20231194 Ver 1_USACE More Info Requested_20240224

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
February 24, 2024
Regulatory Division
Action ID: SAW-2022-01559
Mr. Michael Landguth
Raleigh -Durham Airport Authority
1000 Trade Drive, Post Office Box 80001
Raleigh, North Carolina 27623
Dear Mr. Landguth:
Please reference your Individual Permit application for Department of the Army
(DA) authorization to permanently discharge dredged or fill material into a total of 2.45
acre (ac) (7,293 linear feet [If]) of potentially jurisdictional stream channel, 1.38 ac of
potentially jurisdictional wetlands, and 2.17 ac of potentially jurisdictional open waters
associated with the Runway 5L/23R Replacement Project in Wake County, North
Carolina.
The U.S. Army Corps of Engineers, Wilmington District (Corps) advertised your
proposal by public notice dated January 2, 2024. Comments in response to the notice
were received from agencies including the United States Environmental Protection
Agency (USEPA), Catawba Indian Nation Tribal Historic Preservation Office (THPO),
the United States Fish and Wildlife Service (USFWS), and the North Carolina
Department of Natural and Cultural Resources (NCDNCR). The comments received are
enclosed for your information and to provide you with the opportunity to address any
stated concerns.
The USEPA, in an email dated January 9, 2024, stated that they currently have no
comments or concerns with the project as presented in the Public Notice. The USFWS,
in a letter dated January 18, 2024, stated that requirements under Section 7(a)(2) of the
Endangered Species Act have been satisfied for all federally listed species during
consultation with the Federal Aviation Administration (FAA). Additionally, USFWS
stated, that the FAA initiated formal conferencing for the possible effects to the
tricolored bat (proposed species) on December 19, 2023. The Catawba Indian Nation
THPO, in a letter dated January 25, 2024, stated that they have no immediate concerns
with regard to traditional cultural properties, sacred sites or Native American
archaeological sites within the boundaries of the proposed project areas. Additionally,
Catawba Indian Nation THPO stated that they are to be notified if Native American
Artifacts and/or human remains are located during the ground disturbance phase of this
project. The NCDNCR, in a letter dated January 25, 2024, stated that based on their

consultation with the FAA, they have concurred that no historic properties will be
affected. Additionally, NCDNCR stated that they reviewed the archaeological survey
report and concurred that no archaeological historic properties will be affected.
NCDNCR also noted that there are three (3) cemeteries onsite and that cemeteries and
unmarked human skeletal remains are protected under NC General Statutes.
Further, on February 6, 1990, the DA and the EPA signed a memorandum of
agreement (MOA) establishing procedures to determine the type and level of mitigation
necessary to comply with Clean Water Act (CWA) Section 404(b)(1) Guidelines. This
MOA provides for first, avoiding impacts to waters and wetlands through the selection of
the least environmentally damaging, practical alternative; second, taking appropriate
and practical steps to reduce impacts on waters and wetlands; and finally,
compensation for remaining unavoidable impacts to the extent appropriate and
practical. To enable us to process your application, in compliance with the MOA, we
request that you provide the following additional information:
A. Permits for work within wetlands or other special aquatic sites are available only
if the proposed work is the least environmentally damaging, practicable
alternative. Please furnish information regarding any other alternatives, including
upland alternatives, to the work for which you have applied and provide
justification that your selected plan is the least damaging to water or wetland
areas.
It is unclear, based on the information provided, that the Preferred Alternative
is the LEDPA when compared to the other alternatives.
a) Alternative C4 — Based on Table 2-2 in appendix A, this
alternative would not be economically feasible at this time.
Please provide a brief but detailed description of the cost of this
alternative when compared to the preferred alternative.
b) Alternative C6 — Based on Table 2-2 in appendix A, this
alternative would not be practicable or feasible from a technical,
safety and economic standpoint. Please provide a brief but
detailed description of the safety issues, the redevelopment
cost, and impact to operational capabilities that would result in
this alternative not being practicable (i.e., available and capable
of being done after taking into consideration cost, existing
technology, and logistics in light of overall project purposes).
c) Lumley Road Alternative (tunnel) — Based on Table 2-2 in
appendix A, this alternative would not be practical from a
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technical and economic standpoint. Please provide a brief but
detailed description of the technical issues and associated cost
that would result in this alternative not being practicable (i.e.,
available and capable of being done after taking into
consideration cost, existing technology, and logistics in light of
overall project purposes).
d) Borrow Site 2 - Based on Table 2-2 in appendix A, this
alternative would not be technically and economically feasible.
Please provide a brief but detailed description of the material at
this site and associated cost that would result in this alternative
not being practicable (i.e., available and capable of being done
after taking into consideration cost, existing technology, and
logistics in light of overall project purposes).
e) Borrow Site 3 - Based on Table 2-2 in appendix A, this
alternative would not be technically and economically feasible.
Please provide a brief but detailed description of the material at
this site and associated cost that would result in this alternative
not being practicable (i.e., available and capable of being done
after taking into consideration cost, existing technology, and
logistics in light of overall project purposes).
f) Borrow Site 4 - Based on Table 2-2 in appendix A, this
alternative would not be technically and economically feasible.
Please provide a brief but detailed description of the quantity of
fill material at this site and the amount of impacts (loss) of
aquatic resources associated with this alternative.
g) Off -Airport Borrow Sites - Based on Table 2-2 in appendix
A, all offsite alternatives would not be practical or feasible from
a technical and economic standpoint. Please provide a brief but
detailed description of each alternative's practicability (available
and capable of being done after taking into consideration cost,
existing technology, and logistics in light of overall project
purposes). If necessary please provide a comparison of this
alternative compared to the preferred alternative (i.e., cost
analysis, timeline analysis).
B. It is necessary for you to have taken all appropriate and practicable steps to
minimize losses of Waters of the U.S., including wetlands. Please indicate all that
-3-

you have done, especially regarding development and modification of plans and
proposed construction techniques, to minimize adverse impacts.
i. Provide a description of the measures taken to avoid or minimize the
proposed impacts in designing the overall project.
ii. Describe the locations and design of the proposed erosion sediment control
features and proposed dry ponds (SCMs) and how they are avoiding a
minimizing to the maximum extent practicable.
iii. Describe in more detail the actions taken to avoid all impacts at the borrow
sites.
iv. Provide a description of the measures taken to reduce the impacts from the
project described in the EA to the proposed project in this application.
C. The MOA requires that appropriate and practicable mitigation will be required for
all unavoidable adverse impacts remaining after the applicant has employed all
appropriate and practicable minimization. Please indicate your plan to mitigate
for the projected, unavoidable loss of waters or wetlands or provide information
as to the absence of any such appropriate and practicable measures.
The Corps will evaluate the NCSAM and NCWAM forms associated with your
application to determine if your proposed compensatory mitigation ratio is
appropriate.
Additionally, the following items must be resolved prior to continuing to process
your permit request:
1) Please note that responses to the questions above may prompt additional
information requests to allow full evaluation of the proposed project.
The above requested information is essential to the expeditious processing of your
application; please forward this information to us within 30 days of your receipt of this
letter. If you have any questions regarding these matters, please contact me at (919)
588-9200 or George. L. Phillips(d)-usace. army. m il.
Sincerely,
�etiv9e- C.'YCe- phdi(�k /it
George Lyle Phillips III
Regulatory Project Manger
Raleigh Regulatory Field Office
-4-

Enclosures
Copies Furnished electronically:
Mr. Jim Novak, Raleigh -Durham Airport Authority, iim.novak(a�rdu.com
Mr. Bill Sandifer, Raleigh -Durham Airport Authority, bill. sandifer(a)-rdu.com
Mr. Bob Zarzecki, Soil and Environmental Consultants, bzarzecki(a)-sandec.com
Mr. Todd Bowers, U.S. Environmental Protection Agency, Bowers. todd (a)-epa. gov
Ms. Sue Homewood, North Carolina Division of Water Resources,
Sue. Homewood(a)ncdenr. gov
-5-

Phillips, George L CIV USARMY CESAW (USA)
From: Bowers, Todd <[e-mail]>
Sent: Tuesday, January 9, 2024 12:07 PM
To: Phillips, George L CIV USARMY CESAW (USA)
Subject: [Non-DoD Source] FW: US Army Corps of Engineers Public Notice: SAW-2022-01559
Importance: High
Lyle,
The EPA Region 4 Ocean, Wetlands and Streams Protection Branch has reviewed the subject USACE
Individual Public Notice under DA Action ID SAW-2022-01559 dated January 2, 2024. It is our
understanding that the applicant, Raleigh -Durham Airport Authority, is seeking Department of the Army
authorization to discharge dredged or fill material into potential waters of the United States, including potential
wetlands, associated with the Runway 5L/23R Replacement Project in Wake County, North Carolina.
Specifically per the project narrative, purpose and description, the applicant is proposing to replace the existing
runway 5LI23R with a new 10, 693 foot long runway shifted 537 feet to the northwest of the existing runway.
The Project would excavate approximately 5 million cubic yards of borrow material to fill and level the area of
the relocated runway prior to construction. During construction Brier Creek Reservoir would be used as a
water source for hydro -compression of fill material. Approximately 150 million gallons of water would be
withdrawn over a period of approximately two years. Additional construction activities would include
construction of the FAA -required safety areas, associated drainage improvements, utility relocation,
construction of an airport perimeter road, and relocation of navigational aids. Once construction of the new
runway is complete the existing runway 5LI23R would be converted to a taxiway. Additionally the new location
of the runway protection zone would require the relocation of a portion of Lumley Road. The Project would
result in the discharge of fill material into a total of approximately 2.45 ac (7,293 linear feet [l(l) of potentially
jurisdictional stream channel, 1.38 ac of potentially jurisdictional wetlands, and 2.17 ac of potentially
jurisdictional open waters.
Proposed impacts to potentially jurisdictional streams, wetlands and open waters have been further reduced
from the plans approved in the Federal Aviation Administration's (FAA) Environmental Assessment
(EA)/Finding of No Significant Impact (FONSI)/Record of Decision (ROD), dated August 31, 2023. Stream
impacts have been reduced from 8,780 if to 7,293 ff. Wetland impacts have been reduced from 1.56 ac to 1.38
ac. Open water impacts have been reduced from 3.48 ac to 2.17 ac. Minimization efforts include the avoidance
of all aquatic resources in the location of the proposed borrow sites.
The applicant proposes to provide compensatory mitigation at a 2:1 ratio for the loss of all potentially
jurisdictional streams and wetlands except for those streams and wetlands that were specifically classified
using the N. C. Stream Assessment Method (NCSAM) and N. C. Wetlands Assessment Method (NC RAM) in the
jurisdictional determination request package as either "MEDIUM" or "LOW" quality. The applicant proposes
to provide a 1.5:1 mitigation ratio for the loss of potentially jurisdictional streams and wetlands classified as
"MEDIUM", and a 1:1 ratio for those classified as "LOW". To mitigate for jurisdictional stream channel and
wetland impacts the applicant proposes to purchase 11, 757 warm -water stream credits and 2.16 riparian non-
riverine wetland credits from a combination of available mitigation banks and the North Carolina Division of
Mitigation Services (NCDMS) in lieu fee program.
At this time, the EPA has no comments or concerns with the project as presented.

Thank you for the opportunity to provide oversight and review on DA Action ID SAW-2022-01559 to
discharge dredged or fill material into potential waters of the United States, including potential wetlands,
associated with the Runway 5L/23R Replacement Project in Wake County, North Carolina.
Best Regards,
Todd Bowers
Todd Allen Bowers
US EPA Region 4 Wetlands and Stream Regulatory Section
Water Division Quality Assurance Coordinator
61 Forsyth St. SW
Atlanta, GA 30303
919.323.2637 cell/telework
404.362.9223 office
Bowers.todd&eggov
`Do unto those downstream as you would have those upstream do unto you."
Wendell Berry
to sTq
From: CESAW-PublicNoticeList <[e-mail]>
Sent: Tuesday, January 2, 2024 1:45 PM
Subject: US Army Corps of Engineers Public Notice
Importance: High
Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open
attachments or click on provided links.
As you requested, you are hereby notified that the Wilmington District, United States Corps of Engineers, has
issued a Public Notice. The text of this document can be found on the Public Notices portion of the Regulatory
Division Home Page. Each Public Notice is available in ADOBE ACROBAT (.pdf) format for viewing, printing or
download at:
https://www.saw.usace.army.mil/M issions/Regulatory-Permit-Program/Public-Notices/
The current notice involves: SAW-2022-01559 (Raleigh -Durham International Airport / Raleigh / Wake County

Issue Date: January 02, 2024
Expiration Date: February 01, 2024
Point of Contact: Lyle Phillips
Email: [e-mail]
Project Description:
To achieve the stated purpose, the applicant is proposing to replace the existing runway 5L/23R with a new
10,693-foot-long runway shifted 537 feet to the northwest of the existing runway. The Project would excavate
approximately 5 million cubic yards of borrow material to fill and level the area of the relocated runway prior
to construction. During construction Brier Creek Reservoir would be used as a water source for hydro -
compression of fill material. Approximately 150 million gallons of water would be withdrawn over a period of
approximately two years. Additional construction activities would include construction of the FAA -required
safety areas, associated drainage improvements, utility relocation, construction of an airport perimeter road,
and relocation of navigational aids. Once construction of the new runway is complete the existing runway
5L/23R would be converted to a taxiway. Additionally, the new location of the runway protection zone would
require the relocation of a portion of Lumley Road.
The Project would result in the discharge of fill material into a total of approximately 2.45 ac (7,293 linear feet
[If]) of potentially jurisdictional stream channel, 1.38 ac of potentially jurisdictional wetlands, and 2.17 ac of
potentially jurisdictional open waters.
The applicant stated that the Project is considered "deemed permitted" and exempt from obtaining State
stormwater permits; however, the applicant is proposing to construct four (4) new dry ponds designed to
meet the minimum design criteria (MDC) for Dry Ponds per the State stormwater design manual to treat
stormwater runoff from the project. Other elements of the Project such as the relocation of a section of
Lumley Road would comply with all applicable NCDOT stormwater management requirements.
Subscribe/Unsubscribe: This email was sent out as a result of subscribing to the Wilmington District regulatory program public
notices. Please reply to this email with the subject or message "unsubscribe" to remove your address from future mailings.

Phillips, George L CIV USARMY CESAW (USA)
From: Matthews, Kathryn (Kathy) <[e-mail]>
Sent: Friday, January 19, 2024 4:04 PM
To: Phillips, George L CIV USARMY CESAW (USA)
Cc: Naik, Lopa (FAA); Mann, Leigh
Subject: [Non-DoD Source] Comments to PN for RDU Runway 5L/23R: SAW-2022-01559
(USFWS Project Code: 2022-0061308)
Attachments: 20240118_Itr_FWS_Corps_RDU_Runway5L23R_PNComments.pdf
Hi Lyle,
Please find attached the Service's comments on this public notice. Let me know if you have any comments or
concerns. Have a great weekend!
For the Entire Month of January, we are packing our physical office for a move to a new location. I apologize
for any delays in response. For snail mail, please use the P.O. Box listed below, rather than our physical
address. Thanks!
Kathy Matthews
NC Renewable Energy Coordinator
U.S. Fish and Wildlife Service
P.O. Box 33726
Raleigh, NC 27636-3726
NEW Phone! 984-308-0852

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
18 January 2024
George Lyle Phillips III
Wilmington District
U.S. Army Corps of Engineers
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
SUBJECT: Raleigh -Durham International Airport; Runway 5L/23R Replacement Project
Wake and Durham Counties, North Carolina
Public Notice
USFWS Project Code: 2022-0061308
Corps Action ID Number SAW-2022-01559
Dear Mr. Phillips:
This letter responds to the January 2, 2024, Public Notice (PN) for the Runway 5L/23R
Replacement Project at Raleigh -Durham Airport Authority in Wake County, North Carolina. In
the PN, the U.S. Army Corps of Engineers (Corps) requests concurrence with its determinations
for listed species.
U.S. Fish and Wildlife Service (Service) has reviewed the PN, and we have met with the Corps
on site and in meetings concerning the project, along with the lead federal agency (Federal
Aviation Authority [FAA]). We are conferencing/consulting under section 7 of the Endangered
Species Act (ESA) with the FAA. By letter dated November 10, 2022, the Service concurred
with the FAA's determinations for all federally listed species below. The FAA's requirements
(as well as the Corps' requirements) under Section 7(a)(2) of the ESA have been satisfied for
these species. The Service also agreed in the November 10, 2022, letter that the project is not
likely to disturb nesting bald eagles.
Red -cockaded woodpecker (Dryobates borealis) (NE)
Neuse River waterdog (Necturus lewisi) (NLAA)
Carolina madtom (Noturus furiosus) (NLAA)
Atlantic pigtoe (b'usconaia masoni) (NLAA)
Dwarf wedgemussel (Alasmidonta heterodon) (NLAA)
Michaux's sumac (Rhus michauxii) (NE)
By letter dated December 19, 2023, the FAA requested initiation of formal conferencing for the
possible effects to the tricolored bat (Perimyotis subflavus) from the FAA's proposed
authorization of the project. The Service is initiating formal conferencing and should provide the
conference opinion no later than May 2, 2024. We have assigned Project number 2022-0061308

to this conference. The FAA has supported their request for formal conferencing with existing
information that was provided earlier or is available online (including the August 31, 2023 final
Environmental Assessment, the October 7, 2022 Biological Resources Assessment, and other
information that the Corps should have in its project files). If you desire, please coordinate with
us and the FAA to ensure that the Corps' ESA Section 7 obligations are adequately addressed
during this conferencing process.
If you have any questions or concerns, please contact Kathy Matthews, of my staff, at 984-308-
0852 or [e-mail].
Sincerely,
Digitally signed by
JENNIFER JENNIFERARCHAMBAULT
ARCHAMBAULT Date: 2024.01.1816:51:25
-05'00'
for Pete Benjamin
Field Supervisor
cc: Lopa Naik,FAA

Phillips, George L CIV USARMY CESAW (USA)
From: Caitlin Rogers <[e-mail]>
Sent: Thursday, January 25, 2024 3:51 PM
To: Phillips, George L CIV USARMY CESAW (USA)
Subject: [Non-DoD Source] SAW-2022-01589
Attachments: 2024-56-17.docx
Attached is the concurrence letter for your project.
Hawuh (Thank you),
Caitlin Rogers
Catawba Nation
Cultural Division Programs Manager
Tribal Historic Preservation Office
1536 Tom Steven Road
Rock Hill, SC 29730
803-328-2427 ext. 226
*Please Note: We CANNOT accept Section 106 forms via e-mail, unless requested. Please send us hard
copies. Thank you for your understanding*
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Catawba Indian Nation
Tribal Historic Preservation Office
1636 Tom Steven Road
Rock Hill, South Carolina 29730
Office 803-328-2427
January 25, 2024
Attention: George Lyle Phillips
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Re. THPO # TCNS # Project Description
2024-56-17 SAW-2022-01589
Dear Mr. Phillips,
The Catawba have no immediate concerns with regard to traditional cultural properties,
sacred sites or Native American archaeological sites within the boundaries of the
proposed project areas. However, the Catawba are to be notified if Native American
artifacts and / or human remains are located during the ground disturbance phase
of this project.
If you have questions, please contact Caitlin Rogers at 803-328-2427 ext. 226, or e-mail
[e-mail].
Sincerely,
Wenonah G. Haire
Tribal Historic Preservation Officer

Phillips, George L CIV USARMY CESAW (USA)
From: DCR - Environmental -Review <Environmental. [e-mail]>
Sent: Thursday, January 25, 2024 10:08 AM
To: Phillips, George L CIV USARMY CESAW (USA)
Subject: [Non-DoD Source] Reconstructing Runway 5L/23R, Raleigh -Durham International
Airport (RDU), Wake County, ER 20-2333
Attachments: ER-20-2333_cemetery.pdf
Our response is attached. Thank you.
Best,
Devon L. Borgardt (she/her)
Environmental Review Assistant
State Historic Preservation Office
919-814-6586
109 E. Jones Street MSC 4603 Raleigh, NC 27699
■1■
■■- N NC DEPARTMENT OF
■menu NATURAL AND CULTURAL RESOURCES
■ =XA■
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Please Note: Requests for project review or responses to our review comments should be sent to the
Environmental Review emailbox at [e-mail]. Otherwise, your request will be returned
and you will be asked to send it to the proper mailbox. This will cause delays in your project. Information on
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Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

Qu-
North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
January 25, 2024
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
George Lyle Phillips III George.L.Phillipsgusace.army.mil
Raleigh Regulatory Field Office,
3331 Heritage Trade Drive, Suite 105,
Wake Forest, NC 27587
Re: Reconstructing Runway 5L/23R, Raleigh -Durham International Airport (RDU), Wake County,
ER 20-2333
Dear Mr. Phillips:
Thank you for your submittal of January 2, 2024, regarding the above -referenced Project. We have
reviewed the information provided and offer the following comments.
Based on our consultation with the Federal Aviation Administration for this undertaking, we have
concurred that no historic properties will be affected.
As noted in Public Notice, we have already reviewed the archaeological survey report and concurred that
no archaeological historic properties will be affected. However, there are three cemeteries that are
recommended to be avoided (see letter dated 1/9/2023). These three cemeteries are not mentioned in the
Public Notice.
The R. A. Burgess Cemetery (31WA143) is likely located within a dense wisteria thicket adjacent to site
31WA2475 and is recommended as not eligible for the NRHP. Our recommendations for 31WA143 are to
avoid the wisteria thicket at 31WA2475 with a 75-ft buffer zone or conduct additional fieldwork to clear
the dense vegetation and attempt to locate the cemetery.
• Site 31WA145 is the Burgess -Dunn Family Cemetery and is recommended not eligible; Site
avoidance is recommended.
• Site 31WA2472 is an abandoned cemetery and is recommended not eligible; Site avoidance is
recommended. The site was delineated by a ground penetrating radar survey and systematic
probing.
Following the North Carolina Office of State Archaeology Archaeological Investigation Standards and
Guidelines (November 2023) recommendations for cemetery protection and avoidance (see pg. 21) a 15-
meter (49.2 feet) buffer should be placed around each of the cemeteries. High -visibility construction
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

ER 20-2333, January 25, Page 2 of 2
fencing during construction activities is recommended near cemeteries that do not have a fence or other
physical barrier.
We recommend that the cemetery boundaries be mapped by a licensed surveyor, recorded on deeds or
plats, and filed with the county, when possible. Please note that cemeteries are protected under NC General
Statutes Chapter 14-148 and 14-149 and are afforded consideration under Chapter 65. If unmarked human
skeletal remains are encountered during construction, the provisions of North Carolina General Statute
Chapter 70, Article 3 apply. Construction activities should immediately cease, and the county medical
examiner should be contacted.
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,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579
or environmental.reviewgdncr.nc.gov. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
0-a-, _� . L-�
Ramona Bartos, Deputy
State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

Qu-
North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
January 9, 2023
Douglass Aaron Braswell
Federal Aviation Administration
Memphis Airports District Office
2600 Thousand Oaks Boulevard, Suite 2250
Memphis, TN 38118
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
aaron. braswell @ faa. gov
Re: Phase I Archaeological Survey Report for Reconstructing Runway 5L/23R, Raleigh -Durham
International Airport (RDU) , Wake County, ER 20-2333
Dear Mr. Braswell:
Thank you for your submittal of November 1, 2022, transmitting the draft of the above -referenced report.
We have reviewed the information provided and offer the following comments.
Legacy Research Associates (Legacy) conducted a Phase I archaeological survey on approximately 475.8
acres of the project area that had not been previously surveyed or otherwise previously disturbed. Field
investigations included four archaeological survey areas, representing approximately 33.3 percent of the
1,427.9-acre project area, and were completed with 2,042 shovel tests being excavated. Cemeteries were
investigated with a visual inspection, systematic probing, and limited Ground Penetrating Radar (GPR)
survey.
The survey revisited five previously recorded sites (31 WA0081, 31 WA0082, 31 WA0083, 31 WA0143, and
31WA0145) that were not evaluated for the National Register of Historic Places (NRHP) when they were
previously recorded in 1974 and recorded 36 new sites (31WA2471-31WA2506). The location of one
previously recorded site (31WA0150 — Lynn Mausoleum) was relocated outside the project area in 2010
and was not revisited. Three of the five previously recorded sites were not located and therefore were not
assessed for the NRHP (31 WA0081, 31 WA0083, and 31 WA0143) .
Legacy notes that the R. A. Burgess Cemetery (31 WA0143) is likely within a dense wisteria thicket
associated with the site 31WA2475 that is recommended as not eligible for the NRHP. Legacy
recommendations for 31WA0143 are to avoid the wisteria thicket at 31WA2475 or conduct additional
fieldwork to clear the dense vegetation and attempt to locate the cemetery. Site 31WA0082 is
recommended as not eligible; Site 31WA0145 is the Burgess -Dunn Family Cemetery and is recommended
not eligible and site avoidance is recommended. Following the Avoidance Plan for Cemeteries, the
cemetery boundaries and a 75-ft buffer zone were flagged in the field and recorded with GPS.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

ER 20-2333, January 09, Page 2 of 2
All newly recorded sites (31WA2471-31WA2506) are recommended as not eligible. No further work is
recommended. Legacy notes that one of the 36 newly recorded sites (31WA2472) is an abandoned
cemetery, and a 75-ft buffer zone was flagged in the field and recorded with GPS.
We concur with Legacy's findings and recommendations for all sites and accept the report as final.
Regarding 31WA143, we recommend conducting additional fieldwork to clear the dense vegetation and
attempt to locate the cemetery.
In general, we commend Legacy on the report and its findings; however, we found several aspects of the
GPR surveys to be insufficient to fully evaluate the findings, including the collection methodology, use of
in -field interpretation vs post -processing, and lack of reporting of GPR results such as GPR profiles, time
slice maps, post processing steps. Despite these issues, we feel the recommended 75-foot (22.8 meter)
buffers are sufficient to adequately avoid these cemeteries. We recommend that the cemetery boundaries be
mapped by a licensed surveyor, recorded on deeds or plats, and filed with the county.
Please note that cemeteries are protected under NC General Statutes Chapter 14-148 and 14-149 and are
afforded consideration under Chapter 65. If unmarked human skeletal remains are encountered during
construction, the provisions of North Carolina General Statute Chapter 70, Article 3 apply. Construction
activities should immediately cease, and the county medical examiner should be contacted.
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,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579
or [e-mail]. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
Ramona Bartos, Deputy
State Historic Preservation Officer
cc: Deborah Joy, Legacy Research Associates [e-mail]
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898