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Home My WebLink About20071841 Ver 8_Public Notice Comments_20240618DocuSign Envelope ID: CECC942E-8259-4lB1-BFE6-D5E306176E4A ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality June 18, 2024 Corps Action ID# SAW-2024-00897 DWR# 20071841v8 Buncombe County Mr. Mitchell Anderson U.S. Army Corps of Engineers Asheville Regulatory Field Office Delivered via email to: Mitchell.L.Anderson@usace.army.mil Subject Project: Asheville Airport Runway Object Free Area Extension Project Dear Mr. Anderson: 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 Division requests that you consider the validity of the purpose and need of the proposed project, as well as the documents provided with the application, based on a record of previous applications submitted to the agencies. Please see the attached request for additional information. The applicant has proposed a reduced mitigation ration based on an NCSAM evaluation of the stream. Please note that the stream has been previously impacted by a relocation project, a streambank stabilization project including armoring, and/or a culvert installation (erosion may be a result of previous design decisions). A previous streambank stabilization project proposed small shrubs and trees to be planted in order to improve streambank stability. It appears that the applicant did not undertake this project and therefore a reduced NCSAM evaluation for lack of buffers may be a result of non -compliant actions. The Division is unable to complete a review of the project for compliance with 15A NCAC 02H .0506 at this time. The Division has requested additional technical information from the applicant and requests that the USACE also consider the attached letter during the review of the application. 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 CARCLINA 919.707.9000 DocuSign Envelope ID: CECC942E-8259-41B1-BFE6-D5E306176E4A Corps Action ID# SAW-2024-00897 DWR# 20071841v8 Buncombe County Page 2of2 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 sue.homewood@deg.nc.gov. Sincerely, ESDocuSigned by: ftp�u, bass 980C5097D80E4E9... Stephanie Goss, Supervisor 401 & Buffer Permitting Unit Encl.: Request for Additional Information — Asheville Airport Runway Object Free Area Extension Project, dated June 18, 2024, 2024 Electronic cc: Eric Romaniszyn, ClearWater Andrea Leslie, NCWRC DWR 401 & Buffer Permitting Branch file Filename: 20071841v8 AVL Airport runway safety culvert ext - Buncombe - comments to USACE.docx REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611 NORTH CAROLINA 919.707.9000 naparMeM of EmironmanW 9uallly DocuSign Envelope ID: CECC942E-8259-4lB1-BFE6-D5E306176E4A ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality June 18, 2024 DWR # 20071841 v8 Buncombe County Greater Asheville Regional Airport Authority Attn: Mr. Michael Reisman 61 Terminal Drive, Suite 1 Asheville NC 28732 Delivered via email to: mreisman@flyavl.com Subject: REQUEST FOR ADDITIONAL INFORMATION Asheville Airport Runway Object Free Area Extension Project Dear Mr. Reisman: On April 25, 2024 the Division of Water Resources (Division) received your application requesting a 401 Individual Water Quality Certification from the Division for the subject project. The Division has determined that your application is incomplete and cannot be processed. The application is on -hold until all of the following information is received: 1. 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. The project proposes to extend a culvert within a stream channel at the Asheville Regional Airport for the purpose of security and safety. The application states that the Runway Safety Area (RSA) must be cleared and graded and have no potentially hazardous... surface variations". The RSA based on the largest group of planes at the airport and is stated to be 1,000 feet long and 500 feet wide. On February 4, 2016 an application was submitted to the US Army Corps of Engineers (USACE) and the Division for the same purpose. The 2016 application stated that the RSA was 1000 feet long and 500 feet wide and therefore 130 feet of culvert were proposed for installation within the same stream to meet the RSA requirements. Based on a full review of the application documents in 2016 and the application documents of April 2024, these projects appear to be identical however the drawings showing the location of the RSA and the proposed "required impacts" are inconsistent. Based on information submitted in 2016 and approved by the USACE and the Division, the current project does not appear 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 CARCLINA 919.707.9000 DocuSign Envelope ID: CECC942E-8259-41B1-BFE6-D5E306176E4A_, ieville Airport Runway Object Free Area Extension Project DWR# 20071841v8 Request for Additional Information Page 2of2 necessary to meet the RSA. Please provide clarification on the purpose of the project and the discrepancies between the 2016 application and the current application. 3. The application states that an additional purpose of the proposed culvert replacement is to address flooding on the property due to an existing grate. Please explain why the grate cannot be removed or revised in some fashion to resolve this issue. The Division is unclear how revisions to the culvert design would resolve this issue assuming that a grate would be necessary on the new culvert also. Please note that the Division expressed concern for the proposed double culvert design in 2016 and at that time were assured that the design was appropriate. If it is determined that an alternative design is required to address flooding, it must be designed to avoid and minimize additional impacts (additional culvert length). Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested information for the proper consideration of the application. Please respond in writing within 30 calendar days of receipt of this letter by sending one (1) copy of all of the above requested information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617 OR by submitting all of the above requested information through this link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note the DWR# requested on the link is referenced above). If all of the requested information is not received within 30 calendar days of receipt of this letter, the Division will be unable to approve the application and it will be denied as incomplete. The denial of this project will necessitate reapplication to the Division for approval, including a complete application package and the appropriate fee. Please be aware that you have no authorization under the Section 401 of the Clean Water Act for this activity and any work done within waters of the state may be a violation of North Carolina General Statutes and Administrative Code. Please contact Sue Homewood at 336-813-1863 or Sue.Homewood@deg.nc.gov if you have any questions or concerns. Sincerely, DocuSigned by: �ftpl�,a.�uc, �asS St i�r gZ4 g','Supervisor 401 & Buffer Permitting Branch Electronic cc: Eric Romaniszyn, ClearWater Mitchell Anderson, USACE Asheville Regulatory Field Office Andrea Leslie, NCWRC DWR 401 & Buffer Permitting Branch file Filename: 20071841v8 AVL Airport runway safety culvert ext - Buncombe - addinfo.docx � 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 CAROLINA 919.707.9000 gaparNrM of Emironmanfal quay