20230686 Ver 1_20230686 Ver 1 more info requested response_20230720

CLear\A/aLer
An Enviro offence Company
ClearWater Environmental Consultants, Inc.
www.cwenv.com
July 20, 2023
Ms. Stephanie Goss, Supervisor
NC Division of Water Resources
401 & Buffer Permitting Branch
1611 Mail Service Center
Raleigh, North Carolina, 27699-1611
RE: DEQ's Request for More Information
Asheville Airport Parking Expansion Project Individual Permit Application
Buncombe County, North Carolina
Corps Action ID: SAW-2023-00994; DWR# 20230686
Dear Ms. Goss,
Regarding Greater Asheville Regional Airport Authority's Individual Permit application for the Asheville
Airport Parking Extension Project, ClearWater, an EnviroScience Company (ClearWater) provides the
following responses to DWR's request for more information letter dated June 20, 2023.
DWR #1. That application notes that project alternative D, Site 6 was not considered further because
it would result in the loss of parking spaces as the adjacent rental car lot, however it appears that.
a. there may be available space between the existing parking lot and Stream 1 for access
construction which would not impact, or minimally impact the rental car parking area while
minimizing the impact to Stream 1.
b. Access can be provided via Rental Car Drive.
Please further expand on the justification for elimination of these options. The Division recommends
that you provide visual illustration of these alternative with your response.
Response:
The entrances to the rental car parking lot from Terminal Drive and Rental Car Drive are gated
and locked for security reasons, which prevents Rental Car Drive from being used as an pass -
through for shuttle buses and visitors.
At least one of the parking lot access roads must have access to Terminal Drive. This enables
shuttle buses to stay on the airport property and help make round trips within a short time
frame. Highway 280 is also a busy road so it gives vehicles turning north access to the traffic
signal.
AVCON had considered locating the north access road through the grassy area adjacent to
Terminal Drive between the rental car lot and Stream 1. This was not selected because it would
require an additional intersection along Terminal Drive and add to line of sight and traffic safety
issues. The grassy strip also drops to a slightly lower elevation, which gives some buffer from
high stormwater discharge events, so adding an access road on that side would require more
fill to align elevations with the access road to cross the stream, and limit that buffering capacity.

DEQ Request for More Information
DWR# 20230686
DWR #2. That application notes that project alternative Site 5 was not considered further due to the
construction of a garage near sites 3 and 4. It's not clear why proximity to other parking garages
precludes this alternative, nor why this alternative would impact 740 feet of streams. It appears there
is adequate room to construct a parking garage in this location without impacting any streams.
Response:
A parking garage is anticipated for Site 5 in the future due to its proximity to the terminal (see
Appendix D, Airport Layout figure). Due to the extensive time and resources needed to
construct a garage, there must be parking available elsewhere to offset the temporary loss of
parking that is currently available at Site 5. Therefore, a garage will not be practical until
enough offset parking is available; the proposed project will help meet that offset need in the
future.
It is expected that when the garage is built, it will need to be large enough to accommodate
several thousand vehicles. It is possible the area required to build the structure would be larger
than the space currently available at Site 5 and therefore, it would likely extend into the stream
and result in some impacts to jurisdictional waters.
DWR #3. The proposed parking lot was designed to be on -grade with Highway 280. However, the
application states NCDOT would not allow a new entrance on Highway 280. Raising the parking lot
grade to meet the Highway 280 elevation results in additional fill required to cross S-land S-2. Please
explain why the design elevation of the parking lot cannot be lowered to minimize impacts to S-land
S-2?
Response:
The lot has been lowered below the HWY 280 elevation. Fill volumes have been reduced to
the minimum necessary to construct the lot at the necessary slope for proper drainage and
user safety, and to allow easy connections between the lot with the two entrance drives.
DWR #4. Page 6 of the application states that design fill slope grades are 3:1. Steeper slopes would
further minimize the jurisdictional impacts and are often acceptable for public and private roadways
and development. Please provide further justification for the proposed 3:1fill slopes.
Response: The airport must have access to maintain vegetation and a 3:1 slope is preferred
over the steeper 2:1 slope for personnel safety.
DWR #5. Please provide either.
a. Documentation that a local government, delegated by NCDEQ will be reviewing the
proposed stormwater plan; or
b. A complete stormwater management plan for detailed review.
Response: AVCON submitted the post -construction stormwater permit application to DEQ on
6/21/2023 and it is in review. Documentation of approval can be forwarded upon request.
DWR #6. If the USACE requests a response to any comments received as a result of the Public Notice,
please provide the Division with a copy of your response to the USACE to ensure we have all relevant
information to complete our review in accordance with 15A NCAC 02H .0506(b).
Response: Any responses to comments received from the public notice will be forwarded to
Sue Homewood and Andrew Moore at DEQ.

DEQ Request for More Information
DWR# 20230686
The applicant believes the information submitted in this letter addresses the comments provided by
DWR. Should you have any further questions or comments, please contact me anytime at
[e-mail] or 828-698-9800. Thank you.
Sincerely,
Eric Romaniszyn
Senior Scientist
Copy issued:
Amanda Jones - US Army Corps of Engineers
Sue Homewood - NC Department of Environmental Quality
Andrew Moore - NC Department of Environmental Quality
Andrea Leslie - NC Wildlife Resources Commission
Lew Bleiweis — President/Chief Executive Officer, Greater Asheville Regional Airport Authority
Michael Reisman — Chief Operating Officer, Greater Asheville Regional Airport Authority
James Moose — AVCON, Inc.
Travis Bird - AVCON, Inc.
Clement Riddle - ClearWater, an EnviroScience Company