20001195 Ver 15_Other Agency Comments_20150914

Burdette, Jennifer a
From: Johnson, Alan
Sent: Monday, September 14, 2015 11:48 AM
To: Burdette, Jennifer a
Subject: FW: 20150845 Charlotte Douglas Airport Air Traffic Control Tower, Mecklenburg Co.
Attachments: 201400838 Air Traffic Control Tower_NCWRC.pdf
In case you didn't receive. Not copied to LF
From: Bryant, Shari L.
Sent: Wednesday, September 09, 2015 9:28 AM
To: Johnson, Alan
Subject: 20150845 Charlotte Douglas Airport Air Traffic Control Tower, Mecklenburg Co.
Hi Alan,
I provided comments on the Corps' public notice on this project. I copied you, but since I recently received a copy of the
401 application for the project, I thought I would resend the comments I sent to the Corps on this project.
Thanks
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North Carolina Wildlife Resources Commission IQ
Gordon Myers, Executive Director
MEMORANDUM
TO: Crystal Amschler, Asheville Regulatory Field Office
U.S. Army Corps of Engineers
FROM: Shari L. Bryant, Western Piedmont Coordinator
Habitat Conservation
DATE: 18 December 2014
SUBJECT: Public Notice for the Federal Aviation Administration for Construction of a New Airport
Traffic Control Tower, Charlotte Douglas International Airport, Mecklenburg County,
North Carolina. Corps Action ID #: SAW- 2014 -00838
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document. Our comments are provided in accordance with provisions of the Clean Water Act of
1977 (as amended), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661- 667e),
and North Carolina General Statutes (G. S. 113 -131 et seq.).
The applicant proposes to impact 709 linear feet of intermittent stream and 0.007 acres of
wetlands for construction of an air traffic control tower, terminal radar approach control building, parking
area, access driveway, two stormwater ponds, and sewer lines. The purpose of the project is to replace
the existing air traffic control tower that no longer provides adequate coverage of air traffic control needs.
The applicant requested compensatory mitigation be waived because the intermittent streams proposed for
impact are from stormwater runoff, drain a small watershed area, and have low habitat. The proposed
project will impact an unnamed tributary to Coffey Creek in the Catawba River Basin.
We hesitate to concur with stream piping and filling wetlands. Stream piping eliminates aquatic
and terrestrial wildlife habitat, and reduces infiltration of stormwater and dissipation of stream energy.
Wetlands provide wildlife habitat, flood control, and water quality protection. Also, we are concerned
about the impact of development on aquatic and terrestrial wildlife resources. Changes in land use and
increases in impervious surfaces may exacerbate channel degradation and sediment impacts to stream
ecosystems due to increased stormwater runoff and elevated flooding. In addition, pollutants (e.g.,
sediment, heavy metals, pesticides, and fertilizers) washed from roads and developed landscapes can
adversely affect and extirpate species downstream.
Should the permit be issued, we offer the following comments and recommendations to minimize
impacts to aquatic and terrestrial wildlife resources.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

Page 2
18 December 2014
Air Traffic Control Tower
Corps Action ID No.: SAW - 2014 -00838
For remaining streams and wetlands on the site, maintain a 100 -foot undisturbed, native, forested
buffer along perennial streams, and a 50 -foot buffer along intermittent streams and wetlands.
Maintaining undisturbed, forested buffers along these areas will minimize impacts to aquatic and
terrestrial wildlife resources, water quality, and aquatic habitat both within and downstream of the
project area. In addition, wide riparian buffers are helpful in maintaining stability of stream banks
and for treatment of pollutants associated with stormwater runoff.
2. Stormwater management structures should be designed to mimic the hydrograph consistent with an
impervious coverage of less than 10 %. Structures should be located outside of riparian buffers and
wetland areas. For any stormwater detention ponds, trees and shrubs should be planted around the
pond, excluding the dam. This would provide habitat benefits that offset those functions lost by
development, partially restore aquatic habitats, reduce exposure of the water surface to sunlight to
minimize thermal pollution, and provide essential summer and winter habitats.
3. Use landscaping that consists of non- invasive native species and Low Impact Development (LID)
technology. Using native species instead of ornamentals should provide benefits by reducing the
need for water, fertilizers, and pesticides. Using LID technology in landscaping will not only help
maintain the predevelopment hydrologic regime, but also enhance the aesthetic and habitat value of
the site.
4. Sediment and erosion control measures should be installed prior to any land clearing or construction.
These measures should be routinely inspected and properly maintained. Excessive silt and sediment
loads can have numerous detrimental effects on aquatic resources including destruction of spawning
habitat, suffocation of eggs, and clogging of gills of aquatic species.
5. We defer to the U.S. Army Corps of Engineers and N.C. Division of Water Resources regarding
appropriate mitigation for this project.
Thank you for the opportunity to comment on this project. If we can provide further assistance,
please contact our office at (336) 449 -7625 or shari.brvant(&ncwildlife.or�z.
ec: Alan Johnson, NCDWR