20071841 Ver 1_Other Agency Comments_20071221

~ North Carolina Wildlife Resources Commission ~
December 21, 2007
Ms. Loretta Beckwith
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
Mr. Ian McMillan
NCDENR, Division of Water Quality, 401 Unit
1628 Mail Service Center
Raleigh, North Carolina 27699-1628
SUBJECT: Asheville Regional Airport Authority, Mr. David Edwards Individual Permit Application
Asheville Regional Airport Expansion, Buncombe County
Action ID 2007-3766-311, DWQ No. 07-1841
Dear Ms. Beckwith and Mr. McMillan:
Mr. David Edwards of the Asheville Regional Airport Authority requested an Individual Permit from the U.S.
Army Corps of Engineers (ACOE) to expand the Asheville Regional Airport. North Carolina Wildlife
Resources Commission (Commission) staff attended the December 6, 2007 site meeting. Comments from the
Commission are provided under provisions of the Clean Water Act of 1977 (33 U.S.C. 466 et. seq.) and the
Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d).
About 1,640 feet of stream and 0.209 acre of wetland fills are proposed under the preferred project
alternative. Alternative locations for the expansion were discussed in the application, but no site plans were
shown. The 16-acre preferred site has recently been cleared of vegetation with heavy equipment. This has
exacerbated stream channel erosion, compacted wetland soils, and modified wetland hydrology. Coal fly ash
would be used as the bulk of the structural fill needed to develop this site.
The French Broad River near the airport supports a cool water fishery that includes smallmouth bass and
muskellunge. Wetlands in this region are important to a variety of birds and other wildlife. Bog turtles (State
Threatened) and mole and four-toed salamanders (State Special Concern) have been found in wetlands along
the French Broad River within a few miles of the airport. The largest wetland on the preferred site probably
supported salamanders before the site preparation occurred. It and the riparian areas on the property also
were important for protecting water quality in the French Broad River.
Given the important fish and wildlife resources in the area, the Commission is particularly concerned with the
limited evaluation of project alternatives and the recent wetland and stream impacts that have occurred on the
preferred site. One alternative discussed at the meeting, but dismissed in the application, involves using the
preferred site by relocating a portion of stream channel A to the east instead of using this area solely for storm
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center Raleigh, NC 27699-1721
Telephone: [phone] Fax: [phone]

Asheville Regional Airport Authority Page 2 December 21, 2007
Buncombe
drainage swales. With this possibility, detained and treated storm water might be routed into the head of the
open channel rather than near the property's northern boundary. Since the stream channel is now unstable
and in generally poor condition, any project alternative that is pursued should address this situation. Another
way to minimize impacts without changing the site development may be a slight shift and/or construction of a
low retaining in the northeast fill slope, which currently necessitates filling wetland cc. However, this
wetland would require restorative work like stream channel A given the disturbance that has occurred.
Coal fly ash is not considered a hazardous waste, but it does contain trace elements that can be mobilized by
water and cause toxicity to aquatic life. Therefore, if it is used as structural fill, then adherence to the
requirements outlined in 15A NCAC 13B. 0.1700 will be particularly important because of proximity to
water. These requirements include, in part, not placing ash within 50 feet of wetlands and streams, isolation
of fill from storm water during filling, keeping fill slopes less than 3:1, and maintaining the fill area as a non-
discharge structure. The separation requirement may not be met given the stream fill. Nevertheless, to keep
the fill from discharging, an impervious fill base and cover is recommended since the region normally
receives considerable annual precipitation. Should non-discharge not be achieved, the Commission
recommends that the discharge be periodically tested for toxic elements and, should standards be exceeded, a
remediation plan executed in a timely manner. This would be similar to the monitoring that would be
required to ensure compliance with groundwater standards (15A NCAC 2L).
Extensive impervious cover from the proposed development has the potential to degrade downstream water
quality. This is already evident on the preferred site where stream channel degradation appears to have
increased following the site work and where petroleum and nutrient pollution was noted during the site visit.
Therefore, the Commission requests that effective storm water detention and treatment be used for the
expansion and any existing developed areas that can be incorporated.
If impacts to the streams and wetlands on the preferred site are permitted, then a 2:1 or higher compensatory
mitigation ratio is recommended. This recommendation is based on the apparently good condition of wetland
cc and the lower part of stream A before site grading commenced and their regional importance to fish and
wildlife resources. In addition, the function of streams and wetlands that will not be permanently filled, if
applicable, should be restored.
Thank you for the opportunity to review and comment on this project. If there are any questions
regarding these comments, please contact me at [phone] extension 24.
Sincerely,
~~ .
Dave McHenry
Mountain Region Coordinator
Habitat Conservation Program
cc: Mr. Kevin Barnett, NC Division of Water Quality
Mr. Bryan Tompkins, US Fish and Wildlife Service
Ms. Becky Fox, USEPA