20240241 Ver 1_Public Notice Comments_20240314

DocuSign Envelope ID: 43CE4A41-8FC4-42EE-B9C4-3489FFC2B899
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
March 14, 2024
Corps Action ID# SAW-2001-20723
DWR# 20240241
Johnston County
Matthew Martin
U.S. Army Corps of Engineers
Wilmington Regulatory Field Office
Delivered via email to: [e-mail]
Subject Project: Johnston Regional Airport Midfield Apron Development
Dear Mr. Martin:
On behalf of the NC Division of Water Resources, we respectfully request that you consider the
following comments within your review of the 404 Individual Permit request for the above referenced
project:
1. The applicant has indicated that one reason Alternative B is not feasible is the steep slopes.
However, the airport's publicly available Airport Layout Plan shows this area to be developed
with future hanger area and apron which appears to contradict the statements in the
alternatives analysis that indicate this area is not suited to hanger development.
2. The applicant states that Alternative B would not significantly avoid or minimize impacts to
wetlands because approximately 10 acres of wetlands will be impacted by the proposed
Midfield Development Site, however the current application is for 18.67 acres of wetland impact
when inclusion of the associated infrastructure and stormwater treatment systems are included
and therefore Alternative B does appear to significantly reduce impacts.
3. The applicant states that retaining the previous stormwater drainage pattern was determined to
be the least environmentally intrusive. It is unclear how retaining previous drainage patterns is
determined to be the least environmentally intrusive when the proposed SCM is resulting in
significant stream and wetland impacts.
4. The applicant states that multiple small SCMs were deemed infeasible due to the nature of the
planned site construction. While it is understandable that one SCM may be preferred for
construction simplicity, the Division requests that the USACE carefully evaluate whether the
justification provided is sufficient given the significant impacts proposed for the proposed SCM.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CARou Na 919.707.9000

DocuSign Envelope ID: 43CE4A41-8FC4-42EE-B9C4-3489FFC2B899
Corps Action ID# SAW-2001-20723
DWR# 20240241
Johnston County
Page 2 of 2
It also appears that the applicant has discounted the area proposed as the borrow site for a SCM
location because it would require stormwater to be pumped to the area, but it is unclear if the
analysis is based on the existing elevations or the proposed elevations after the area is used as a
borrow site.
6. It appears that there is further opportunity for minimization of impacts from the SCM if it were
shifted towards the existing runway. The Aquatic Resources Map provided with the application
shows uplands between the proposed location and the runway, and it appears that it would be
feasible to shift the location of the proposed SCM and further minimize wetland and stream
impacts.
7. The Division has not received a complete application at this time as the application fee has not
yet been received. Therefore, the Division has not conducted a technical review in accordance
with NC regulations.
Thank you for your considering the Division's comments during your review of this Individual Permit. If
you have any questions, please contact Sue Homewood at 336-813-1863 or
[e-mail].
Sincerely,
DocuSigned by:
Sf t plA,aa f- CDSS
980C5097D80E4E9...
Stephanie Goss, Supervisor
401 & Buffer Permitting Unit
Electronic cc: Kevin Lapp, AECOM
Gabriela Garrison, NCWRC
DWR 401 & Buffer Permitting Branch file
Filename: 20240241 JNX Midfield Apron - Johnston - Comments to USACE.docx
North Carolina Department of Environmental Quality I Division of Water Resources
D � 512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
NoalHCaao-wa 919.707.9000