20021139 Ver 2_Comments to the USACE_20180921

NORTH CAROLINA
ROY COOPER Environmental Quality
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim otrectar
September 21, 2018
DWR# 20021139 v2
Forsyth County
Bryan Roden -Reynolds
U.S. Army Corps of Engineers
Charlotte Regulatory Field Office
151 Patton Ave, Room 208
Asheville, North Carolina 28801-5006
Subject Project: Smith Reynolds Airport Project
Corps Action ID# SAW -2017-01312
Dear Mr. Roden -Reynolds:
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 property:
1. Based on information provided in the application, as well as current aerial imagery, it
appears that construction may have begun on this project. If the project has begun, the
applicant should be informed that activities already conducted will not be considered in
review of this project.
2. The Purpose and Need for the Runway 15-33 Obstruction Removal portion of this
project does not clearly detail why the applicant cannot make sufficient use of their
property without impacts to the wetlands or with a reduced impact to wetlands. The
applicant has not provided an on-site alternative analysis that includes clearing trees
with no impacts, or with temporary impacts and restoration, to jurisdictional waters.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

DWR #20021139v2
DWR Comments to USACE
Page 2 of 2
3. The applicant has not provided a detailed on-site Alternatives Analysis or a detailed
avoidance and minimization plan for the New MRO Facilities with Auto Parking and
Apron Expansion portion of the proposed project. The applicant has not provided
detailed information supporting the proposed project size (number of hangers, number
of parking spaces, size of apron, etc.) or an on-site alternatives analysis that discusses
the use of uplands within the existing property limits.
4. The applicant has not provided a detailed Purpose and Need or an avoidance and
minimization analysis for the proposed permanent Haul Road. The applicant has not
provided sufficient information to document the need for permanent impacts from the
Haul Road.
5. The applicant has not provided a detailed Purpose and Need or an avoidance and
minimization analysis for impacts resulting from the proposed temporary sediment and
erosion control and/or permanent stormwater control measures. Sediment and Erosion
Control measures are only temporary in nature and therefore these impacts should be
considered temporary if they are found to be justified. The North Carolina DEQ
Stormwater Design Manual includes many options for permanent stormwater control
measures available for consideration by the applicant.
6. 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.
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 336-776-9693 or
[e-mail].
Sinc�erjelly,, `
� _ a e
Karen Higgins, Supervisor
401 & Buffer Permitting Branch
cc: Clement Riddle, ClearWater Environmental (via email)
Andrea Leslie, NCWRC (via email)
Byron Hamstead, USFWS (via email)
DWR ARO
DWR — Wetlands and Buffer Permitting Branch
Filename: 021139v2Sm ith ReynoldsAi rportProject( Forsyth)_404_Comments