20021139 Ver 2_USACE request for more info_20181002

US Army Corps
Of Engineers
Wilmington District
PUBLIC NOTICE COMMENTS
Date Issued: October 2, 2018
Corps Action ID Number: SAW -2017-01312
Mr. Mark Davidson
Airport Commission of Forsyth County
3801 N. Liberty Street
Winston-Salem NC 27105
Dear Mr. Davidson:
Please reference your Individual Permit (IP) application for Department of the Army (DA)
authorization to discharge fill material into 1.13 acres of wetlands and 4,079 linear feet of
stream, associated with the following activities: 1) Extension of Taxilane L and new
maintenance, repair, and overhaul (MRO) facilities; 2) MRO auto parking and apron expansion;
3) Runway 15-33 obstruction removal; 4) Runway 22 safety area extension; 5) New haul road;
and 6) Construction of an erosion control/stormwater basin for the Smith Reynolds Airport in
Forsyth County, North Carolina.
Your proposal was advertised by public notice on August 28, 2018. Comments in response
to the notice were received from the North Carolina Department of Environmental Quality,
Division of Water Resources (NCDEQ-DWR), the North Carolina Wildlife Resources
Commission (NCWRC), United States Department of the Interior, Fish and Wildlife Service
(USFWS), the National Oceanic and Atmospheric Administration, National Marine Fisheries
Service (NMFS), North Carolina Senator Paul A. Lowe Jr., Yadkin Riverkeeper, and the general
public. In addition to the comments received during the public notice period, the NCDEQ-DWR,
submitted a letter dated, September 21, 2018, requesting additional information from the
applicant. Within that letter, NCDEQ-DWR determined the applicant's IP application to be
incomplete and cannot be processed at this time. The NCDEQ-DWR considers the Smith
Reynolds IP application on -hold until all of the additional information requested is received and
sufficiently addresses the NCDEQ-DWR's concerns.
The comments and recommendations received during the public notice are listed below for
your information and to provide you with the opportunity to respond to and/or address all of the
stated concerns. The Corps has administratively withdrawn your permit application until
your response to comments and the additional information requested by NCDEQ-DWR
are received by this office. Review and processing of your application will resume once this
information is received. Any changes to the standard permit application package initially
submitted, including revised plans and drawings, should be noted accordingly.

Comments:
The USFWS recommended, not required, the applicant to avoid any associated tree
clearing activities during the maternity roosting season from May 15th through August
15th. If tree clearing activities cannot be avoided during the maternity roosting season, the
USFWS may have preference to when tree clearing should happen during May 15th
through August 15th timeframe. Therefore, the Corps recommendations the applicant
consult with the USFWS (i.e., Byron Hamstead, Asheville Field Office) to determine
their preference on when tree clearing activities should occur during the May 15th through
August 15th maternity roosting season.
2. With respect to the project purpose, its analysis is a critical first step in the Corps
permitting process. The Corps is responsible in all cases for independently defining the
project purposes from both the applicant's and the public's perspective. Initially, the
Corps evaluates a project's "basic purpose" to assess whether the project is water
dependent. Once the Corps has determined the water dependency of the project, it no
longer considers the basic project purpose, but analyses practicable alternatives in the
light of the "overall project purpose". The overall project purpose must be specific
enough to define the applicant's need, but not so restrictive as to preclude an analysis of
all reasonable alternatives. The project purpose stated in your application is "is to enact
several development recommendations provided within the 2012 Master Plan Update
(MPU) and Airport Layout Plan (ALP) update and those requested by the Federal
Aviation Administration (FAA). These recommendations include satisfying FAA
standards and improving overall efficiency and safety at Smith Reynolds Airport." In
considering the overall project purpose, we have determined that this project purpose
does not specify the specific FAA recommendations and regulatory requirements which
necessitate the need for the proposed project. Therefore, we have determined the overall
project purpose of this project is for Smith Reynolds Airport to meet the long-term
aviation demand within the surrounding community, satisfy FAA standards, and improve
airport efficiency and safety through various projects including a taxilane extension,
facility building upgrades, hanger parking lot expansion, terrain obstruction removal, an
extension of a runway safety area, and stormwater management.
3. In Section 5.1 (Taxilane L Extension, New MRO Facilities with auto parking, and apron
expansion) you state "Smith Reynolds Airport proposes to construct a 1,650 -foot taxilane
extension and will be located on an existing concrete ramp and will provide access to the
proposed MRO hangers." These are general statements and are not specific or detailed
enough for the Corps to analyze. Therefore, please provide additional
information/specific details associated with the Taxilane L extension, but not limited to:
1) Type of construction material used; 2) Width (in feet) of taxilane; 3) Expected
volume/use of taxilane; 4) Life expectancy of Taxilane L; and 5) Maintenance and/or
repair needs and operational costs.
4. In Section 5.1 (Taxilane L Extension, New MRO Facilities with auto parking, and apron
4

expansion) you state "These hangers may be utilized in the future for air cargo and
corporate aircraft as well." These are general statements and are not specific or detailed
enough for the Corps to analyze. Therefore, please provide additional
information/specific details associated with new MRO facilities, but not limited to: 1)
The likelihood (percentage) that these hangers will be utilized by air cargo and corporate
aircrafts; and 2) If not utilized by air cargo and corporate aircrafts, what other types of
usages do these MRO facilities provide?
5. In Section 5.1 (Taxilane L Extension, New MRO Facilities with auto parking, and apron
expansion) you state "Based on 500 square feet per space, the proposed lot would provide
up to 170 spaces or approximately 56 spaces per hanger. In addition, a 242,000 square
foot concrete apron would provide aircraft space and mobility from the Taxilane L
extension to the MRO hanger facilities." These are general statements and are not
specific or detailed enough for the Corps to analyze. Therefore, please provide additional
information/specific details associated with the parking lot and apron expansion, but not
limited to: 1) Type, model, and size of aircraft utilizing the 170 spaces; 2) Life -
expectancy or need to expand in the future; and 3) What is the additional apron aircraft
space for (i.e., parking, storage, maintenance, moving safely, etc.).
6. In Section 5.2 (Runway 15-33 Obstruction Removal) you state "Obstructions in the form
of trees and excess terrain currently penetrate the runway Object Free Area and
imaginary surface planes east of Runway 15-33. In total, approximately 24.2 acres of
property would be re -graded to resolve this deficiency." These are general statements and
are not specific or detailed enough for the Corps to analyze. Therefore, please provide
additional information/specific details associated with Runway 15-33 obstruction
removal, but not limited to: 1) Number and type of trees removed; 2) Define/describe the
term excess terrain and provide amount removed in cubic yards and/or acres; 3)
Define/describe imaginary surface planes and its relation to the obstruction removal
component of the proposed project; and 4) Provide specific details related to the
improvement of an existing gravel road network (i.e., type of material used, construction
plans, etc.).
7. In Section 5.3 (Runway 22 Safety Area Extension) you state "The existing runway safety
area for Runway 22 does not meet current FAA requirements for the length of the runway
safety area that extends past the end of the runway. The runway safety area would be
extended to a total of 300 feet from the end of Runway 22 using materials from the
obstruction removal component of the proposed project." These are general statements
and are not specific or detailed enough for the Corps to analyze. Therefore, please
provide additional information/specific details associated with Runway 22 safety area
expansion, but not limited to: 1) Do you plan on using the dirt and/or trees from the
obstruction removal component of the proposed project as fill material for the Runway 22
safety area extension?
8. In Section 5.4 (Access Haul Route) you state "The proposed construction haul route
would occur entirely on airport property and would utilize a portion of an existing gravel
3

road network. Proposed permanent fill (culvert) impacts are associated with this activity."
These are general statements and are not specific or detailed enough for the Corps to
analyze. Therefore, please provide additional information/specific details associated with
the new haul road construction, but not limited to: 1) Length, width, and material used to
construct the haul road; 2) Timeframe for construction; 3) Construction plans (i.e.,
grading, tree removal, etc.); 4) Life -span of haul road (i.e., will it be utilized only for this
proposed project or will there be future usage); 5) Maintenance measures; 6). Culvert
type, diameter, and length; and 7) Length (in feet) of the existing gravel road network
that will be utilized.
9. In Section 5.5 (Erosion Control/Stormwater Basin) you state "This basin would be
converted to a stormwater retention basin upon completion of the Taxilane L extension,
new MRO facilities with auto parking, and apron expansion." These are general
statements and are not specific or detailed enough for the Corps to analyze. Therefore,
please provide additional information/specific details associated with the new erosion
control/stormwater basin, but not limited to: 1) Alternative siting locations within the
project area; and 2) wet retention basin or a dry retention basin.
10. You did not provide an Off-site Alternative analysis for the proposed project. Therefore,
please provide a brief Off-site Alternative analysis considering the following criteria: 1)
Operational; 2) Environmental; 3) Cost; and 4) Feasibility.
11. In Section 6.0 (Discussion of Alternatives), you presented only a No -Action Alternative
and the Preferred Alternative for each of the proposed project's components. This section
lacks sufficient detail and is considered incomplete. On-site alternatives that were
considered, for each component of the proposed project, need to be discussed in this
section. These additional on-site alternatives need to be evaluated based on the four
criteria presented in this section (i.e., operational, environmental, costs, and feasibility),
which were used to determine the Preferred Alternative. In addition, specific details need
to be presented as to why the other on-site alternatives, for each component of the
proposed project, were not chosen compared to the Preferred Alternative. On-site
alternatives that are determined to be reasonable and practicable will be compared to the
applicant's Preferred Alternative to determine the least environmentally damaging
practicable alternative as required by the 404(b) (1) guidelines.
12. In Section 6.1(b) (Preferred Alternative for Taxilane L extension, new MRO facilities
with auto parking, and apron expansion) there are no other alternatives discussed other
than the preferred alternative and a no -action alternative. Additional alternatives need to
be analyzed, under the same criteria as the preferred alternative, such as moving the
location of the new MRO facilities further to the north/northeast of the property and
extending Taxilane L to accommodate this new location. Also to be considered, one of
the new MRO facilities is proposed to house Forsyth Technical College's aviation
maintenance classes. Could this program be held on campus at Forsyth Technical College
thus resulting in less environmental impacts for the proposed project? Additional
information needs to be presented as to why this new college program should be held on
n

airport property, causing additional environmental impacts, and not on Forsyth
Community College campus, where infrastructure is potentially in place to accommodate
this new curriculum.
13. Section 6.2(b) (Preferred Alternative for Runway 15-33 Obstruction Removal) lacks
details on the overall plan for the 24.2 acres that is proposed to be cleared as a component
of the proposed project. Therefore, please provide additional information, such as but not
limited to: 1) plans for re -seeding cleared ground; 2) FAA requirements for re-
planting/re-seeding areas in and around runways and how the proposed project plans to
comply with those regulations; 3) ongoing maintenance operations to ensure compliance
with FAA regulations; 4) temporary and permanent sediment and erosion control
measures for the cleared 24.2 acres; and 5) any other pertinent information to minimize
adverse environmental effects in the near- and long-term for in and around the cleared
area.
14. In Section 6.3(b) (Preferred Alternative for Runway 22 Safety Area Extension) you state
"According to FAA design criteria set forth in FAA Advisory Circular, Runway 22
requires a runway safety area of 150 feet wide and 300 feet in length. The current runway
safety area is 150 feet wide (meets FAA design criteria) and 130 feet in length (does not
meet FAA design criteria)." The preferred alternative extends the Runway 22 safety area
over 1,000 feet and widens it over 150 feet, both exceeding the criteria for runway safety
areas set by the FAA. You need to analyze an on-site alternative for the Runway 22
safety area that includes only expanding the current safety area another 170 feet, to meet
the FAA criteria of 300 feet in length and not widening it past 150 feet. This additional
alternative could potentially have less permanent stream and wetlands impacts and needs
to be justified as to why the applicant chose the preferred alternative, with potentially
more stream and wetland impacts, then this new on-site alternative.
15. You did not provide an alternatives analysis on the construction of the new haul road
component of the proposed project. Therefore, please provide an alternatives analysis to
include the following: 1) a no -action alternative; 2) preferred alternative; and 3) on-site
alternative (which could include a different configuration of the haul road which may or
may not increase stream and wetland impacts compared to the preferred alternative).
Please make sure to include specific details, such as length, width, material used,
lifespan, maintenance, usage, etc., for both the preferred alternative and the additional on-
site alternative.
16. You did not provide an alternatives analysis on the construction of the erosion
control/stormwater basin component of the proposed project. Therefore, please provide
an alternatives analysis to include the following: 1) a no -action alternative; 2) preferred
alternative; and 3) on-site alternative. The additional on-site alternative needs to analyze
the different configurations (i.e., size and shape) of stormwater basin, using multiple
basin throughout the proposed project area versus the preferred one large basin, and
different locations for the one large stormwater basin compared to the preferred
alternative. Please make sure the additional on-site alternative compares streams and
5

wetland impacts to the preferred alternative and why the preferred alternative was chosen
over the additional on-site alternative.
17. In Section 6.4 (Avoidance and Minimization) it is not clear what constraints were
considered and how the applicant has avoided and minimized impacts to streams and
wetlands to the greatest extent practicable and feasible while still accomplishing the
overall project purpose. Once Comments 3 through 15 are answered with more detail,
which should also enhance the alternatives analysis, the Corps may feel more confident
the applicant has avoided and minimized impacts to streams and wetlands to the greatest
extent practicable and feasible. If the additional information does not support the
applicant's avoidance and minimization analysis, then the Corps reserves the right to
request additional information, at that time.
18. The compensatory mitigation ratio (1:1) for all stream and wetland impacts is not
sufficient to offset the environmental losses resulting from the unavoidable impacts to the
previously mentioned streams and wetlands within the proposed project area.
Compensatory mitigation must be commensurate with the amount and type of impact.
The proposed project plans to impact nine wetlands totaling 1.13 acres and seven stream
totaling 4,079 linear feet, resulting in a loss of over 63 percent of wetland acreage and
over 43 percent of linear feet of stream, respectively. Stream and wetland quality
assessments (i.e., North Carolina Stream Assessment Methodology and North Carolina
Wetland Assessment Methodology) were conducted to determine the level of function of
streams and wetlands within the proposed project area relative to reference condition. A
ratio of less than 2:1 is justified based on the lower quality of the impacted wetlands.
However, all seven streams were perennial with medium to high ratings. Therefore, the
Corps proposed the following compensatory mitigation ratios: 1) 1.5:1 for Wetland
Impacts #4, #6, #8, #9, #10 and #13; 2) 1.75:1 for Wetland Impacts #1, #2, and #5; and 3)
2:1 for Stream Impacts #3, #7, # 11, # 12, # 14, # 15, and # 16. Please revise your
Compensatory Mitigation Plan to reflect these changes in compensatory mitigation ratios
for all impacted streams and wetlands.
19. Please revise Section 7.0 (Conceptual Mitigation Plan) to represent the current North
Carolina, Department of Environmental Quality's Current Rate Schedules for streams
and wetlands. As of July 1, 2018, the cost for one linear foot of stream credit is $507.32
and $60,187.45 for one acre of wetland (riparian and non -riparian) credit within the
Yadkin service area (i.e., HUC 03040101). Therefore, based on the newly revised
Current Rate Schedule, the proposed project compensatory mitigation costs would be as
follows: 1) Stream Impacts #3, #7, #11, #12, #14, #15, and #16 = $4,138,717; 2) Wetland
Impacts #4, #6, #8, #9, #10 and #13 = $153,478; and 3) Wetland Impacts #1, #2, and #5
_ $8,742; for a total of $4,300,937. This total was generated by calculating the costs of
stream credits at a ratio of 2:1 for 4,079 linear feet, low -quality wetland credits at a ratio
of 1.5:1 for 1.05 acres, and medium -quality wetland credits at a ratio of 1.75:1 for 0.083
acre.
20. Please provide a copy of the North Carolina Stream Assessment Methodology, including
1.1

the Field Assessment Results Form (Version 2.1) and Stream Rating Sheet (Version 2.1)
for stream Impacts #15 and #16.
If you have any questions regarding these matters, please contact me at [phone] or
bryan.roden-re. n�&usace.g,M.mil.
Sincerely,
Bryan Roden -Reynolds
Regulatory Program Manager
Charlotte Field Office
7

Enclosures:
1. Table 1. Comments in Response to the Public Notice
2. NMFS Comment Letter Dated August 24, 2018
3. USFWS Comment Letter Dated September 11, 2018
4. NCDEQ-DWR Comment Letter Dated September 21, 2018
5. NCDEQ-DWR Additional Information Request Dated September 21, 2018
6. NC Senator Paul A. Lowe Jr. Comment Letter Dated September 24, 2018
7. NCWRC Comment Letter Dated September 24, 2018
8. Yadkin Riverkeeper Comment Letter Dated September 24, 2018
9. General Public (i.e., Jackie Milton Johnson, Deborah Daniels, and Mount Sinai Full
Gospel Deliverance Center) Dated September 21 and 24, 2018
Copies Furnished (via email):
Clement Riddle — Clearwater Environmental, Inc.
Byron Hamstead — USFWS
Sue Homewood — NCDEQ—DWR
Senator Paul A. Lowe Jr. — North Carolina Senator
Olivia Munzer — NCWRC
Brian Fannon — Yadkin Riverkeeper

Table 1. Comments in Response to the Public Notice
Date of Comment Letter
4F V Commenter
Comment 11
Recommendation
August 24, 2018
National Oceanic and Atmospheric
Based on the information in the public notice, the proposed project would
N/A
Administration, National Marine
not occur in the vicinity of essential fish habitat. Present staffing levels
Fisheries (NMFS)
preclude further analysis of the proposed work and no further action is
planned. This position is neither supportive or nor in opposition to
authorization of the proposed work.
September 11, 2018
United States Department of Interior,
1). The Applicant propose to mitigate for impacts to streams and wetlands
1). Although not required, we encourage you to avoid any associated tree
Fish and Wildlife Service (FWS)
at a 1:1 ratio via NCDMS In -Lieu Fee Program. We believe that the stream
clearing activities during the maternity roosting season from May 15 —
and wetland assessment forms (i.e., NCSAM and NCWAM) support the
August, if possible.
need for at least a 2:1 mitigation ratio.
2). Instream work (e.g. haul road culverts) should occur under dry
2). In the event that sufficient mitigation credits are not available within
conditions utilizing a temporary diversion/pump-around system.
the project's watershed and the Applicant resorts to permittee -responsible
mitigation, we request that a complete mitigation plan be submitted to this
3). Grading and backfilling should be minimized, and existing native
office for review. The FWS maintains that compensatory mitigation should
vegetation should be retained (if possible) to maintain riparian cover for
be provided within the watershed where impact originate (HUC
fish and wildlife. Disturbed areas should be re -vegetated with native grass
03040101).
and tree species.
3). Since the purpose of stormwater control is to protect streams and
4). Ground disturbance should be limited to what will be stabilized
wetlands, no stormwater control measures or best management practices
quickly, preferably by the end of the workday.
should be installed within any stream (perennial or intermittent) or
wetland.
5). Natural fiber matting (i.e., coir) should be used for erosion control as
synthetic netting can trap animals and persist in the environmental beyond
its intended purpose.
6). We recommend that retention ponds be located at least 750 feet from
wetlands to minimize hydrologic disturbance and ecological function.
September 21, 2018
North Carolina Department of
1). Based on information provided in the applicant, as well as current
1). NCDEQ has requested additional information in a letter titled Request
Environmental Quality
aerial imagery, it appears that construction may have begun on this project.
for Additional Information and Dated September 21, 2018. In this letter,
If the project has begun, the applicant should be informed that activities
NCDEQ has determined that the applicant's IP applicant is
already conducted will not be considered in review of this project.
incomplete and cannot be processed. The application is on -hold until
all the following information requested in that letter is received.
2). The purpose and need for the Runway 15-33 Obstruction Removal
portion of this project does not clearly detail why the applicant cannot
2). The NCDEQ Stormwater Design Manual includes many options for
make sufficient use of their property without impacts to the wetlands or
permanent stormwater control measures for consideration by the applicant.
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.
3). The applicant has not provided a detailed on-site alternative 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 (i.e., number of hangers, number of parking spaces,
size of apron, etc.) or an on-site alternatives analysis that discusses the use

Date of Comment Letter
Commenter
lComment
Recommendation
of uplands within the existing property lines.
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 area
only temporary in nature and therefore these impacts should be considered
temporary if they are found to be justified.
September 21, 2018
General Public (Jackie Milton
We are concerned that the airport project will increase the rain water
N/A
Johnson)
runoff into the stream and cause further damage. When the trees on the
airport were cleared is when we started experiencing more problems (i.e.,
wild turkey, deer, and more erosion). Now we are trying to protect our
property but the stream gets high enough to was out the rocks that were put
in to protect property. If more water is sent into the stream, we are very
concerned that it will wash out our property. We ask that a closer look is
taken of the stream and the impacts and that we have a better
understanding of where all the new runoff is going before the project
starts.
September 24, 2018
North Carolina Senator Paul A.
Requests a public hearing from the North Carolina Division of Water
N/A
Lowe, Jr.
Resources to discuss the health, environmental and safety concerns with
residents that will be impacted by the scheduled work plan.
September 24, 2018
General Public (Deborah Daniels)
Requests that due diligence be implemented and that a hearing be held to
N/A
discuss the impact of this project in simple English to be transparent to the
physical and environmental impact.
September 24, 2018
North Carolina Wildlife Resources
As indicated in our scoping comments, dated June 16, 2017, we have
1). Minimize impacts streams and wetlands by redesigning aspects of the
Commission
concerns regarding the amount of impacts to wetlands and streams and its
project. We understand FAA and other limitations can guide development
effects on aquatic ecosystems.
at an airport. However, alternatives for different configurations of the
project were not provided in the IP. For example, consider relocating
1). The IP indicates "the dredge and fill of streams and wetlands will have
the erosion control/stormwater basin or MRO facilities and parking to
minor to no effects on aquatic organisms, physical and chemical
reduce impacts to streams and wetlands.
characteristics of the aquatic system, and wetlands." However, the dredge
and fill of wetlands and streams can have significant adverse direct and
2). We recommend a bottomless culvert or bridge rather than a circular
indirect impacts on aquatic ecosystems. The streams to be filled have an
culvert.
NCSAM rating of high or medium. In general, placing fill in aquatic
resources can alter hydrology, result in significant negative impacts to
3). Limit impervious surface to less than 10% or use stormwater control
downstream areas, and eliminate aquatic and terrestrial wildlife habitat.
measures to mimic the hydrograph consistent with an impervious coverage
Additional impervious surface results in an increase in stormwater runoff
of less than 10%.
that can exert significant impacts on stream morphology. In addition,
pollutants washed from developed landscapes can adversely affect
4). Sediment and erosion control measures should be installed prior to any
extirpate species downstream.
land clearing or construction. The use of biodegradable and wildlife-

Date of Comment Letter
Commenter
lComment
0001kecommendation
friendly sediment and erosion control devices is strongly recommended.
2). NCSAM forms were completed for Impacts #15 and #16. Please
Silt fencing, fiber rolls, and/or other products should have loose -weave
provide these forms for the two impacts or explain the absence of the
netting that is made of natural fiber natural materials with movable joints
forms.
between the vertical and horizontal twines.
September 24, 2018
Yadkin Riverkeeper
The neighbors reported that erosion has accelerated recently and feel that
N/A
the land clearing on the airport property may have contributed to higher
stormwater runoff. Upon examination of aerial photography, evidence of
erosive patterns is visible in the cut -over area, with no apparent runoff or
sediment structures in place upstream of the impacted area. The Yadkin
Riverkeeper could find no indication plans for handling the increased
runoff from the project and its final destination.
September 24, 2018
General Public (Mount Sinai Full
We are gravely concerned about the potential impact of any airport
N/A
Gospel Deliverance Center)
expansion on residents, businesses, and particularly on the community
revitalization currently in progress. Health, environmental, and safety
concerns are paramount as well as our prolonged and extensive
investments in the redevelopment of the area; all of which will be seriously
jeopardized by the project

(Sent via Electronic Mail)
Colonel Robert J. Clark, Commander
USACE Wilmington District
69 Darlington Avenue
Wilmington, North Carolina 28403-1398
Dear Colonel Clark:
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Ad ministration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
26313th Avenue South
St. Petersburg, Florida 33701-5505
http:ltsera. n mfs. noaa.gov
August 24, 2018
NOAA's National Marine Fisheries Service (NMFS) reviewed the project described in the public
notice listed below. Based on the information in the public notice, the proposed project would
NOT occur in the vicinity of essential fish habitat (EFH) designated by the South Atlantic
Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS.
Present staffing levels preclude further analysis of the proposed work and no further action is
planned. This position is neither supportive of nor in opposition to authorization of the proposed
work.
Notice No. Applicant(s) Notice Date Comment Due Date
SAW -2017-01312 Airport Commission of August 24, 2018 September 24, 2018
Forsyth County
Please note these comments do not satisfy consultation responsibilities under section 7 of the
Endangered Species Act of 1973, as amended. If an activity "may effect" listed species or critical
habitat under the purview of the NMFS, please initiate consultation with the Protected Resources
Division at the letterhead address.
Sincerely,
Pace Wilber for
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division

ua
FTM &AVTLIHIFE
United States Department of the InteriorSERVIUE
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa StreetFl
Asheville, North Carolina 28801
September 11, 2018
Bryan Roden -Reynolds
USACE Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
Dear Mr. Roden -Reynolds:
Subject: Smith Reynolds Airport Expansion Project; Forsyth County, North Carolina
Log No. 4-2-17-417
The U.S. Fish and Wildlife Service (Service) has reviewed the information provided in the public
notice and associated materials issued August 24, 2018. The Service provided scoping
comments directly to the Applicant June and September, 2017. We submit the following
comments in accordance with the provisions of the Fish and Wildlife Coordination Act, as
amended (16 U.S.C. 661-667e); the National Environmental Policy Act (42 U.S.C. §4321
et seq.); and section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C.
1531-1543) (Act).
Project Description
According to the information provided, the proposed airport expansion project would occur on
94 acres in Winston-Salem, North Carolina. The project aims to satisfy modern FAA standards
and to improve safety and the overall efficiency of the development. Specifically, the Airport
Commission of Forsyth County proposes to 1) expand Taxilane L, Runway 22, and existing
maintenance facilities; 2) clear obstructions (terrain and vegetation) within a 24.2 acre Object -
Free Area; and 3) install a haul road and erosion control basin (to be converted for stormwater
management post -construction). The proposed activities would impact approximately 43% of
onsite streams and 63% of onsite wetlands, resulting in fill of 4,079 linear feet of perennial
stream and fill of 1.13 acres of wetlands (headwater forest and bottomland hardwood). The
Applicant proposes to mitigate for stream and wetland impacts at a 1:1 ratio via NCDMS In -Lieu
fee program. The public notice indicates that sufficient mitigation credits from private
mitigation banks within the watershed were not available within the watershed at the time of the
Applicant's request.
Federally Listed Endangered and Threatened Species
According to Service records, suitable summer roosting habitat may be present in the project
area for the federally threatened northern long-eared bat (Myotis septentrionalis). However, the
final 4(d) rule (effective as of February 16, 2016), exempts incidental take of northern long-eared

bat associated with activities that occur greater than 0.25 miles from a known hibernation site,
and greater than 150 feet from a known, occupied maternity roost during the pup season (June 1
— July 31). Based on the information provided, the project (which may or may not require tree
clearing) would occur at a location where any incidental take that may result from associated
activities is exempt under the 4(d) rule. Although not required, we encourage you to avoid
any associated tree clearing activities during the maternity roosting season from May 15 —
August 15 if possible.
The permit application indicated that suitable habitat was identified within the project area for
the federally endangered small-anthered bittercress (Cardamine micrathera), but that surveys
conducted in March and April 2014 did not detect this species. While historic records for this
riparian plant occur in Forsyth County, North Carolina, current records are known only from the
Dan River basin which is outside of the project area.
Based on the information provided, the Service does not have any concerns for any other
federally protected species. Please be aware that obligations under section 7 of the Act must be
reconsidered if. (1) new information reveals impacts of this identified action that may affect
listed species or critical habitat in a manner not previously considered, (2) this action is
subsequently modified in a manner that was not considered in this review, or (3) a new species is
listed or critical habitat is determined that may be affected by the identified action.
Compensatory Mitigation
In the interest of protecting natural resources, every effort should be made to avoid/minimize
impacts to streams and wetlands. The Applicant should be aware that effective July 1, 2018, the
NCDMS fee schedule has been modified. The Airport Commission of Forsyth County proposes
to mitigate for impacts to streams and wetlands at a 1:1 ratio via NCDMS In -Lieu Fee Program.
We believe that the stream and wetland assessment forms (NCSAM and NCWAM) support the
need for at least a 2:1 mitigation ratio. Approximately 33% of proposed stream impacts (1,363
linear feet) are represented by an overall "high" NCSAM rating.
In the event that sufficient mitigation credits are not available with the project's watershed and
the Applicant resorts to permittee -responsible mitigation, we request that that a complete
mitigation plan be submitted to this office for review. The Service maintains that compensatory
mitigation should be provided within the watershed where impacts originate (03040101).
Erosion and Sediment Control
Measures to control sediment and erosion should be installed before any ground -disturbing
activities occur. Instream work (e.g. haul road culverts) should occur under dry conditions
utilizing a temporary diversion/pump-around system. Grading and backfilling should be
minimized, and existing native vegetation should be retained (if possible) to maintain riparian
cover for fish and wildlife. Disturbed areas should be revegetated with native grass and tree
species. Ground disturbance should be limited to what will be stabilized quickly, preferably by
the end of the workday. Natural fiber matting (coir) should be used for erosion control as
synthetic netting can trap animals and persist in the environment beyond its intended
purpose.
2

Impervious Surfaces and Low -Impact Development
The Service is concerned about the potential stormwater-mediated impacts to streams and
wetlands onsite. Where detention ponds are used, storm -water outlets should drain through a
vegetated area prior to reaching any natural stream or wetland area. Detention structures should
be designed to allow for the slow discharge of storm water, attenuating the potential adverse
effects of storm -water surges; thermal spikes; and sediment, nutrient, and chemical discharges.
Since the purpose of storm -water -control is to protect streams and wetlands, no
storm -water -control measures or best management practices should be installed within any
stream (perennial or intermittent) or wetland. We recommend that retention ponds be located
at least 750 feet from wetlands to minimize hydrologic disturbance and ecological function.
We also recommend that consideration be given to the use of pervious materials (i.e., pervious
concrete, interlocking/open paving blocks, etc.) for the construction of roads, driveways,
sidewalks, etc. Pervious surfaces minimize changes to the hydrology of the watershed and can
be used to facilitate groundwater recharge. Pervious materials are also less likely to absorb and
store heat and allow the cooler soil below to cool the pavement. Additionally, pervious concrete
requires less maintenance and is less susceptible to freeze/thaw cracking due to large voids
within the concrete.
The Service appreciates the opportunity to provide these comments. Please contact Mr. Byron
Hamstead of our staff at 828/258-3939, Ext. 225, if you have any questions. In any future
correspondence concerning this project, please reference our Log Number 4-2-17-417.
Sincerely,
- - original signed - -
Janet Mizzi
Field Supervisor
Ex: Mark Davidson; Airport Commission of Forsyth County
Clement Riddle; CWE
Kaylie Yankura; CWE
Sue Homewood; NCDWR
Olivia Munzer; NCWRC
3

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

NORTH CAROLINA
ROY COOPER Environmental Quality
Gove"W
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Dlrector
September 21, 2018
DWR It 20021139 v2
Forsyth County
Airport Commission of Forsyth County
Attn: Mr. Mark Davidson, Airport Director
2801 N. Liberty St
Winston-Salem, NC 27105
Subject: REQUEST FOR ADDITIONAL INFORMATION
Smith Reynolds Airport
Dear Mr. Davidson;
On August 13, 2018, the Division of Water Resources — Water Quality Programs (Division)
received your application dated June 27, 2018, requesting an Individual Water Quality
Certification from the Division for your 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. The application states that project construction is estimated to begin on July 1, 2018.
Clarify what portions of this project have begun prior to submittal of this application. In
addition, based on available aerial imagery, it appears that the majority of the proposed
Haul Road has been constructed at this time. Please provide more information about
the current status of the Haul Road and whether there are existing impacts to streams
or wetlands from the Haul Road. Clarify why the Haul Road is proposed as permanent
impacts rather than temporary construction impacts, and what options were
investigated for further avoidance and minimization of impacts resulting from the Haul
Road. (15A NCAC 02H .0506(b)]
2. Provide a more detailed purpose and need for the Runway 15-33 Obstruction Removal
and Grading portion of the proposed project. The FAA inspection documentation
provided with your application indicates that trees are present within the Object Free
Area and must be removed. Tree clearing may occur without grading impacts to
wetlands and/or streams, or with minimum temporary impacts. The application does
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

Smith Reynolds Airport
DWR# 20021139 v2
Request for Additional Information
Page 2 of 3
not provide sufficient justification for re -grading of a large area to support this purpose
and need. Please revise the plans to minimize the impacts or provide a detailed
explanation of why the proposed plan for the activity cannot be practically
accomplished, reduced or reconfigured to better minimize disturbance to the wetlands.
[15A NCAC 02H .0506(f) and (g)] [15A NCAC 02H .0506(b)]
3. Provide more details regarding avoidance and minimization for the impacts associated
with the proposed New MRO Facilities with Auto Parking and Apron Expansion. It
appears that there are uplands within the airport property that have the potential to
support these needs, a portion of these needs, or an alternative layout which could
potentially minimize impacts to stream and wetlands. In addition, provide details of
how the how parking space needs were determined. Please revise the plans to
minimize the impacts or provide a detailed explanation of why the proposed plan for
the activity cannot be practically accomplished, reduced or reconfigured to better
minimize disturbance to the wetland. [15A NCAC 02H .0506(f) and (g)]
4. Provide a site plan with the proposed projects as overlays including jurisdictional
features (combine Figure 3.0 and 3.1). Clearly show building/parking envelopes,
proposed grading topography, stormwater control measures, and all temporary impacts
for erosion control and/or construction access clearly on all plans. Please provide these
plans at a scale that is sufficiently clear for our review. [15A NCAC 02H .0502(g)]
5. Clarify whether the Division of Energy, Mineral and Land Resources will require riprap
within any stream channels or wetlands as part of the Erosion & Sedimentation Control
Plan approval (including temporary impacts from lake dewatering discharge). If riprap is
required, enumerate and clearly label the temporary and permanent impacts on the site
plan and submit a channel restoration detail. Riprap must be located below the stream
bed elevation. [15A NCAC 02H .0506(f) and (g)]
Clarify if the City of Winston-Salem will be reviewing and approving a Phase II post
construction stormwater management plan for this project. Please note that NCGS 143-
214.7 indicates that the use of stormwater control measures that promote standing
water is not preferable within a 5 -mile radius of airports. [15A NCAC 02H .0506(f) and
(g)]
7. Provide an avoidance and minimization analysis for Impact #15 resulting from a
temporary sediment basin. Your response should include documentation from the
appropriate review agency that the proposed location and size of the sediment basin is
the only option available that will satisfy the regulatory program. Please note that
sediment and erosion control measures are temporary measures and the area may be
restored to natural conditions upon project completion. [15A NCAC 02H .0506(f) and
(g)]

Smith Reynolds Airport
DWR# 20021139 v2
Request for Additional Information
Page 3 of 3
8. Provide an avoidance and minimization for Impact #15 resulting from a permanent
stormwater wet pond. Your response should include documentation from the
appropriate review agency that the proposed location and type of SCM is the only
practicable option available that will satisfy the regulatory program. [15A NCAC 02H
.0506(f) and (g)]
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 all of the above requested information through
this link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note that the
DWR# that is requested on the link is referenced above) or by sending one copy of all of the
above requested information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center,
Raleigh, NC 27699-1617.
If all of the requested information is not received in writing within 30 calendar days of receipt
of this letter, the Division will be unable to approve the application and it will be returned. The
return 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 Water Quality Certification Rules 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 336-776-9693 or Sue. [e-mail] if you have
any questions or concerns.
Sincerely, _
Karen Higgins, Supervis
401 & Buffer Permitting Unit
cc: Clement Riddle, ClearWater Environmental (via email)
Bryan Roden Reynolds, USACE Charlotte Regulatory Field Office (via email)
Olivia Munzer, NCWRC (via email)
Byron Hamstead, USFS (via email)
DWR ARO 401 files
DWR 401 & Buffer Permitting Unit
Filename: 021139v2SmithReynoldsAirport(Forsyth)_IC_HOLD

NORT- fCA12OLIX4 GEAERALASSEWBLT
North Carolina Senate
1119 Legislative Bui(fing
16 West ]ones Street
l?tleigh, North Carolina 27601-2808
SENATOR PAUL A. LOWE, JR.
32ND DISTRICT
TELEPHONE: [phone]
[phone] FAX
E-MAIL ADDRESS: [e-mail]
September 23, 2018
Bryan Roden -Reynolds
Regulatory Project Manager
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Dear Mr. Roden -Reynolds:
COMMITTEES:
APPROPRIATIONS/BASE BUDGET
APPROPRIATIONS ON HEALTH AND HUMAN
SERVICES
HEALTH CARE
JUDICIARY
RULES AND OPERATIONS OF THE SENATE
I am writing this letter in response to the Proposed Project as described in the public
notice that was sent to property owners immediately adjacent to the Smith Reynolds
Airport in Forsyth County, North Carolina. As a public official serving Senate District
32 and as a resident of this community, I am requesting a public hearing from the North
Carolina Division of Water Resources to discuss the health, environmental and safety
concerns with the residents that will be impacted by the scheduled work plan.
Your favorable consideration to this request will be most appreciated. Please feel free to
contact me should you need any additional information. I look forward to hearing from
you soon.
Sincerely,
Senator Paul A. Lowe Jr.
North Carolina State Legislator
NC Senate District 32

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
24 September 2018
Mr. Bryan Roden -Reynolds
Regulatory Project Manager
U.S. Army Corps of Engineers
Charlotte Regulatory Office
8430 University Executive Park Drive
Charlotte, NC 28262
Subject: Individual Permit Application for the Smith Reynolds Airport Expansion Project, Forsyth
County; USACE Action ID SAW -2017-01312.
Dear Mr. Roden -Reynolds,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
Individual Permit (IP) application. Comments are provided in accordance with provisions of the Clean
Water Act of 1977 (as amended) and Fish and Wildlife Coordination Act Wildlife Coordination Act (48
Stat. 401, as amended; 16 U.S.C. 661 et seq.).
The Airport Commission of Forsyth County proposes to expand within the boundaries of Smith Reynolds
Airport in Winston-Salem, Forsyth County, North Carolina. The proposed project would entail the 1,650 -
foot extension of Taxilane L; new aircraft maintenance, repair and overhaul (MRO) facilities; MRO auto
parking and apron expansion; Runway 15-33 obstruction removal; Runway 22 safety area extension; new
haul road; and construction of an erosion control/stormwater basin. The proposed project would impact
approximately 1. 13 acres of wetlands and 4,079 linear feet of streams.
Bushy Fork and its unnamed tributaries flow through the site. Brushy Fork in the Yadkin River basin is
classified as a Class C stream by the NC Division of Water Resources. We have no records of federally
or state -protected species at or adjacent to the site; however, the lack of records does not imply or confirm
the absence of federal or state -listed species. Clearwater Environmental Consultants, Inc. (CEC)
conducted a federal threatened and endangered species review and habitat assessment for the site. CEC
did not observe suitable habitat for and/or individuals of red -cockaded woodpecker (Picoides borealis;
federally endangered), small-anthered bittercress (Cardamine micranthera; federally endangered), bog
turtle (Clemmys muhlenbergii; federally threatened S/A), northern cup plant (Silphium perfoliatum; state
threatened), or purple fringeless orchid (Platanthera peramooena; state threatened). CEC included the
brook floater (Alasmidonta varicose), a federal at -risk species and state endangered mollusk, as having
the potential to occur at the site, but CEC did not report their results of the surveys and habitat assessment
for this species in the report. NCWRC has an information gap for the state special concern Greensboro
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

24 September 2018
Smith Reynolds Airport Expansion Page 2
USACE Action ID: SAW -2017-01312
burrowing crayfish (Cambarus catagius) and state significantly rare Carolina ladle crayfish (Cambarus
davidi) in Forsyth County. T.R. Russ, the NCWRC foothills aquatic diversity coordinator, is requesting
crayfish surveys or for NCWRC to survey the site. Contact Mr. Russ at 828.803.6035 or
thomas.russgncwildlife.org to coordinate crayfish surveys.
As indicated in our scoping comments (NCWRC 16 June 2017), we have concerns regarding the amount
of impacts to wetlands and streams and its effects on aquatic ecosystems. Please see the following
comments on the IP:
Development impacts are occurring throughout North Carolina at unprecedented rates. Water
quality issues already exist due to "sprawl" around urbanized areas. Increased population and
development impacts are causing unmitigated loss of stream headwaters and forested ecosystems
through "site stripping" practices that pipe and pave geologically and biologically functioning
ecosystems without consideration of direct and indirect impacts to our environment. Headwater
streams, such as these, can significantly reduce nutrient export to rivers (Alexander et al. 2000;
Peterson et al. 200 1) and the condition of the stream in the lower reaches is closely dependent on
the condition in the headwaters (Vannote et al. 1980).
The IP indicates the dredge and fill of streams and wetlands will have minor to no effects on
aquatic organisms, physical and chemical characteristics of the aquatic ecosystem, and wetlands.
However, the dredge and fill of wetlands and streams can have significant adverse direct and
indirect impacts on aquatic ecosystems. According to the NC Stream Assessment Method
(NCSAM) forms included in the IP, the streams to be filled have a functional rating of high or
medium. In general, placing fill in aquatic resources can alter hydrology, result in significant
negative impacts to downstream areas, and eliminate aquatic and terrestrial wildlife habitat.
Additional impervious surface results in an increase in stormwater runoff that can exert
significant impacts on stream morphology. This will cause further degradation of aquatic habitat
through accelerated stream bank erosion, channel and bedload changes, altered substrates, and
scouring of the stream channel. In addition, pollutants (e.g., sediment, heavy metals, pesticides,
and fertilizers) washed from developed landscapes can adversely affect and extirpate species
downstream.
2. NCSAM forms were not completed for Impacts #15 and #16. We recommend these forms be
completed for these two streams or explain the absence of the forms. Impact #16 is from the fill
of 671f of stream and Impact #15 is the fill of 5261f of stream for the construction of an Erosion
Control/Future Stormwater Basin.
3. Minimize impacts to streams and wetlands by redesigning aspects of the project. We understand
Federal Aviation Administration and other limitations can guide development at an airport.
However, alternatives for different configurations of the project were not provided in the IP. For
example, consider relocating the erosion control/stormwater basin or MRO facilities and parking
to reduce impacts to streams and wetlands.
4. We recommend a bottomless culvert or bridge rather than a circular culvert.
5. Limit impervious surface to less than 10% or use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10%.
6. 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 or similar materials that have been reinforced with
plastic or metal mesh should be avoided as they impede the movement of terrestrial wildlife

24 September 2018
Smith Reynolds Airport Expansion Page 3
USACE Action ID: SAW -2017-01312
species. Excessive silt and sediment loads can have detrimental effects on aquatic resources
including destruction of spawning habitat, suffocation of eggs and clogging of gills.
Thank you for the opportunity to review and comment on this project. If I can be of further assistance or
free technical guidance, please contact me at [phone] or olivia.munzer&ncwildlife.org.
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
Ec: T.R. Russ, NCWRC
Mark Davidson, Airport Commission of Forsyth County
R. Clement Riddle, CEC
Sue Homewood, NCDWR
Byron Hamstead, U.S. Fish and Wildlife Service

Smith Reynolds Airport Project
Impacts to the Barkwood Neighborhood adjoining Brushy Fork
Comments From Brian Fannon, Yadkin Riverkeeper
[e-mail]
[phone]
On September 181h, 2018, 1 was contacted by Jackie Glover of the Barkwood Neighborhood in
Winston Salem, adjoining the Smith Reynolds Airport. Ms. Glover had received a notice of
comment period on the airport construction project, and was unsure as to whom to contact to
help her and her neighbors with concerns about erosion on Brushy Fork, running behind several
houses in the neighborhood. I met Ms. Glover and her neighbor Ms. Johnson that evening, and
they discussed their concerns about increasing property loss due to erosion from Brushy Fork,
and how it had increased considerably over the last year, in the same time frame that timber
had been cleared from the airport property.
I traversed the stream channel area, and noted that the stream has suffered from considerable
erosion, including the loss of a large tree rootwad and associated soil (fig. 1). Ms. Glover stated
that originally her yard had extended several feet beyond the current streambank in this area,
and that the tree had not been on the streambank until it eroded back to it.

9 yy
R „�'~� �.kx.. t 1 � ., � � .7 •� � � 1: �� rev `
�•!.
IZ
� � �' ��� ars ,:b e � � - � '4. � l I � � � _ - � ti ,� � > �.p•..
v � a
R -

The neighbors reported that erosion has accelerated recently, and feel that the land clearing on
the airport property may have contributed to higher stormwater runoff. Upon examination of
aerial photography, evidence of erosive patterns is visible in the cut -over area, with no
apparent runoff or sediment structures in place upstream of the impacted area. (fig. 5).
Fig. 5.
Impacted area.
The neighbors are very concerned about this apparently overlooked impact on their property,
and in reviewing the public documents I could find no indication plans for handling the
increased runoff from the project and its final destination. Brushy Fork is already handling more
flow than it can sustain in a stable manner during runoff events, and the addition of more
stormwater to this creek, through direct piping or land runoff, stands to damage these
properties (and likely other properties downstream) unless mitigating action is taken to protect
them, and indeed, their situation calls for attention sooner rather than later due to the current
impacts on their properties.

September 21, 2018
To Whom It May Concern:
Concerning the Smith Reynolds Airport Project, we have received your notification letter and the
information on the airport project. We are very concerned about the impact of this project on our
neighborhood. Many of us have lived here for over 40 years. The stream that run thru our
neighborhood (Brushy Fork) has always had a small amount of erosion. Over the past year, it has sped
up dramatically, taking land and trees, and threatening some backyard buildings, as well as creating sink
holes in the back yards.
We are very concerned that the airport project will increase the rain water runoff into the steam, and
cause further damage. When the trees on the airport were cleared is when we started experiencing
more problems... wild turkeys, deer's and more erosion. Now we are trying to protect our property, but
the stream gets high enough to wash out the rocks that were put in to protect property. If more water
is sent into the stream, we are very concerned that it will wash out our property. We ask that a closer
look is taken of the steam and the impacts, and that we have a better understanding of where all the
new runoff is going to go before the project starts.
Respectfully,
�ac�ie7` �fton�o�inson

3020 Bainbridge Drive
Winston-Salem NC 27105
September 24, 2018
Bryan Roden -Reynolds
Regulatory Project Manager
Regulatory Field Office ROOM 208
151 Patton Avenue
Asheville NC
Dear Mr. Roden -Reynolds:
I am in receipt of the public notice regarding the expansion of Smith Reynolds
Airport. I am very concerned that this project has not been properly explained
to the residents affected.
There obviously has already been some preliminary work done via excavation in
preparation for the project. The neighborhood has seen an increase in the
wildlife whose habitats have already been disturbed on our properties and in
the streets. How is the old Evergreen Cemetery affected which also bordering
the property? Additionally, we have observed soil deposits from water run-off. It
has also come to our attention that a landfill adjacent to neighborhood
properties will also be upset. Noise pollution has been an ongoing concern,
including the noise level and the times of planes land and take off.
I have reviewed the public notice which is written in such complicated and
technical language that it is incomprehensible. The maps are ambiguous and
do not delineate the actual 70-80 residences directly affected by the project.
Last week neighbors learned that the jurisdiction of the Smith Reynolds Airport
has been transferred from the Airport Commission to the Forsyth County
Commissioners. It is my opinion that the neighborhood residents should have
been properly notified of this change. The residents in the affected African-
American communities deserve to hear the details and to have their voices
heard.
I am requesting that due diligence be implemented and that a hearing be held
to discuss the impact of this project in simple English to be transparent to the
physical and environmental impact. Hopefully this hearing will include
representatives from the various governmental bodies, i.e. city, county, state,
and federal. Many residents work during the day. Therefore, I am requesting
that the times of the hearing reflect the opportunity for working persons to

attend. We deserve to be heard and the informed about what is going on
which impact the values of our homes and our quality of life.
Thank you for your favorable response to this request. I am available at the
above address or at [phone] or dtdanielsl @yahoo.com
Sincerely,
1�5ebor2 k T. �a v�,LeLs
Deborah T. Daniels
cc: Mark Davidson
R. Clement Riddle
David R. Plyler
Paul Lowe
Derwin Montgomery
Vivian Burke

LL)ikiw tl" Linc
11n, Yvolglc il, hlu
A" p�w ju& &6_6�rw- (&Mmr
2721 Manchester Street Winston-Salem, NC 27105
Phone: [phone] Email: [e-mail] Fax: [phone]
mountsinaifullgospel.org
Bishop J. L. Hines (The Late), Founder
Pastor Yvonne H. Hines, Senior Presbyter
September 24, 2018
Mr. Bryan Roden -Reynolds
Regulatory Project Manager
Corps of Engineers, Wilmington District
Asheville Field Office
151 Patton Avenue
Asheville, NC 28801
Mr. Roden -Reynolds:
This communication represents the position of the Mount Sinai Full Gospel
Deliverance Center, Winston-Salem, NC on the application submitted by the Airport
Commission of Forsyth County. As the owner of numerous properties that will be
adversely affected, we go on record as a dissenting party to the proposed project.
We are gravely concerned about the potential impact of any airport expansion on
residents, businesses and particularly on the community revitalization currently in
progress. Health, environmental and safety concerns are paramount as well as our
prolonged and extensive investments in the redevelopment of the area; all of which will
be seriously jeopardized by the project.
Our issues are substantial and merit the utmost consideration.
Sincere Thanks,
Rev. Yvonne H. Hines, et al
Church Representative