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Home My WebLink About20151229 Ver 1_More Info Received_20160222Tk PIEDMONT TRIAD AIRPORT AUTHORITY February 19, 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 Subject: Action ID SAW -2015-00920 HAECO Facility Improvements at Piedmont Triad International Airport The Piedmont Triad Airport Authority (PTAA) has received your Request for Additional Information dated January 26, 2016 and offers the following responses to your comments regarding appropriate and practicable mitigation: 1) The Corps has evaluated the compensatory mitigation plan included in your application, including payment to the NC Division of Mitigation Services (NCDMS), for the permanent stream and wetland impacts associated with this project. However, as directed in 33 CFR 332.3, preference should generally be given to satisfying compensatory mitigation requirements through mitigation banks if available, secondly by in -lieu fee program, and lastly by on-site restoration, creation, or preservation, based on a variety of considerations. Please refine your proposal, including determining if appropriate stream and wetland credits are available from mitigation banks (see Restoration Systems, LLC letter). If not, or if only a portion of the mitigation need is available from a bank you may propose to satisfy the remainder of the mitigation requirement through the NCDMS. PTAA is negotiating purchase of all credits offered by Restoration Systems, LLC. PTAA understands that these 1477.75 stream mitigation units (SMU) are the only available mitigation credits in the Cape Fear 02 (Hydrologic Unit Code 03030002). It is our understanding that this purchase, along with the 214 SMU remaining at the Causey Farm Mitigation Site (see Causey Farm Status, attached), constitutes all obtainable private bank credits in this HUC and consequently the balance of the mitigation required will be purchased from the NCDMS. The mitigation proposed to compensate for the 0.81 acres riparian wetland and 1601 linear feet perennial stream impacts is refined as summarized in the response to Comment 2, following. 2) Note also that your application did not indicate proposed stream/ivetland credit to impact ratios or include acceptance letters from any mitigation provider; this information is necessary to continue processing your application. Justification for credit to impact ratios less than 2:1 must be provided based on functional quality using stream reach and/or wetland functional assessments in the form of NC Stream Assessment Method (NCSAM) or NC Wetland Assessment Method (NCWAM) evaluations, respectively, per the Corps Public Notice dated April 21, 2015. 1000A Test Johnson Parkway • Greensboro„ Noilli Carolina 27409 i Plione: 336.665.5600 • Fax: 336.665.1425 Mr. David E. Bailey February 19, 2016 Page 2 of 2 As discussed in our pre -application meeting of September 28, 2015, credit to impact ratio of 2:1 is proposed for both wetland and stream mitigation. The mitigation proposed is summarized below: IMPACT RATIO MITIGATION 0.81 ac. Riparian wetland 2:1 1.75 WMU NCDMS 1,477.75 SMU Restoration Systems 1,601 l.£ Perennial stream 2:1 214 SMU Causey Farm 1,510.25 SMU NCDMS PTAA has addressed recommendations provided by the North Carolina Wildlife Resources Commission (NCWRC) dated January 11, 2016 in the attached correspondence to Shari Bryant. PTAA has also addressed comments received from Restoration Systems, LLC dated January 11, 2016 through purchase of their entire HUC 03030002 credit availability (acceptance letter attached). We appreciate your continued consideration of this application for Section 404 Individual Permit. Please feel free to contact me (rossera gsoair.org, 336.665.5620) or Richard Darling (rdarlingkmbakerintl.com, 919.481.5740) with additional questions or comments. Sincerely, PIEDMONT TRIAD AIRPORT AUTHORITY J. Alex Rosser, P.E. Deputy Executive Director RD/AR:rd Enclosures: PTAA Response to NCWRC Acceptance Letter; Restoration Systems LLC Causey Farm Status Letter; Restoration Systems LLC Acceptance Letter; NCDMS cc: Todd Bowers; USEPA Sue Homewood; NCDEQ Richard Darling; Michael Baker International PIEDMONT TRIAD AIRPORT AUTHORITY February 19, 2016 North Carolina Wildlife Resources Commission Division of Inland Fisheries 1721 Mail Service Center Raleigh, NC 27699-1721 Attention: Ms. Shari L. Bryant, Western Piedmont Coordinator Habitat Conservation Division Subject: USACE Action ID SAW -2015-00920 HAECO Facility Improvements at Piedmont Triad International Airport The Piedmont Triad Airport Authority (PTAA) has received your Memorandum to the United States Army Corps of Engineers (USACE) dated January 11, 2016 and offers the following in response to your recommendations: 1. Use stormwater control measures to mimic the hydrograph consistent with an impervious coverage of less than 10%. Where feasible, trees and shrubs should be planted around stormwater ponds, excluding the dam. This would provide habitat benefits that offset those functions lost by development, partially restore aquatic habitats, reduce exposure of the water surface to sunlight to minimize thermal pollution, and provide essential summer and winter habitats. Due to the nature of airport development and Federal Aviation Administration (FAA) airport design requirements (AC 150/5300-13A), impervious surfaces (runways, taxiways, aprons, etc.) are combined with vast grassed (pervious) in -field areas. PTAA impervious cover is less than 24% for the entire airport. Stormwater control measures are designed to mimic the pre -project hydrograph. PTAA is restricted in application of project landscaping by current FAA airport design regulations. Further, FAA AC 150/5200-33B restricts the application of features with potential to enhance the habitat value of the site for potentially hazardous wildlife due to aircraft -wildlife strike potential. 2. Concrete is toxic to aquatic life and should not be allowed to come in contact with surface waters until cured. Pursuant to anticipated Section 401 water quality certification conditions, concrete will not be allowed to come in contact with surface waters until cured. Sediment and erosion control measures should be installed prior to any land clearing or construction. The use of biodegradable and wildlife friendly sediment and erosion control devices is strongly recommended. Silt fencing, fiber rolls and/or other products should have loose -weave netting that is made of natural fiber materials with movable joints between the vertical and horizontal twines. Silt fencing that has been reinforced with plastic or metal mesh should be avoided as it impedes the movement of terrestrial wildlife species. These measures should be routinely inspected and properly maintained. Excessive silt and sediment loads can have numerous detrimental effects on aquatic resources including destruction of spawning habitat, suffocation of eggs, and clogging of gills of aquatic species. As stated in the Section 404/401 (of the Clean Water Act) permit application, erosion and sedimentation control measures for the project will be coordinated through the North Carolina Department of Environmental Quality (NCDEQ). PTAA will obtain the applicable Erosion and Sedimentation Control Permits and accompanying National Pollutant Discharge 1 OOOA Ted Johnson Parkway * Greensboro, North Carolina 274.00 * Phone: 336.665.5600 * Pax: 336.665.1425 Ms. Shari L. Bryant February 19, 2016 Page 2 of 2 Elimination System (NPDES) Construction Permits. Potential temporary impacts to surface water quality as a result of construction activities will be effectively mitigated through adherence to the approved Erosion and Sedimentation Control Plans and to the NPDES permit requirements, as well as through compliance with FAA AC 150/5370-1O13. 4. We defer to the U.S. Army Corps of Engineers and N.C. Division of Water Resources regarding the mitigation credit to impact ratio for this project. Mitigation credit to impact ratio of 2:1 for both wetlands and streams have been agreed to by the U.S. Army Corps of Engineers and NC Division of Water Resources in the pre - application meeting of September 28, 2015. We appreciate your review of the PTAA application for Section 404 Individual Permit. Please feel free to contact me (rosseraggsoair.org, 336.665.5620) or Richard Darling (rdarling@mbakerintl.com, 919.481.5740) with questions or comments regarding your recommendations. Sincerely, PIEDMONT TRIAD AIRPORT AUTHORITY 4Ar J. Alex Rosser, P.E. Deputy Executive Director RD/AR:rd cc: David Bailey; USACE Sue Homewood; NCDEQ Richard Darling; Michael Baker International RESERVATION LETTER Cripple Creek Stream & Wetland Mitigation Bank Bass Mountain Stream Mitigation Bank February 5, 2016 Piedmont Triad Airport Authority Mr. J. Alex Rosser 1000-A Ted Johnson Parkway Greensboro, NC 27409 Re: Reservation of Stream Mitigation Credits Project: HAECO Facility Improvements, Guilford County, North Carolina We are providing this letter to confirm that 502.45 Stream Mitigation Credits (Credits) from the Cripple Creek Mitigation Bank (Bank) & 975.3 Stream Mitigation Credits from the Bass Mountain Stream Mitigation Bank (1,477.75 total credits) are currently available and may be used, once transferred, for compensatory mitigation relative to the HAECO Facility Improvements project and as proposed by Piedmont Triad Airport Authority (Applicant). Our company hereby confirms that the Credits are currently available for transfer from the Bank's Ledger to the Applicant at a cost of $350 per credit, $517,212.50 total cost. Payment must be made by March 7, 2016 to receive the $350 per credit price. Should the Applicant purchase the Credits within the relevant timeframe, we will complete and execute the Compensatory Mitigation Responsibility Transfer Form (Transfer Form) within three (3) business days of the Bank's receipt of the full purchase price. We will further provide copies of the completed and executed Transfer Form to the Applicant, the Bank's USACE Project Manager and, if needed, other regulatory agencies. Finally we will also provide to the USACE an updated copy of the Bank's Ledger, reflecting the transaction. Transaction information in the updated Bank Ledger will include relevant Permit and Applicant information as well as the number and resource type of the debited Credits. Should your office have any questions, please contact me at 919.334.9123. Sincerely, J "w Ar-- Tiffani Bylow Restoration Systems 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 Environmental Quality February 22, 2016 Alex Rosser, PE Piedmont Triad Airport Authority 1000-A Ted Johnson Pkwy. Greensboro, NC 27409 Project: HAECO Facility Improvements PAT MCCRORY DONALD R. VAN DER VAART se � h r , Expiration of Acceptance: August 22, 2016 County: Guilford This letter replaces and revises one issued on February 15, 2016. The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing to accept payment for compensatory mitigation for impacts associated with the above referenced project as indicated in the table below. Please note that this decision does not assure that participation in the DMS in -lieu fee mitigation program will be approved by the permit issuing agencies as mitigation for project impacts. It is the responsibility of the applicant to contact permitting agencies to determine if payment to the DMS will be approved. You must also comply with all other state, federal or local government permits, regulations or authorizations associated with the proposed activity including G.S. § 143-214.11. This acceptance is valid for six months from the date of this letter and is not transferable. If we have not received a copy of the issued 404 Permit/401 Certification/CAMA permit within this time frame, this acceptance will expire. It is the applicant's responsibility to send copies of the permits to DMS. Once DMS receives a copy of the permit(s) an invoice will be issued based on the required mitigation in that permit and payment must be made prior to conducting the authorized work. The amount of the in -lieu fee to be paid by an applicant is calculated based upon the Fee Schedule and policies listed at http://portal.ncdenr.org/web/eep. Based on the information supplied by you in your request to use the DMS, the impacts that may require compensatory mitigation are summarized in the following table. The amount of mitigation required and assigned to DMS for this impact is determined by permitting agencies and may exceed the impact amounts shown below. Impact River CU Location Stream (feet) Wetlands (acres) Buffer I Buffer II Basin (8 -digit HUC) (Sq. Ft.) (Sq. Ft.) Cold Cool Warm Riparian Non -Riparian Coastal Marsh Cape 03030002 0 0 756 0.81 0 0 0 0 Fear Upon receipt of payment, DMS will take responsibility for providing the compensatory mitigation. The mitigation will be performed in accordance with the In -Lieu Fee Program instrument dated July 28, 2010 and 15A NCAC 02B .0295 as applicable. Thank you for your interest in the DMS in -lieu fee mitigation program. If you have any questions or need additional information, please contact Kelly Williams at (919) 707-8915. cc: David Bailey, USAGE- Raleigh Richard Darling, agent Sincerely, Ja e . B Stanfill Asse Management Supervisor -!- 'Nothing Compares!"-,- State ompares State of North Carolina I Environmental Quality 1601 Mail Service Center I Raleigh, North Carolina 27699-1601 919-707-8600