20230686 Ver 1_More Info Received_20230928

Baker, Caroline D
From: Eric Romaniszyn <[e-mail]>
Sent: Thursday, September 28, 2023 9:53 AM
To: Fuemmeler, Amanda J CIV USARMY CESAW (USA)
Cc: Jones, M Scott (Scott) CIV USARMY CESAW (USA); Homewood, Sue; Moore, Andrew
W; Leslie, Andrea J; [e-mail]; Michael A. Reisman; Jared Merrill; John
Coon; Anna Henderson; Rita Yanz; Moose, James; Bird, Travis_P.E.; Clement Riddle
Subject: [External] Corps Comments in Response to Asheville Airport PN/Application AID:
2023-00994 - Use of Rental Car Drive
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Dear Ms. Jones
Regarding the Greater Asheville Regional Airport Authority's Individual Permit application for the Asheville Airport
Parking Extension Project, ClearWater, an EnviroScience Company (ClearWater) provides the following response to the
Corps' comments received via email on July 10, 2023 (included below). These responses pertain to comment #5 and the
potential use of Rental Car Drive to access the new parking area. They are in addition to the original responses emailed
to the Corps and NC DEQ on August 11, 2023.
Comment #5: Site 6Alternative: Please provide further clarification as to why moving the primary entrance to the lot
further south is not practicable. It appears that there is room to have two access points without much impact/loss to the
rental car facility. It is also not clear why access can't be changed/allowed to make the primary route of shuttles along
Rental Car Drive versus Terminal Drive or why one access would be sufficient with proper access control points.
Response: Rental Car Drive is not a viable option for accessing the new parking area. The drive is in a private lease
agreement held with the rental car companies. The agreement includes the road and the service center within the
security fence. The rental car facility on Rental Car road acts as a service center where rental cars are cleaned, refueled,
maintained (e.g., oil change, tire maintenance), and repaired. There are four separate operations within this area, each
managed by a different rental car company, and each includes its own gas fueling station and above -ground storage
tanks. The Rental Car Facility is not open to the public and the public does not have direct access to those facilities.
On any given day, there are nearly 3,000 rental vehicles being processed at the Asheville airport. The running 12-month
average is 2,073 vehicles in rental per day (according to rental company data), up to 500 in the service area, and up to
235 in the parking garage for customer pick-up. The volume of rental car usage at the airport will increase in the near
future as the airport is also adding 175 more spaces in the garage. As a result, the service area is highly used and thus,
the north entrance gate off Terminal Road is kept open from 8:00 AM to 5:00 PM Monday through Friday to minimize its
use and reduce maintenance needs and risk of equipment failure. This gate closes after normal business hours requiring
controlled access to enter the leasehold at all other times. The south gate is closed at all times for security and safety
reasons.
Rental Car Drive is also used daily by tractor trailers transporting rental cars; delivery trucks for fuel, tires, trash, and
other deliveries; and employees. The tractor trailers are too large to maneuver in and out of the service area and must
park on Rental Car Drive.

Rental Car Drive is not suitable for direct access to Terminal Drive from the new parking lot for the following reasons:
• It would require Rental Car drive be widened to add a new lane, sidewalk, and separation median to accommodate
shared use by passenger vehicles, delivery trucks, and tractor trailers, as well as a sidewalk connecting the parking
area with the terminal. The drive could not be widened to the west due to the location of the airfield. Expanding to
the east would reduce the riparian buffer and would likely require additional stream impacts. The pedestrian access
would also have to cross traffic patterns six times from the Terminal to the parking area.
• Expanding the road would also require the service area be expanded to maintain the 500 available parking spaces,
to accommodate delivery truck access and movement, and to add security gates. This expansion would very likely
result in stream impacts as those proposed in this project.
• Due to the lease agreement, the rental car companies have liability for any issues that would arise from public use of
Rental Car Drive and areas near the service center.
• If the public was given access to Rental Car Drive, the airport would have to constantly patrol, enforce and tow
illegally parked cars, as they frequently do at other areas on the airport property. The added patrols and expected
public parking issues would further hinder normal rental car operations, deliveries, and other related activities.
• The five security gates that would need added to protect the service center would be operated independently, and
the frequency that they would be used would result in significant operational delays, reduced efficiency as well
increased security and higher maintenance costs.
• The service center includes five above -ground gasoline storage tanks along with others needed for oil (new and
used) and car wash stations. The cost, logistics, and space needed to move this infrastructure for widening or to a
different location would be prohibitive. There is also an inherent safety risk in permitting the general public access to
the existing fuel storage tanks which are positioned along the edge of Rental Car Road in order to accommodate
bulk fuel transfer operations.
The applicant believes the information submitted in this email addresses the comment provided by the Corps. Should
you have any further questions or comments, please contact me anytime at [e-mail] or 828-
698-9800. We are also available to meet if you want to discuss this further. Thank you.
Sincerely,
Eric
Eric Romaniszyn
Senior Scientist
EnviroSciencelnc.com
"Excellence in Any Environment"
C. 865-406-1281
From: Eric Romaniszyn
Sent: Friday, August 11, 2023 1:26 PM
To: Fuemmeler, Amanda J CIV USARMY CESAW (USA) [e-mail]
Cc: Jones, M Scott (Scott) CIV USARMY CESAW (USA) [e-mail]; 'Homewood, Sue'
sue. [e-mail]; Moore, Andrew W [e-mail]; Leslie, Andrea J
[e-mail]; [e-mail]; A. A. E. Michael A. Reisman ([e-mail])
[e-mail]; Moose, James [e-mail]; Bird, Travis_P.E. [e-mail]; Clement Riddle
[e-mail]
Subject: RE: Corps Comments in Response to Asheville Airport PN/Application AID: 2023-00994
Hi Amanda,

Please find attached our comment/response package for the AVL Airport Individual Permit application. Please contact
me anytime if you have any questions or further comments.
Thank you.
Eric
Eric Romaniszyn
Senior Scientist
EnviroSciencelnc.com
"Excellence in Any Environment"
C. 865-406-1281
From: Fuemmeler, Amanda J CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, July 10, 2023 1:25 PM
To: Eric Romaniszyn<[e-mail]>; Clement Riddle <[e-mail]>
Cc: Jones, M Scott (Scott) CIV USARMY CESAW (USA) <[e-mail]>; 'Homewood, Sue'
<[e-mail]>; Moore, Andrew W <[e-mail]>
Subject: Corps Comments in Response to Asheville Airport PN/Application AID: 2023-00994
[EXTERNAL EMAIL - Please use caution]
Thanks for the call today to discuss the comments received in response to the Public Notice for this project. Comments
received were previously sent via email.
Below is the Corps comments/concerns which are similar to those expressed by the N.C. Division of Water Resources as
they relate to the alternatives analysis and avoidance/minimization measures. A response to our comments should be
received by August 10, 2023 and please copy us on your response to NCDWR's as well. Feel free to contact me with any
questions.
1. Please provide a summary of parking facilities to date that the Airport utilizes (both on and off Airport Property)
to include when those facilities were constructed, # of spaces provided, what/if any impacts to waters of the US
were incurred and anticipated plans for changes to these areas.
2. Your Alternatives Analysis should include off -site locations to include sites currently adjacent/near the Airport
and not necessarily owned by the Airport at the time of this analysis.
3. Site 1 Alternatives Discussion: Please clarify if this site could be used for future parking expansion and a
discussion on if this site would meet the project's purpose/need for parking regardless of the commercial/multi-
use designation. Your response should note the extent of wetland/water impacts if any for development of this
site. This discussion should also address/include the potential alternative of relocating the existing Marathon
Gas Station/Dunkin Donuts commercial facility to Site 1. This facility was sited on property shown as potential
parking alternatives in the 2013 Airport Master Plan and is on property still owned by the Airport. The
construction of this commercial development eliminates the opportunity to align the primary entrance off
Terminal Drive in a way that could have avoided/minimized impacts to approximately 745 linear feet of stream
channel.
4. Site 5 Alternative — Please clarify why expansion of this parking area/conversion into a garage would not be
considered practicable and why it's proximity to adjacent garages would preclude this alternative from being
further considered.
5. Site 6 Alternative: Please provide further clarification as to why moving the primary entrance to the lot further
south is not practicable. It appears that there is room to have two access points without much impact/loss to
the rental car facility. It is also not clear why access can't be changed/allowed to make the primary route of
shuttles along Rental Car Drive versus Terminal Drive or why one access would be sufficient with proper access
control points.

Amanda Jones
Project Manager
USACE-Asheville Regulatory Field Office
828-271-7980 ext. 4225
THIS MESSAGE IS INTENDED ONLY FOR THE PERSONALAND CONFIDENTIAL USE OF THE INDIVIDUAL OR ENTITY TO
WHOM IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL, AND EXEMPT FROM
DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the intended recipient, or the employee or
agent responsible for delivering the message to the intended recipient, you are hereby notified that you have received
this message in error and that any review, dissemination, distribution, or copying of this communication is strictly
prohibited.
THIS MESSAGE IS INTENDED ONLY FOR THE PERSONALAND CONFIDENTIAL USE OF THE INDIVIDUAL OR ENTITY TO
WHOM IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL, AND EXEMPT FROM
DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the intended recipient, or the employee or
agent responsible for delivering the message to the intended recipient, you are hereby notified that you have received
this message in error and that any review, dissemination, distribution, or copying of this communication is strictly
prohibited.