relatively common in the region but are generally found in mixed contexts (Ward and Davis 1999:146),
perhaps indicative of stable populations inhabiting the same areas for long periods of time.
Subsequent Middle Woodland ceramics consist of the Connestee series,which are generally thinner,sand
tempered wares most often plain or decorated with simple stamped, cord marked or brushed surfaces.
Crushed quartz temper was added in small amounts. Fabric impressed and check stamped sherds are also
included in the series. Plain necks are characteristic, with punctated shoulders rarely occurring (Keel
1976:247-255). Swift Creek ceramics are often found as a minority ware on Middle Woodland sites in
the area(Kimball and Shumate 2003;Robinson 1989;Ward 1977).Extremely rare,are Ohio Hopewellian
ceramics of non-local manufacture or locally made copies (e.g. rocker stamped) and figurines, but these
have been identified at Garden Creek, the Biltmore Mound site, and at Icehouse Bottom (Keel 1976;
Kimball and Shumate 2003). Lithic artifacts characteristic of the late Middle Woodland consist of large
triangular and side-notched projectile points (Garden Creek and Connestee triangulars, Pigeon side
notched),gorgets, and also a prismatic blade and polyhedral core technology that was probably ultimately
derived from the Hopewellian Midwest (Chapman and Keel 1979:157). Copper is also found on Middle
Woodland sites in the area, such as at the Garden Creek Mound, Cherokee EMS, and Peachtree, but is
rare(Chapman and Keel 1979; Seltzer and Jennings 1941).
Connestee phase populations .engaged in mound building, evidenced by such substructure mounds as
Garden Creek No. 2 and the Biltmore Mound, and interacted with Hopewellian populations in the
Midwest and elsewhere (Keel 1976; Kimball and Shumate 2003; Ward and Davis 1999:151-153).
Connestee series sherds are present on Hopewellian sites, and small numbers of Hopewellian ceramics
and bladelets made of chalcedony from Flint Ridge in Ohio are present at the Garden Creek site, at the
Biltmore Mound site, and at Icehouse Bottom (Chapman 1973; Chapman and Keel 1979; Kimball and
Shumate 2003;Moore 1984).Marine shell was also traded(Kimball et al.2004).It has been hypothesized
that western North Carolina was one source of the mica that was traded and used widely during this
period.
Architectural information has been limited, but at Garden Creek Mound No.2, at the base of the
premound layer,a square structure measuring approximately 6 in across was identified and was attributed
to the Connestee occupation (Keel 1976). At Ela, eight circular strictures 7-8 m in diameter were
identified as representative of Connestee phase constrictions (Wetmore 1989, 2002). Recent excavations
at the Macon County Airport site have also uncovered both circular and square to rectangular Woodland
structures.
Late Woodland (ca. A.D. 600-1000). The Late Woodland period in much of the Southeast saw the
emergence of sedentary village life and intensive maize (Zea mays) horticulture and the development of
complex tribal and chiefdom-level political structures. Certainly, by A.D. 1000, many interior
Southeastern groups were producing substantial amounts of corn, which continued into the Mississippian
period when wild food resources were supplemental to cultivated ones (Scarry 2003:88-89).
In the Appalachian Summit, the Late Woodland is largely invisible, raising questions about its character
there (Wetmore 2002). A similar lack of recognition of distinctive Late Woodland components has been
described in northern Georgia(Rudolph 1991).Part of the problem may be the lack of specific diagnostic
artifacts useful for unequivocally identifying sites of this period (i.e. plain sherds, small triangular
projectile points), but it is also possible that the Appalachian Summit region was more lightly populated
during this time and small,dispersed sites were more typical.Robinson et al.(1994, 1996)have suggested
that the Connestee phase may have lasted well into the Late Woodland period based on work at several
sites. One Late Woodland manifestation was identified by Keel and Egloff(1984) at the Cane Creek site;
14

the distinctive, largely plain-surfaced assemblage from that site is similar to Connestee wares and a single
radiocarbon date from that site is 1340t90 B.P. (uncorrected). Anderson and Schuldenrein (1985:720)
suggest that some materials identified as Middle Woodland Cartersville Phase in the central Piedmont of
Georgia and South Carolina may actually be Late Woodland in age. Plain-surfaced ceramics predominate
in the contemporaneous Simpson's Field assemblage, and the longevity of simple stamped and plain
assemblages was demonstrated at the Rucker's Bottom and Bullard sites, which returned late Late
Woodland dates from contexts containing those wares(Anderson and Schuldenrein 1985). Other parallels
may also exist further to the south in Georgia, where the Late Woodland Vining Phase ceramics are
largely plain and simple stamped (Pluckhahn 1997; Elliott and Wynn 1991; Meyers et al. 1999; Worth
1996).
Scattered Napier and Late Swift Creek ceramics and sites (such as the Cullowhee Valley School site
[31JK32] [Greene 1996:120-121], Biltmore II [31BN175] [Hall and Baker 1993], Ravensford
[31SW78/136], Hominy Creek [31BN828] [Par6 et al. 2007], and Sneed [31JK466] [Benyshek 2008c])
also occur in the region and reflect influences from the south during this period. For northern Georgia,
Rudolph (1991) notes that Caldwell's Swift Creek `B complex" wares are characteristic of the Late
Woodland in that area; these wares consist of finer-lined stamping than classic Swift Creek pottery, and
occur with Napier forms at sites in the upper Chattahoochee and Savannah River valleys, such as the
Annewakee Creek, Tugalo, and the Simpson's Field site (38AN8), which is in the Richard B. Russell
Reservoir (Wood et al. 1986). The B-complex wares appear to be a Late Woodland marker for western
North Carolina as well, if perhaps an infrequent one. David Moore conducted salvage operations at the
multi-component Cullowhee Valley School site, and many of the sherds recovered are very similar in
appearance to the ones found at the single component Sneed site (David Moore,personal communication
2007).In addition,one radiocarbon date obtained from Feature 18 at that site is close to the dates obtained
from the Late Swift Creek Sneed site dates,which are 1270f40 and 1290f30 (uncorrected).The accepted
date range of the Late Swift Creek component at Simpson's Field is very similar to the Sneed and
Cullowhee Valley School site dates (Benyshek 2008c). Rudolph (1991) also suggests that increased
regionalization of ceramic styles occurred during this period in northern Georgia and points out that site
dispersal seems to be the trend compared to earlier Middle Woodland site aggregation and this appears be
the case for western North Carolina as well.
Mississippian Period(ca.A.D. 1000-1540)
The Mississippian period in the Southeast is marked primarily by the increasing intensification of maize
horticulture, the establishment of increasingly hierarchical social structures and settlement systems, and
an increase in ceremonialism expressed architecturally in the constriction of flat-topped substructure
mounds.Increasing evidence exists that territorial boundaries between chiefdoms were closely maintained
during the Mississippian period, although individual chiefdoms rose and fell in cyclical patterns. Studies
of relations between native chiefdoms and Spanish expeditions suggest that some type of supra-chiefdom
level organization was maintained through a system in which paramount chiefs traveled from fief to fief,
displaying royal powers and prerogative and receiving gifts and tribute from subservient chiefdoms
(Smith and Hally 1992).
The Pisgah phase (ca. A.D..1000-1450) corresponds with the early centuries of the Mississippian period,
at least in parts of western North Carolina (Dickens 1976:13-14). Sites with Etowah phase (ca. A.D.
1100-1300) components are present in the Hiwassee River valley (Riggs and Kimball 1996) and in the
upper Little Tennessee River valley. Sites with a larger percentage of Pisgah pottery are found primarily
in the eastern and central part of the Appalachian Summit region, and range from small sites such as
Brunk (Moore 1981) to nucleated villages with substructure mounds such as Garden Creek (Ward and
Davis 1999:160-161). Pisgah pottery is also found in the western part of the summit region as well,
however, and down into northern South Carolina, and into southwestern Virginia and northeastern
15

Tennessee (Dickens 1976). Diagnostic Pisgah artifacts include small triangular projectile points and
distinctive rectilinear complicated stamped vessels with collared,punctated rims.Dickens(1976)suggests
that finer-lined complicated stamping and lack of rim elaboration characterizes the earlier portion of the
phase and Moore (1981) documents some of this material from the Brunk site. Maize and other crops
were important sources of food,but floral and faunal remains document the persistence of wild resources
as major components of the diet (Ward and Davis 1999:171). Warren Wilson is the most extensively
explored Pisgah village to date, and work there over several field seasons documented at least seven
palisade lines and 17 structures; seven of these had entry trenches (Dickens 1976; Moore 2002; Ward
1986). Garden Creek Mound and Village also contains a Pisgah component and the main mound (Mound
No. 1)at that site was constructed during the Pisgah phase(Dickens 1976).
The Qualla phase represents the final centuries of Native American autonomy in the region. Although
elements of the material culture,belief systems,place names, and social structure of Mississippian society
lingered in the region well into the 19th century (and in some cases to the present day), this period is
largely one of social change due to increasing Euro-American intrusion and settlement. This part of the
Native American occupation of the region is discussed below as part of the historic background.
HISTORIC CHEROKEE OCCUPATION
The French Broad drainage lies east of the core area of known 17th and 18th century Cherokee settlement,
which was concentrated in the Blue Ridge Mountains to the west and southwest. The area was likely
frequented by Cherokee hunters, however, and may have contained small settlements at various times as
well. According to Mooney (1900:380-381), the French Broad lies west of a neutral area between the
Cherokees and the Catawbas,which was bounded by the Catawba River on the east and the Broad River
on the west(Mooney 1900:380-381).
Pre-Removal Cherokee Occupations
The first Euro-American intrusion into western North Carolina took place in 1540, when Hernando de
Soto's expedition passed through the area. Several different reconstructions of de Soto's route have been
proposed, with some early scholars (e.g., Swanton 1985:201-202) suggesting that he crossed Cherokee
country by way of the Hiwassee River valley. A later reconstruction (Hudson et al. 1984) proposed that
de Soto crossed the Blue Ridge farther to the north at Swannanoa Gap, and then continued along the
French Broad River into Tennessee;more recently,Beck(1997)and Hudson(1997:193)have agreed that
the expedition probably followed a more northerly route along the Toe River. The route through the
Swannanoa Gap may have been taken by Juan Pardo, however, who was a Spanish explorer who
traversed much of the same area in 1567-1568 (Beck 1997:167;Hudson 1990:27-46, 1997:193).
Whatever the precise routes of these explorers, it is clear that the ancestral Cherokees' first encounter
with Europeans occurred in the mid-16`h century(and that the Spanish were unlikely to have traversed the
present project area). These encounters were to have dramatic effects. The introduction of European
diseases to which the native populations had little resistance caused a major reduction in Native American
population levels and extensive changes in political organization. Elsewhere in the Southeast, the
fragmentation and reformation of political groups resulted in a general decrease in social complexity and
the total disappearance of some prehistoric societies (Smith 1987). Although substantial disruption
occurred,the Cherokee managed to retain control of portions of their homeland.
The historic-period Cherokee occupation of western North Carolina is known archaeologically as the
Qualla phase (ca. A.D. 1450-1838). Although early formulations of the phase (Dickens 1976) divided it
into two segments (Early Qualla, ca.A.D. 1450-1650; and Late Qualla, ca. A.D. 1650-1838),more recent
analysts (Riggs and Rodning 2002; Rodning 2004, 2008; Ward and Davis 1999) suggest a tripartite
16

division. Following this latter scheme, the Early Qualla phase predates A.D. 1500, and thus was likely
contemporaneous with at least the latter part of the Pisgah occupations in the region. These authors
suggest that Qualla represents an in situ development in the Upper Little Tennessee and Hiwassee basins
and likely is not a direct derivative of the Pisgah phase.Early Qualla phase ceramics show affinities to the
more southern Savannah and Wilbanks styles, and samples from Coweta Creek and 31SW291 are
characterized by "grit" tempered, primarily rectilinear complicated stamped wares (Riggs and Rodning
2002:39), sometimes with"sawtooth"rims. Red filming also occurs (Rodning 2004).Pisgah collared and
punctated rims are not an uncommon occurrence with these Early Qualla wares, however, and Early and
Late Pisgah ceramics have been identified at Ravensford. Domestic winter structure forms during the
Early Qualla are the same as Late Pisgah forms (Benyshek and Webb 2008).
Subsequent Middle Qualla phase (ca. A.D. 1500-1700) ceramics are characterized by jar forms with
notched appliqu6, or more often, folded and notched everted to flared rims, and also by the presence of
carinated or cazuela bowls with incised designs. Curvilinear complicated stamping predominates,
although rectilinear designs are also present(Rodning 2004). By the Late Qualla phase (post-A.D. 1700),
some variations occur; incised ceramics become much less common, while rectilinear stamped designs,
rims with notched appliqu6 strips or fillets, and check stamping become more common in later, pre-
Removal (pre-1838) assemblages. Sometime during the Middle Qualla phase, domestic structure forms
change to paired winter and summer dwellings sometimes attached by entryway trenches. Summer
dwellings were rectangular in shape, while winter houses were circular to octagonal (Shumate and
Kimball 1997; Shumate et al.2005;Webb and Benyshek 2008).
The Qualla subsistence base was mixed,and included cultivation of maize,beans, and other foods as well
as wild plant gathering,hunting, and fishing (Dickens 1976:14). The Late Qualla phase is marked by the
increasing appearance of European goods at Cherokee sites, as well as a shift towards more European-
style architecture (Dickens 1976:15). Although small triangular projectile points are found in Early and
Middle Qualla assemblages, these largely disappear with the increasing prevalence of European firearms
after A.D. 1700.
During most of the 181h century, the Cherokees were concentrated in towns and villages scattered
throughout much of present-day western North Carolina, eastern Tennessee, northeastern Georgia, and
northwestern South Carolina. The towns in western North Carolina were known as the Middle Towns
(along the Little Tennessee), the Out Towns (along the Tuckasegee drainage), and the Valley Towns (in
the Valley River area to the southwest) (Smith 1979; Duncan and Riggs 2003:17). The French Broad
drainage lies east of the core area of known 17`h and 181h century Cherokee settlement, which was
concentrated in the Blue Ridge Mountains to the west and southwest. The area was likely frequented by
Cherokee hunters,however, and may have contained small settlements at various times as well.
The 18`h century also brought the continuous arrival of Europeans and the resulting loss of Cherokee
lands. With the signing of the Treaty of Hopewell in 1785, the Cherokees lost inuch of their lands east of
the Blue Ridge, leading to widespread Euro-American settlements east of Asheville (Mooney 1900:61-
62). A subsequent treaty in 1791, the Treaty of Holston,resulted in additional cessions by the Cherokees
in the west (Mooney 1900:68-77), and a treaty in 1798 ceded additional land south and southwest of
Asheville within present-day Buncombe, Henderson, Transylvania, and Haywood counties (Royce
1899:660-661).
The early 19`h century witnessed the increasing acculturation of many Cherokees, largely as a result of
increasing contact and intermarriage with white traders and settlers. Other Cherokees resisted changes to
their traditional lifestyles, especially those residing in western North Carolina (Riggs 1988:10-11).
Accounts by contemporary observers indicate that the population of that area was strongly traditionalist,
17

and contained the highest proportion of fullbloods to be found in the Cherokee Nation (McLoughlin and
Cosner 1984:224-225).
Most remaining Cherokee land claims in North Carolina were ceded to the U.S. government by the
Calhoun Treaty of February 1819 (Royce 1884, 1887), and the signing of the Treaty of New Echota in
1835, which set in motion the forced removal of many of the remaining Cherokees to lands in the
Arkansas Territory (Mooney 1900:123-133; Thomason 2003). The cruelty of this march, known as the b
Trail of Tears,has been well documented.
Post-Removal Cherokee Occupations
Despite the Treaty of New Echota and the Trail of Tears, however, some Cherokee.remained in their
former lands. A sizeable population living along the Oconaluftee and nearby was allowed to remain as a
result of their assistance in the Tsali affair. Other Cherokees remained in the vicinity of Cheoah (along
Buffalo Creek in present-day Graham County), primarily due to the difficulty in removing them along
poor roads (Duggan 1998). Finally, still other Cherokees managed to evade the Army, escaped during the
Removal, or, like Junaluska, returned from the Arkansas territory soon afterwards. These groups became
the nucleus of the Eastern Band of Cherokee (King 1979). After the death of Chief Yonagusta in 1839,
they were increasingly assisted by William H. Thomas, a white merchant who was Yonagusta's adopted
son. Thomas worked on the Cherokees' behalf for the next 40 years, acquiring land for both individual
Cherokees and the tribe. Thomas eventually acquired some 73,000 acres for these communities, mostly
within the present-day Qualla Boundary.
The mid-19`h through 20 century social and political history of the Eastern Band has been described in
detail by Finger(1984, 1991),Hill (1997),Mooney (1900), and others, and needs only be recapped here.
By 1840,Thomas had assisted the Quallatown residents into organizing into three towns, including Paint
Town,Wolf Town, and Bird Town. Two other towns, Big Cove and Yellow Town, were later added to
these three (Finger 1984:67). By 1851 approximately 883 Cherokees were living in three towns in the
Quallatown area. The Cherokees' rights to the lands bought by Thomas were confirmed by a federal court
decision in 1874, providing some measure of security to the local population. In 1889, the Cherokees in
North Carolina were officially incorporated under state law as the Eastern Band of Cherokee Indians
(Finger 1984). Most Cherokees continued to practice a farming economy throughout the 19`h century,
although hunting, fishing, and gathering wild plant foods were also important subsistence activities.
Logging became an important source of jobs for a time beginning in the late 1800s, although most
logging jobs were gone by the early 1930s. Although the Cherokee population has increasingly become
outwardly acculturated since the growth of the modem tourist industry beginning in the 1930s, it has
preserved a distinct cultural and ethnic identity through the retention of the Cherokee language and
aspects of both day-to-day and ceremonial life(Riggs et al. 1997:19).
REGIONAL HISTORIC OVERVIEW
Buncombe County
Prior to the American Revolutionary War, the Blue Ridge Mountains formed the western terminus of
European settlement in North Carolina. The first documented English foray into the French Broad
drainage west of the Blue Ridge Escarpment occurred in 1674.This doomed expedition was led by James
Needham and included an indentured servant, Gabriel Arthur, and eight native guides. Financed by a
wealthy Virginian, Abraham Woods, the expedition did not provide the profits expected by the financier,
but it did begin the opening of the vast lands of the Cherokees,which were coveted by the Euro-American
settlers for their natural resources and beauty(Dykeman 1965:27-41).
18

During the Revolutionary War the Cherokees sided with the British in the hope that a defeat of the
colonists would stem the spread of colonial settlements within their traditional homelands. This alliance
led to a number of military expeditions against the Cherokees in western North Carolina. The three major
incursions against the Cherokees included colonial troops from North Carolina led by General Rutherford,
Virginia troops led by Colonel Christina, and Tennessee troops led by Colonel Sevier (Dykeman 1965).
Rutherford's 1776 campaign likely crossed the closest to the project area, as his 2,400 men crossed the
Swannanoa Gap and followed the river of the same name to the French Broad and then on to the
Tuckasegee, Oconaluftee, and the upper Little Tennessee rivers, eventually destroying 36 Cherokee
towns. After the war, the Cherokee signed their first treaty with the United States government at
Hopewell, South Carolina, in which they surrendered all lands east of the Blue Ridge, but maintained
their home lands to the west(Arthur 1914:569-572).
After the war, and with the Cherokees mostly subdued, large numbers of settlers (mostly Scots-Irish but
also English, Welsh, German, and French) moved into western North Carolina (Ager 1981:10; Blethen
and Wood 1987:76; Sondley 1930.398).After 1783,Land Act legislation was approved that allowed land
sales for western settlements. In addition, war veterans were rewarded with land grants in the west as
compensation for time served.
In 1784 Samuel Davidson, his family and a single slave became the first known colonial settlers west of
the Blue Ridge Mountains,in what was to become Buncombe County.They settled along the Swannanoa
River near Jones Mountain. After Samuel Davidson's death,his brother(Major William Davidson),sister
(Rachel Alexander), their families and several friends followed in his footsteps and established a
settlement a year later near the confluence of Bee Tree Creek and the Swannanoa River.
As the new settlement grew, western expansion into the mountains was rapid. By 1792, the County of
Buncombe was created, including present-day Buncombe,Cherokee, Clay, Graham,Henderson, Jackson,
Macon; Madison, Polk, Swain; Transylvania, and Yancey counties. Eventually, the Buncombe County
Court was established between the Bee Tree Creek settlement and the Reems Creek Valley settlement; the
court met on the property of Colonel William Davidson(a cousin of Major William Davidson), near the
present-day entrance to the Biltmore Estate(Ager 1981:10-11; Sondley 1930:460).The joining of the two
settlements was originally known as Morristown in 1792 (Blackmun 1977:162). In 1794, John Burton
was granted 200 acres by the State of North Carolina next to William Davidson's property. Forty-two
half-acre lots were laid off and sold on Burton's property along two newly formed roads now known as
Broadway and Biltmore Avenue (Powell 1981:33). The town was incorporated in 1797 and renamed
Asheville after Governor Samuel Ashe(Van Noppen and Van Noppen 1973:379).
Although, the communities along the Swannanoa River were the first establishments in Buncombe
County, Asheville became the dominant city and county seat. By 1800,Asheville had a hatter, a tailor, a
blacksmith, an inn, a gristmill, and several merchants (Powell 1981:33). A post office was established in
1800 and the Public Square (now known as Pack Square)was laid out in 1805 (Sondley 1930:648-649;
Stroupe et al. 1996). A brick courthouse was built in the square between 1825 and 1833 (Sondley
1930:649). By the early 1800s Asheville was a stopping point for livestock, as herders moved cattle from
Tennessee and Kentucky to market in Georgia and South Carolina along the Buncombe Turnpike (Powell
1981:34).The road ran from Greeneville,Tennessee,to Hot Springs and then along the French Broad into
Asheville. From there,the road headed towards Old Fort and then on to Greenville, South Carolina. Most
of the roadway was completed by 1827 and helped to contribute to the growth of the town (Blethen and
Wood 1987:88). With a higher traffic flow through the region, Asheville experienced an economic and
population boom (Powell 1981:34). In addition to drovers, the turnpike also brought in some of
Asheville's first tourists. By 1860, the town had a population of 1,100, while 12,654 people resided in
Buncombe County(Blackmun 1977:288; Powell 1981:38;Sondley 1930:827-828).
19

During the Civil War, a rifle factory was located in the town for a short time, but because of the fear of
Union troops in nearby Tennessee it was later moved to Columbia, South Carolina.In April 1865, a small
skirmish occurred near Reed Creek north of the town, on land that is now part of the University of North
Carolina at Asheville campus (Sondley 1930:691-697; Powell 1981:36-37). Overall, little physical
damage from the Civil War occurred in the town, but growth was interrupted and railroad construction
was delayed.
In 1880, the railroad (Western North Carolina Railroad) was established to Asheville from Old Fort,
connecting towns that had earlier been served by the Buncombe Turnpike. Just the year before, the first
telegraph line was built, and a public library opened(Bishir et al. 1999:56;Van Noppen and Van Noppen
1973:379). In 1882, the rail line was completed to the Tennessee state line and by 1886 the railroad
connected Asheville to points in all directions (Bailey et al. 2000). With new and easier access,Asheville
experienced a revival in growth.From a population of about 2,600 in 1880, it had swollen to over 10,000
in 1890. By 1920, nearly 28,500 people resided in the town (Sondley 1930:828). In addition to an
increase in industries such as logging in Buncombe County, Asheville grew as a resort for leisure and
health. In the years after 1880, several sanitariums were opened in the town as many doctors
recommended the healthy climate of Asheville and the surrounding area (Van Noppen et al. 1973:379).
As tourism grew,many of the people who visited built second or vacation homes in the Asheville area or
returned to invest in local industries.
Henderson County
Henderson County was formed in 1838 from a portion of Buncombe County and was named in honor of
Leonard Henderson, Chief Justice of the Supreme Court of North Carolina (Corbitt 1996:120). However
land grants in what would become Henderson County began .in 1787, starting in the Mill River Valley
with a grant to William Mills who established Fruitland(Patton 1976). Hendersonville, the county seat,
was laid out in ca. 1840 after much debate about its location. Two factions had developed over the site of
the new county seat—those that favored the community of Horse Shoe located on the French Broad River
and those that favored a more central location on the Buncombe Turnpike (which ultimately won out}--
resulting in a number of debates and lawsuits (FitzSimons 1976:68). Hendersonville was incorporated as
a town in 1847(Patton 1976:237).
From its earliest history, transportation remained an important issue to those living in western North
Carolina, particularly in the more mountainous reaches. A stagecoach line serviced Henderson County
primarily by way of the Buncombe County Turnpike. The Buncombe Turnpike,running from Greenville,
Tennessee to Greenville, South Carolina, was completed in 1827 and passed through Flat Rock and
Hendersonville. Tourists, mainly from the low-country south, came to the area; boarding houses and
hotels sprang up to accommodate summer visitors. Flat Rock was called "The Little Charleston of the
Mountains," due to the large number of prominent Charlestonians who came to the vicinity beginning in
the early 1800s in an effort to escape ailments typical of crowded cities and the heat of the Lowcountry
(Ray 1970). As the population and commerce grew in western North Carolina, transport of goods and
people became increasingly important to the region.By 1879,the Asheville and Spartanburg Railroad had
reached Hendersonville,linking that town to larger commercial and industrial centers.
Similar to most western North Carolina counties, Henderson did not see much military action during the
Civil War. Initially, Henderson County voted against considering secession from the Union. After the
declaration of war, however, many county residents joined the Confederate cause. According to Fain
(1980:51),over 1,000 Henderson County men joined the war effort with less than half returning at the end
of hostilities. At least five Confederate Companies were formed in Henderson County, and numerous
other men enlisted in other service branches or companies;it is believed that ahnost as many men enlisted
in the Union (Fain 1980:51).In addition to the enlistment or conscription of many of the able-bodied men
20

in Henderson County,those remaining had to endure economic hardships through a scarcity of goods,the
raiding of farms for provisions by troops, and the damage wrought by bushwackers throughout the region.
The only known military action within the county was the presence of Union troops in Hendersonville
under the command of Major General George W. Stoneman during his capture of Asheville (Fain
1980:59).
The early 20`h century saw increased growth in the county, as in the region in general. Henderson County
continued to be a region of farming and fruit growing, but also remained an important destination for
tourists.At that time,Hendersonville had become an important tourist town and was frequently compared
to Asheville in terms of its amenities and "social charm" (Arthur 1914:182). By 1913, Hendersonville
reportedly had "everything in the way of hotels, boarding houses, clubs, banks, street railways, parks,
lights, water, livery and other advantages that could be wished" (Arthur 1914:182). Bishir et al.
(1999:310)reports that by the 1920s the town was well known as a tourist destination, attracting big band
musicians and performers while claiming to be the "dancingest little town in America." A number of
country resorts were sited,within the county including a few on Osceola Lake and Kanuga Lake,and ones
at Chimney Rock, Buck Forest,Fletcher, and Buck Shoals (near the current project area). Manufacturing
enterprises had also arisen,including at least three textile mills, a cannery, and a furniture factory(Arthur
1914:184-185).
Henderson County has continued to grow throughout the 20`h century. Although agriculture remains an
important economy in the county,manufacturing and tourism have continued to grow.As with other areas
of western North Carolina, the late 201h century has brought an influx of tourists and new residents, with
associated increased development. As of 2007, Henderson County boasted just over 100,000 residents
with a projected 25 percent growth over the next decade(Henderson County Government 2007).
Asheville Airport History
The current location of the Asheville Regional Airport represents the second incarnation of a regional
Western North Carolina airport; the first was located approximately three miles to the east in the
Fletcher/Hooper's Creek area. Located along the Buncombe and Henderson county boundaries, the
airport originally was a joint operation between the two counties and the city of Asheville. Complexities
in the joint ownership, along with the need for expansion, led the city of Asheville to seek a different
arrangement. By the late 1950s the present location was selected, and a land swap of approximately 30
acres was made between Buncombe and Henderson counties. Henderson County received the old airport
location, which is now an industrial park, and the city of Asheville received the land that houses the
current airport(Fain 1980:7). The current airport was constructed between 1958 and 1960 and opened for
business in 1961. It has seen a number of additions and improvements over the years in order to continue
to serve not only the cities of Asheville and Hendersonville but the entire Western North Carolina region
(http://www.flyavl.com/airport-info/avl-airport-history.html).
PREVIOUS ARCHAEOLOGICAL RESEARCH
Western North Carolina has been the subject of archaeological research for over a century, and most
trends in the history of North American archaeology are reflected in the region. As early as the 1880s,
workers from the Valentine Museum in Richmond investigated several mound sites in the region
(Dickens 1976:7), and other early investigations were carried out by the Osbornes (Keel 1976). The
museum's work was primarily oriented toward recovering artifacts, although in some cases the resulting
data have been useful in addressing present-day research questions (e.g., Dickens 1976:91). Also in the
1880s, researchers from the Smithsonian Institution's Bureau of Ethnology excavated sites in western
North Carolina as part of their investigations into the origin of the "Mound Builders" (Thomas 1894).
That research was instrumental in demonstrating that the mounds in western North Carolina and
21

elsewhere had in fact been built by American Indians and were not the products of a mysterious,vanished
race.
Early 20`h century work in western North Carolina continued to focus on mound explorations. Between
1915 and 1919, George Heye and associates excavated at the Garden Creek site in Haywood County and
at other.nearby sites (Harrington 1922;Heye 1919;Heye et al. 1918).Although that work was designed to
gather artifacts for Heye's Museum of the American Indian in New York,it did provide some data on the
antiquity of the Cherokees in the region (Dickens 1976:7-8). Subsequent work in 1933 and 1934 by the
Smithsonian Institution at the Peachtree Mound and Village in Cherokee County was also designed to
investigate the relationship between the Cherokees and prehistoric cultures in the area (Setzler and
Jennings 1941). Also in the 1930s, George MacPherson (1936a, 1936b) and Hiram Wilburn conducted
surveys of numerous sites in Great Smoky Mountains National Park.Although many of their data were to
be incorporated into later research (Bass 1975), at the time their work had little impact on the
understanding of the region's prehistory.
Intensive, systematic work in the Appalachian Summit region did not begin until 1964, when the
University of North Carolina instituted the Cherokee Archaeological Project. This project, which lasted
until 1971, included large-scale surveys and salvage excavations, as well as intensive investigations of
late prehistoric and historic Cherokee sites (Purrington 1983:98-99; Ward 1979; Ward and Davis
1999:17-18). Data from this project have been reported in several theses, dissertations, and other
publications (e.g., Dickens 1976; Egloff 1967; Keel 1976), and provide much of the background
information on the Appalachian Summit region.As part of that project,substantial work was conducted at
the Warren Wilson site, and documented a Mississippian period Pisgah phase village as well as earlier
Woodland period occupations (Keel 1976). Other substantial work was accomplished at Coweta Creek
(Rodning 2004), Garden Creek (Keel 1976), Townson (Ward and Davis 1999; 268-271), and at the
Tuckasegee site(Dickens 1976).
Beginning in the 1970s, the establishment of Federal cultural resources legislation and management
procedures resulted in an increasing number of archaeological projects in both Buncombe and Henderson
Counties as well as the rest of western North Carolina.In the immediate vicinity of the airport and along
the Buncombe—Henderson County line there have been a few relatively recent archaeological projects, as
a result of civic improvements (Ayers 1981; Whyte and Kimball 1993), Department of Transportation
(DOT)road projects (Padgett 1983) and improvements and additions to the airport(Benyshek and Kesler
2008;Hall 1995).
22

4. RESEARCH GOALS AND METHODS
RESEARCH GOALS
The primary goal of the project was to systematically gather data on any cultural resources present within
the survey tract for the purposes of regulatory compliance. In addition,the archaeological field data were
to be combined with information obtained in the background research to address the nature of the
prehistoric and historic period occupations of the area.
RESEARCH METHODS
Specific research methods were utilized for the background studies,field research, analysis, and reporting
stages of the project.The methods used in each stage of research are outlined below.
Background Research
Background literature review was conducted to gather information on any known cultural resources on or
adjacent to the tract within a one mile in radius around the project area, and included examination of the
following materials:
• Archaeological site files and reports at the North Carolina Office of State Archaeology in Asheville and
Raleigh;
• North Carolina cemetery survey maps at the North Carolina State Archives, Henderson County GIS
cemetery data,and any available published Henderson County cemetery records;and
• Historical maps and other data available on-line, in the UNC-Chapel Hill North Carolina Collection, the
North Carolina State Archives,in TRC's collection and similar repositories.
Archaeological Field Methods
The archaeological survey complied with all pertinent state and federal regulations, including the North
Carolina Office of State Archaeology's (OSA) Guidelines for Preparation of Archaeological Survey
Reports in North Carolina. The field survey was conducted by a team of two, consisting of the Field
Director and one Archaeological Technician.
Following standard regional procedures, the archaeological survey consisted of the excavation of shovel
tests at 20-m intervals across the four separate areas. Shovel tests were excavated in all parts of the survey
areas with the exception of those that exhibited 10% or more slope,hydric soils, and/or showed signs of
severe prior disturbance. All portions of the four project areas also were subjected to a pedestrian survey
to search for any surface indications of archaeological sites.
All shovel tests measured about 30 to 35 cm in diameter and were excavated to sterile subsoil or at least
60 cm below surface. All soil was screened through 1/4 inch screen for uniform artifact recovery. Each
shovel test was described in terms of depth, stratigraphy, and artifact recovery (when applicable).
Furthermore,the texture and Munsell soil color of representative soils was recorded.
The single positive shovel tests was delineated at 10 in intervals until two consecutive negative shovel
tests were excavated or up to either natural boundaries or artificial obstructions. A site map was then
drawn, GPS coordinates were obtained, photographs were taken and observations were made concerning
23

environmental conditions and the extent of previous impacts such as erosion, plowing, deposition, and
development.
Artifact Analyses
Following the completion of field work, the recovered artifact was returned to TRC's Asheville office for
processing, cleaning, and analysis. The single debitage fragment was classified according to raw material
type.
NRHP Eligibility Evaluations
A significance recommendation was made for each archaeological site in terms of its eligibility for the
National Register of Historic Places, following the NRHP Eligibility Criteria as outlined in 36 CFR 60.4
(USDOI 1991).The NRHP Eligibility Criteria state:
The quality of significance in American history,architecture,archeology,engineering,and culture
is present in districts, sites, buildings, structures and objects that possess integrity of location,
design,setting,materials,workmanship,feeling and association.
(a).That are associated with events that have made a significant contribution to the broad patterns
of our history;or
(b).That are associated with the lives of persons significant in our past;or
(c).That embody the distinctive characteristics of a type,period,or method of construction;or that
represent the work of a master, or that possess high artistic values; or that represent a significant
and distinguishable entity whose components may lack individual distinction;or
(d).That have yielded,or may be likely to yield,information important in prehistory or history.
24

5. RESULTS
BACKGROUND RESEARCH
Previously Identified Resources
Archaeological Sites. The archaeological site files and records at the SHPO contain information on four
previously recorded archaeological sites (31HN73, 31HN74, 31HN96, and 31HN113) within a mile
radius of the project areas (Table 1). All four sites are located south of Old Fanning Bridge Road on or
adjacent to the French Broad River floodplain..
Table 5.1.Previously Recorded Archaeological Sites within One Mile of Project Area.
Site No. Description NRHP Eligibility Reference
3113N73 Middle/Late Archaic lithic scatter camp Ineligible Ayers 1978
31HN74 Middle Archaic to Early Woodland camp Ineligible Ayers 1978
31HN96 Late Archaic lithic scatter Ineligible Padgett 1983
31HN113 Non-diagnostic prehistoric lithic/ceramic scatter Ineligible Whyte and Kimball 1993
One site (31HN74) is located either in or immediately adjacent to the large ca 6.0-acre field (Area 4)..
That site was recorded in 1978 during a survey of the South Buncombe Interceptor Sewer Project(Ayers
1978), and identified as a low density surface scatter of prehistoric lithic and ceramic artifacts atop a
small ridge extending into the floodplain. While the mapped location of this site corresponds with the
approximate location of the northern part of Area 4, the topography described 32 years ago does not
correspond with the current field conditions. No evidence of the site was found either in surface or
subsurface contexts.during TRC's survey of the area. The site may be located in the field immediately
north of the current project area; alternatively, the area may have been heavily disturbed and altered so
that no evidence of the site remains.
The three remaining sites include a Middle to Late Archaic period lithic scatter(31HN73),a Late Archaic
lithic scatter (31HN96) and a non-diagnostic prehistoric artifact scatter (31HN113). All four sites were
described as lacking intact subsurface cultural deposits, and were previously recommended ineligible for
the NRHP(Ayers 1978;Padgett 1983;Whyte and Kimball 1993).
Cemeteries. Examination of the Henderson County GIS website (ht�t ://gisweb.hendersoncgLi c.org/
GoMaps/map/Index.cf m) and a compilation of data on Henderson County cemeteries (Henderson County
Genealogical and Historical Society [HCGHS] 1995)revealed no known cemeteries within a mile of the
project area. The Buncombe County GIS website OM:Hgis.buncombecoimiy.org/buncomgp-o records a
single cemetery within a one mile radius of the project area; the Boiling Springs Baptist Church Cemetery
is located approximately 0.7 mile northeast of the project area, south of Fanning Bridge Road(SR 1358)
where it crosses Interstate 26.No evidence of any unrecorded cemeteries was observed by TRC personnel
in the survey areas.
Historic Maps of the Project Area
In addition to the site file check, historic maps were examined to evaluate past land use and determine if
there was any potential for historic sites in the vicinity. As the project area location is at the border of
both Henderson and Buncombe counties (and the airport property was formerly in Henderson County),
maps of both counties were examined. The 1907 Henderson County Soil map (Hearn and MacNider
1908) depicts three major roads in the project vicinity (including one that is now Old Fanning Bridge
Road) and three structures that appear to be northwest of the current project area (Figure 5.1). The 1938
25

Henderson County road map (NCSHPWC 1938b) shows that the area was crossed by a number of roads,
and that several structures were situated in the general vicinity (Figure 5.2). Due to the schematic nature
of the map, however, it is not possible to discern if any of those structures were within the current survey
areas. Review of the 1938 Buncombe County road map (NCSHPWC 1938a) shows little detail at the
airport location with the exception of Fanning Bridge Road and a few unnamed roads. No evidence of
historic period occupation was discovered during the archaeological survey.
ARCHAEOLOGICAL FIELD SURVEY
The intensive survey included a surface pedestrian survey and subsurface testing at 20 in intervals across
all four survey areas (Figures 5.3 and 5.4). A total of 139 shovel tests were excavated, including 28 in
Area 1, 37 in areas 2 and 3, and 74 in Area 4. Additionally, as a portion of Area 4 is situated on a
floodplain terrace along the French Broad River, a hand auger was used to facilitate excavations deeper
than the 60 cmbs reached with shovels. Not all shovel tests were augered, but a sufficient number were
tested to demonstrate that no buried cultural soils exist in the proposed project area.
As the project areas had not been marked in the field,in some cases the survey coverage extended outside
the apparent area boundaries to ensure that the coverage was complete; in addition,the Area 4 survey was
inadvertently extended across the large wetland area to the bank overlooking the French Broad River.
The soils encountered were generally eroded and disturbed,with very little consistency among the shovel
tests. The soils in Area 1 consisted of a shallow compact A horizon of strong brown (7.5YR 5/6) silt or
silt loam that extended to about 15 to 25 cm below surface(cmbs);the underlying subsoil was a yellowish
red (5YR 4/6) compact silty sand. The shovel tests along two small intermittent drainages in Area 1
contained mottled hydric soils beneath the A horizon.
The soils in Area 2 varied considerably,with a deep A horizon found at the west end of the drainage.That
soil consisted of brown (I OYR 5/3) silt to silt loam extending up to 43 to 54 cmbs, and overlying a thin
(approximately six cm thick) lens or band of compact light olive brown (2.5YR 5/4) sand. The subsoil
was dark gray(1 OYR 4/1)silty sand.Further upstream along the drainage,the soils became shallower and
consisted of a reddish brown (5YR 4/4) clay loam or light reddish brown (5YR 6/4) silt loam A horizon
that extended to 19 to 25 cmbs,and overlay dark gray(I OYR 4/1)very sandy clay subsoil extending to 37
to 45 cmbs. Two shovel tests also contained a thin (approximately six cm thick) lens or band of light
grayish brown(1 OYR 6/2)silty sand mottled with pockets of yellowish brown(1 OYR 516)sand.
The soils along both sides of the northern drainage (Area 3) consisted of either a dark yellowish brown
(10YR 3/6) loam or a brown (10YR 5/3) silt loam A horizon that extended to an average depth of 30
cmbs,and overlay a yellowish brown(1 OYR 5/6)silty clay loam subsoil.
The soils within Area 4 showed much greater variation and evidence of disturbances, with fragments of
black plastic found throughout the A horizon. Within the northern part of the field, the A horizon was a
very compact brown(I OYR 5/3) silt loam extending to approximately 15 to 20 cm below surface(cmbs);
shovel test pits close to the fence line along Old Fanning Bridge Road contained moderate to heavy
amounts of gravel. Subsoil was encountered at varying depths ranging from 23 to 35 cmbs, and consisted
of compact brownish yellow (10YR 6/6) silt loam. Closer to the hydric/wetland area in the center of the
field,the soils consisted of a dark yellowish brown(1 OYR 4/6)silt loam A horizon extending to depths of
12 to 25 cmbs, and overlying strong brown (7.5YR 516) silt clay loam extending to approximately 50 to
70 cmbs.
26

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Figure 5.3.Location of project areas and site 31BN958,Buncombe County,North Carolina.
28

,Area 2
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\ 100 400 ft
\ \ 200
\ Project areas surveyed[]
/
\ / Shovel test transects
Isolated Find (IF)
Figure 5.4. Detail inap of project areas and site 31BN958..

The survey recovered only a single artifact; that was a non-diagnostic prehistoric chert flake in a shovel
test on the south side of the drainage in Area 2,which has been designated 31BN958.
31BN958 (Isolated Find 1)
This isolated find consists of a single non-diagnostic prehistoric chert flake found within the%plow zone 1
at an approximate depth of 32 to 39 cmbs, along the south side of the drainage in Area 2. Six additional
shovel tests were excavated at 10-m intervals in cardinal directions around the fmd,but all were negative.
Due to the extremely low artifact density and lack of intact cultural deposits, 31BN958 appears to have
little research potential and is recommended ineligible for the NRHP.
30

6. SUMMARY AND RECOMMENDATIONS
TRC has completed an intensive archaeological survey of the proposed additions to the Asheville
Regional Airport in Buncombe County,North Carolina.The four project areas include a ca.0.9 acre south
of the existing runway (Area 1), areas extending 50 feet on either side of two small streams east of Old
Fanning Bridge Road(NC 280) (Areas 2 and 3),and a ca. 6.0-acre area southwest of NC 280.
The background research identified a single previously recorded site (31HN74) that was mapped within
or immediately adjacent to the project area, but this site was not encountered by the survey. The field
survey encountered a single archaeological resource, isolated find 31BN958 which consists of a single
non-diagnostic prehistoric chert flake found along the east bank of an unnamed intermittent drainage
(Area 2)north of Old Fanning Bridge Road(NC 280).Despite supplementary testing at 10 in intervals,no
additional cultural artifacts were found. Site 31BN958 appears to lack research potential, and is
recommended ineligible for the NRBP. Consequently, no further archaeological investigations are
recommended for the proposed airport improvements.
31

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i

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42

50101 Governor's Drive
Suite 250
�3 Chapel Hill, NC 27517
919.530.8446 PHONIF
919.530.8525 FAX
www.1'E:Csa{utions.corn � Og�2�fl l O
August 23,2010 D `;�:� , f,,:zt=.,,� :
Mr.Lew Bleiweis
Asheville Airport Authority
61 Terminal Drive,Suite 1
Fletcher,North Carolina 28732
Re: Management Summary for Intensive Archaeological Survey for Proposed Additions to
Asheville Regional Airport,Buncombe County,North Carolina.
Dear Mr.Bleiweis:
TRC has completed a Phase I archaeological survey of four separate areas for proposed additions to the
Asheville Regional Airport, Buncombe County, North Carolina. The survey areas were identified by
C1earWater Environmental personnel as requiring survey for COE permitting requirements, and are
located at the south end of the airport.The areas include: a ca. 0.9 acre south of the existing runway(Area
1), areas extending 50 feet on either side of two small streams east of NC 280 (Areas 2 and 3), and a ca.
6.0-acre area southwest of Old Fanning Bridge Road (NC 280) (Area 4) (Figure 1). The four areas total
approximately 10 acres.
This study was conducted to produce information on the presence and location of significant
archaeological sites on the tract,in order to comply with Section 106 of the National Historic Preservation
Act and so that the information could be considered for planning purposes. The survey meets the
standards established by the North Carolina State Historic Preservation Office(SHPO)and Office of State
Archaeology (OSA). The field survey took place on August 11-13 and 16, 2010 and was directed by
Michael Nelson;the background study was conducted on August 4,2010.
PROJECT SETTING
The project areas are located at the Asheville Regional Airport property, and are situated on both sides of
Old Fanning Bridge Road. Area 1 is located in an open field approximately 920 ft west of the south end
of the existing airport runway and covers approximately 0.9 acres. Areas 2 and 3 extend for 50 feet on
either side of two small streams on the west side of the Old Fanning Bridge Road. The smaller of those
areas(Area 2)is south of an existing construction staging area and access gate,and covers approximately
400 ft x 100 ft. The larger (Area 3)measures approximately 900 ft x 100 ft, and is north of the staging
area/access gate. The largest of the four areas (Area 4) is situated across a large open field (ca. 6 acres)
the southwest of Old Fanning Bridge Road.
All of the surveyed areas area relatively flat, with the exception of a small knoll in the northwest corner
of Area 4(the ca. 6.0 acre tract).Most of the areas are in open grass fields, and are moderately to heavily
disturbed from past agricultural and grading activities (Figure 2). The area along the smaller stream is
moderately wooded with mixed hardwoods and pine with a light understory(Figure 3).

BACKGROUND RESEARCH
The background research included examination of the following materials for an area extending one mile
in radius around the project area:
• Archaeological site files and reports at the North Carolina Office of State Archaeology(OSA);
® North Carolina cemetery survey maps at the North Carolina State Archives,Henderson County GIS
cemetery data,and any available published Henderson County cemetery records;and
m Historical maps and other materials at the UNC-Chapel Hill North Carolina Collection,the North Carolina
State Archives,and similar repositories.
Archaeological Sites
The archaeological site files and records at the SHPO contain information on four previously recorded
archaeological sites(31HN73, 31HN74,31HN96,and 31HN113)within a mile radius of the project areas
(Table 1).All four sites are located south of Old Fanning Bridge Road on or adjacent to the French Broad
River floodplain. One site (31HN74) is located either in or immediately adjacent to the large ca 6.0-acre
field (Area 4) of the project area. That site was identified as a low density surface scatter of prehistoric
lithic and ceramic artifacts atop a small ridge extending into the floodplain, and was recorded in 1978
during a survey of the South Buncombe Interceptor Sewer Project (Ayers 1978). While the mapped
location of this site corresponds with the approximate location of the north corner of Area 4, the
topography described 32 years ago does not correspond with the current field conditions.No evidence of
the site was found either in surface or subsurface contexts during TRC's survey of the area. The site may
be located in the field immediately adjacent to the north end of the current project area; alternatively, the
area may have been heavily disturbed and altered so that no evidence of the site remains.
Table 1.Previously recorded archaeological sites within one mile of project area.
Site No. Description NRHP Eligibility Reference
31HN73 Middle/Late Archaic lithic scatter camp Ineligible Ayers 1978
31HN74 Middle Archaic to Early Woodland camp Ineligible Ayers 1978
31HN96 Late Archaic lithic scatter Ineligible Padgett 1983
31HN113 Non-diagnostic prehistoric lithic/ceramic scatter Ineligible Whyte and Kimball 1993
The three remaining sites include a Middle to Late Archaic period lithic scatter(31HN73), a Late Archaic
lithic scatter (31HN96) and a non-diagnostic prehistoric artifact scatter (31HN113). All four sites were
described as lacking intact subsurface cultural deposits, and were previously recommended ineligible for
the NRHP(Ayers 1978;Padgett 1983;Whyte and Kimball 1993).
In addition to the site file check,historic maps were examined to evaluate past land use and determine if
there was any potential for historic sites in the vicinity. As the project area location is at the border of
both Henderson and Buncombe Counties, maps of both counties were examined. The Asheville Airport
was part of Henderson County prior to being annexed by the city of Asheville. The 1907 Henderson
County Soil map (Hearn and MacNider 1908) depicts three major roads in the project vicinity including
one that is now Old Fanning Bridge Road and three structures that appear to be northwest of the current
project area. Review of the 1938 Henderson County map prepared by the North Carolina State Highway
and Public Works Commission(NCSHPWC 1938) shows the area was crossed by a number of roads, and
was the location of numerous structures and at least two mines in the general vicinity of the project area.
However, it is difficult to discern if any of those structures were within the boundaries of the current
survey locations. Review of the 1938 Buncombe County road map (NCSHPWC 1938) shows little detail
at the airport location with the exception of Fanning Bridge Road and a few unnamed roads.No evidence
of historic period occupation was discovered during the archaeological survey.

Cemeteries
Examination of the Henderson County GIS website (littp://gisweb.hendersoncount n�c.org[
GoMaps/map/Index.cfm) and a compilation of data on Henderson County cemeteries (Henderson County
Genealogical and Historical Society [HCGHS] 1995) revealed no known cemeteries within a mile of the
project area. The Buncombe County GIS website (http:#gis.buncombecounty.or uncomapn records a
single cemetery within a one mile radius of the project area;the Boiling Springs Baptist Church Cemetery is
located approximately 0.7 mile northeast of the project area,south of Fanning Bridge Road(CR 1358)where
it crosses Interstate 26. No evidence of any unrecorded cemeteries was observed by TRC personnel in the
survey areas.
ARCHAEOLOGICAL SURVEY
The intensive survey included a surface pedestrian survey and subsurface testing at 20 m intervals across
all four areas.A total of 139 shovel tests were excavated, including 28 shovel tests in Area 1, 37 in areas
2 and 3, and 74 shovel in Area 4. The soils in each area were generally eroded and disturbed, with little
consistency noted. As the project areas had not been marked in the field, in some cases the survey
coverage extended outside the apparent area boundaries in order to ensure that the coverage was
complete; in addition,the Area 4 survey was inadvertently extended across the large wetland area to the
bank overlooking the French Broad River.
The survey recovered only a single artifact; that was a non-diagnostic prehistoric chert flake in a shovel
test on the south side of the drainage in Area 2, which has been designated 31DN958. Six shovel tests
excavated at 10 in intervals in cardinal directions from the initial positive shovel test were excavated; all
were negative.This isolated find will be recommended ineligible for the NRHP, and no fiuther work will
be required.
SUIVEAARY
The background research and archaeological survey identified no significant archaeological sites within
the designated survey areas. Consequently, no additional archaeological investigations should be needed
prior to construction of the proposed additions to the Asheville Regional Airport.
A detailed report on the survey is in preparation,and will be provided soon.Please do not hesitate to
contact me at(828)230-4812/[phone],or via email at tben s�Rtresolutions.com,in the
interim if you have any questions or comments.
Sincerely,
Tasha Benyshek,M.A.,R.P.A.
Senior Archaeologist,Asheville

REFERENCES CITED
Ayers,Harvard G.
1978 Archaeological Reconnaissance Survey of the Hominy valley Interceptor Sewer Project and the South
Buncombe Interceptor Sewer Project,Buncombe and Henderson Counties,North Carolina.Ms.on file,
Department of Anthropology,Appalachian State University.
Buncombe County GIS Services
2010 Buncombe County website http://aisweb.hendersoncountyne.org/GoMaps/niap/lndex.cfin,accessed August
18,2010.
Hearn,W.Edward,and George M.MacNider
1908 Soil Survey of Henderson County,North Carolina.U.S.Department of Agriculture,Washington,D.C.
Henderson County Genealogical and Historical Society
1995 Henderson County,North Carolina Cemeteries.The Reprint Company,Spartanburg,SC.
Henderson County GIS Services
2010 Henderson County GoMaps,website http://www.hendersoncountyne.org/gis/index.htnfl accessed August
18,2010.
North Carolina State Highway and Public Works Commission
1938 Buncombe County,North Carolina.North Carolina Department ofNatural Resources and Community
Development,Raleigh.
1938 Henderson County,North Carolina.North Carolina Department of Natural Resources and Community
Development,Raleigh.
Padgett,Thomas J.
1983 Archaeological Study,NC 280 from Mills River to I-26,Henderson County,R-401.Technical report
submitted to the Archaeology Branch,North Carolina Department of Archives and History.
Whyte,Thomas R.and Larry R.Kimball
1993 An Archaeological Survey ofthe Westfeldt River Park Henderson County,North Carolina.Technical report
submitted to the Henderson County Parks and Recreation Department,Hendersonville,NC.

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Figure 1. Location of survey areas and isolated Find 3 1BN958,Asheville Regional Airport, Buncombe County,North Carolina.

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North Carolina Department of Cultural Resources
State Historic Preservation Office
Peter B.Sandbeck,Administrator
Beverly Eaves Perdue,Governor Office of Archives and History
Linda A.Carlisle,secretary Division of Historical Resources
Jeffrey i.Crow,Deputy secretary David Brook,Director
June 11, 2010
Lew Bleisweis CE'- Project (Ok6
Asheville Regional Airport Authority
61 Terminal Drive Date Recipvec"� 0(011eglo
Suite 1
Fletcher, NC 28732
Re: Taxiway, Cargo Apron,Warehouse Building,Truck Loading Docks and Infrastructure,
Asheville Regional Airport,Buncombe County,ER 10-0930
Dear Mr. Bleisweis:
We have received the Public Notice for the above project from the US Army Corps of Engineers for review.
There are no known recorded archaeological sites within the project boundaries. The majority of the project
area appears to be in previously disturbed portions of the existing airport facility. Based on the topographic
and hydrological situation, there is a high probability for the presence of prehistoric or.historic archaeological
sites located in the undisturbed portion of the project area, such as Section F in the Project Development Plan.
We recommend that a comprehensive survey of the undisturbed portions of the project area be conducted by
an experienced archaeologist to identify and evaluate the significance of archaeological remains that may be
damaged or destroyed by the proposed project. The survey should take into account the potential for deeply
buried deposits adjacent to the French Broad River. Potential effects on unknown resources must be assessed
prior to the initiation of construction activities.
Two copies of the resulting archaeological survey report,as well as one copy of the appropriate site forms,
should be forwarded to us for review and comment as soon as they are available and.well in advance of any
construction activities.
A list of archaeological consultants who have conducted or expressed an interest in contract work in North
Carolina is available atwww.arch.dcr.st-ate.nc.us/consults.htin. The archaeologists listed, or any other
experienced archaeologist,may be contacted to conduct the recommended survey.
We have determined that the project as proposed will not have an effect on any historic structures.
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,
please contact Renee Gledhill-Earley, environmental review coordinator, at 919/807-6579. In all future
communication concerning this project,please cite the above referenced tracking number.
Sincerely,
Peter Sandbeck
u
cc: ACOE
Clement Riddle, Clearwater Environmental Consultants

50101 Governor's Drive
Suite 250
Chapel Hill, NC 27517
��4K 919.530.3446 PHONE
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F 3 ar .. �, Wv�v"TRCsolutions.corn
September 30,2008
Mr.Kevin E.Howell, C.M.
Development Manager
Asheville Regional Airport Authority
61 Terminal Drive, Suite 1
Fletcher,North Carolina 28732
Re: Management Summary,Archaeological Phase I Survey of 2.8 Acres for Proposed Improvements
to Asheville Regional Airport,Fletcher,Buncombe County,North Carolina
Dear Mr.Howell,
TRC has completed a Phase I archaeological survey for the proposed improvements to the northern end of
the Asheville Regional Airport property in Buncombe County.The archaeological survey and related
background research were conducted on September 24 and 26.The project Area of Potential Effects
(APE)as defined by the USACE is linear,measures approximately 1,200 feet in length and extends a
maximum of 50 feet on each side of a perennial stream;the total project area is 2.8 acres(Figures 1 and 2)
(Lori Beckwith,personal communication September 2008).The proposed work will consist of the
connection of two existing drainage culverts at the north and south ends of the project area;subsequently,
the area is to be filled to bring it up to the level of the surrounding artificial landscape.This streambed
handles rainwater runoff from the airport runways and parking lots.Additionally,there are other perennial
and intermittent streams and wetlands within the project area all of which feed the main stream that runs
the length of the project area.The land surrounding the APE has already been significantly modified
(Figure 3), and the 16-acre area within and immediately surrounding the APE was logged some time after
June of 2006.
BACKGROUND RESEARCH
Background research consisted examination of SHPO archaeological site and report files.No previously
recorded archaeological sites are located within the APE, as indicated in a 2007 SHPO comment letter.
Four archaeological sites have been identified within one mile of the APE.These include 31BN165,along
with three sites recorded by local collector V. Gary Henry that have never received permanent state site
numbers(and are labeled sites 366,367, and 379). Site 31BN165 is a Middle and Late Archaic site with a
Pisgah phase component located at the confluence of Avery Creek and the French Broad River.No
information is on file regarding the other sites is on file.
FIELD RESULTS
The soils were found to be very disturbed over the length of the project area, and surface inspection was
undertaken in areas of obvious disturbance and with greater than 50%surface exposure.Additionally,
shovel test pits(STPs)were excavated at 20 meter intervals in areas thought to potentially contain intact

soils,and at 40 meter intervals in areas with indications of significant disturbance at the surface(Figure
4). Shovel testing was not performed in the wetland areas of the APE or in areas where subsoil was
exposed at the surface.A total of 22 STPs were excavated.
The shovel tests contained inconsistent soil profiles and extremely varied stratigraphy,indicating
significant disturbance.The few STPs with possible intact soils consisted of dark yellowish brown(1 OYR
4/4)sandy silt above dark grayish brown(IOYR 4/2) clay subsoil(Figure 5). Other STPs contained a mix
of these soils with large, displaced inclusions of the dark grayish brown clay at varying depths within the
soil column.Many of the shovel tests had construction fill on top that was washed down from the
surrounding slopes(Figure 6). Construction fill completely covered the easternmost and westernmost
edges of the APE. Other disturbed areas contained schist rock mixed with brown(7.5YR 4/4)sand
beneath yellow brown(1 OYR 5/6) sandy silt with gravels. Some of the STPs contained modern trash and
most contained pieces of wood from the past logging.At the north and south ends of the APE the
disturbed soils contained numerous charcoal chunks from the burning of timber associated with logging.
Additionally,one STP contained coarse sand and modern bottle glass that may have been deposited by
the runoff from a past rain event.The subsoil ranged in depth from exposure at the surface to 40 cmbs.No
archaeological sites or isolated finds were discovered.
SUMMARY AND RECOMMENDATIONS
The archaeological survey of approximately 2.8 acres for the proposed improvements at Asheville
Regional Airport identified no artifacts or other indications of an archaeological site,and documented
disturbed soils throughout most of the project area.Additionally,the presence of deeply buried intact
cultural deposits within the APE is highly unlikely due to the level of disturbance and the shallow nature
of the clayey subsoil.It is recommended that no further archaeological work be required in connection
with this project.
The draft report detailing this investigation is in progress.If you have any questions about the
investigation,please feel free to contact me at(828)230-4812,or [e-mail].
Sincerely,
Tasha Benyshek M.A.,RPA
Senior Archaeologist/Asheville Office Manager

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