20151065 Ver 1_More Info Received_20160222

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PIEDMONT TRIAD AIRPORT AUTHORITY
February 22, 2016
Department of the Army
Wilmington District, Corps of Engineers
69 Darlington Ave.
Wilmington, NC 28403-1343
Attention: Mr. David E. Bailey
Regulatory Project Manager
Raleigh Field Office
NC Department of Environmental Quality
Division of Water Resources
450 W. Hanes Mill Rd., Suite 300
Winston Salem, NC 27105
Ms. Sue Homewood
Environmental Specialist
Winston-Salem Regional Office
Subject: Action ID SAW -2012-01547
Northwest Taxiway Connector at Piedmont Triad International Airport
Based on the February 10, 2016 field application and subsequent discussions of the North
Carolina Stream Assessment Method (NCSAM) to the unnamed tributary to Brush Creek (SAC)
potentially impacted by the Northwest Taxiway Connector, the Piedmont Triad Airport
Authority (PTAA) is revising the mitigation proposed in the subject Clean Water Act
Section 404 application. PTAA proposes to mitigate the 244 linear feet (l.f.) of perennial
channel to be impacted, at a 2:1 ratio at the Causey Farm mitigation site as described in the
Application. At this time, mitigation for the formerly `intermittent' reach appears inappropriate
due to its current status as described below. Mitigation proposed for the purposes of the Section
401 application remains unchanged at 1:1 ratio.
The original subwatershed for Stream SAC has been largely removed (from approximately
0.044 square miles to 0.026 square miles) due to the significant re -grading to the northeast by the
North Carolina Department of Transportation (NCDOT I-5110 project, 1-73) roadway
construction. This drainage area removal has resulted in a significant reduction in the volume of
water entering the stream. No flow, standing water, or remnant pools were observed in the
`intermittent reach', although it remained evident as a channel feature. Given the wetter than
average 2015-2016 autumn and winter (6.5 inches more precipitation than the average from
September 2015 - January 2016 using NC-CRONOS data for the Airport's weather station), at
least some degree of flow should have been detected for an intermittent stream. It is apparent
that the stream has been altered to a less than intermittent flow regime and no longer exhibits
jurisdictional characteristics.
The NCSAM spreadsheet for the `intermittent' reach returned an overall rating of `Medium',
with a `Medium' rating in the stream Hydrology function class, a `Low' rating in the Water
Quality class, and a `Medium' rating in the Habitat class. This assessment was predicated on at
least seasonal flow for this reach, as a true intermittent stream. With no water in the channel
even during a wet time of year, there is no stream hydrology, water quality, or habitat present to
assess and scores for all three functions would be low. Thus, with the loss of flow as described
above, determination of the mitigation appropriate for potential impacts to this reach would be
better based on its present non jurisdictional status.
1000A Ted Johnson Parkway + Greensboro, North Carolina 27409 • Phone: 336.665,5600 9 Fax: [phone]

Mr. David K Bailey, Ms. ,Sue Homewood
February 22, 2016
Page 2 of 2
The perennial reach of SAC also rated `Medium' and the channel observed below the significant
headcut (-10 foot vertical drop) appears consistent with this determination. The mitigation
proposed is revised as follows:
A total of 488 Stream Mitigation Units (SMU) will be debited at the Causey Farm site for this
project, meeting the USACE mitigation requirement and exceeding the NCDWR requirement.
The credit balance of 214 SMU at Causey Farm will be applied to the HAECO project at PTIA
(Action ID SAW -2015-00920).
Pursuant to your request, Restoration Systems LLC, as owner of the Causey Farm Mitigation Site, has
acknowledged the change in impact locations for the applicable SMUs (letter dated February 17, 2016
enclosed). We appreciate your continued consideration of this application. Please contact me
([e-mail], 336.665.5620) or Richard Darling (rdarlingna,mbakerintl.com, 919.481.5740) if
you require any additional information to issue the permit as expeditiously as possible.
Sincerely,
PIEDMONT TRIAD AIRPORT AUTHORITY
8 �k L'
J. Alex Rosser, P.E.
Deputy Executive Director
RD/AR:rd
Enclosures: Causey Farm Ledger Update
cc: Richard Darling; Michael Baker International
Impact
USACE
NCDWR
USACE
NCDWR
SAC Reach
(l.f.)
Ratio
Ratio
Debit (SMU)
Debit (SMU)
`Intermittent'
151
NA
1:1
0
151
Perennial
244
2:1
1:1
488
244
Total
395
488
395
A total of 488 Stream Mitigation Units (SMU) will be debited at the Causey Farm site for this
project, meeting the USACE mitigation requirement and exceeding the NCDWR requirement.
The credit balance of 214 SMU at Causey Farm will be applied to the HAECO project at PTIA
(Action ID SAW -2015-00920).
Pursuant to your request, Restoration Systems LLC, as owner of the Causey Farm Mitigation Site, has
acknowledged the change in impact locations for the applicable SMUs (letter dated February 17, 2016
enclosed). We appreciate your continued consideration of this application. Please contact me
([e-mail], 336.665.5620) or Richard Darling (rdarlingna,mbakerintl.com, 919.481.5740) if
you require any additional information to issue the permit as expeditiously as possible.
Sincerely,
PIEDMONT TRIAD AIRPORT AUTHORITY
8 �k L'
J. Alex Rosser, P.E.
Deputy Executive Director
RD/AR:rd
Enclosures: Causey Farm Ledger Update
cc: Richard Darling; Michael Baker International

February 17, 2016
Mr. David Bailey
Regulatory Project Manager
US Army Corps of Engineers
3331 Heritage Trade Drive
Suite 105
Wake Forest, NC 27587
RE: PTIA Northwest Taxiway Connector Project (Action ID SAW -2012-01547) & HAECO
Facility Improvements Project (Action ID SAW -2015-00920)
Dear Mr. Bailey -
Restoration Systems (RS) is designating the 1,123 linear feet (If) of North Prong Stinking
Quarter Creek of the Causey Farm Mitigation Site currently available as 702 Stream Mitigation
Units (SMUs) based on the 1:1.6 "off-site" penalty ratio established for the PTAA FedEx Project
(SAW -2000-21655) as follows:
PTIA Northwest Taxiway Connector Project (SAW -2012-01547) 488 SMUs
HAECO Facility Improvements Project (SAW -2015-00920) 214 SMUs
This letter documents the use of all available SMUs at the Causey Farm Site and we will update
our records accordingly.
Sincerely,
John Preyer
President
Restoration Systems
cc: Sue Homewood / Division of Water Resources
Richard Darling / Michael Baker International
Alex Rosser / Piedmont Triad Airport Authority
1101 Haynes St., Suite 211 • Raleigh, NC 27604 • www.restorationsystems.com • Ph 919.755.9490 • Fx 919.755.9492