20150088 Ver 2_Comments to USACE_20190507

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
May 7, 2019
Corps Action ID# SAW -2018-00173
DWR# 20150088 Ver 2
Buncombe County
Ms. Amanda Jones
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Ave, Room 208
Asheville, North Carolina 28801-5006
Subject Project: Greater Asheville Regional Airport Authority Apron Expansion
Dear Ms. Jones:
On behalf of the NC Division of Water Resources (Division), we respectfully request that you consider
the following comments within your review of the 404 Individual Permit request for the above
referenced property:
1. The applicant's Alternatives Analysis disqualifies other alternatives under consideration for
reasons that do not match the siting criteria or are not equally viewed between sites. For
example, the applicant provides alternatives that have existing infrastructure and then rules out
these alternatives due to the existing infrastructure (Alternatives A and B). The preferred
alternative also has existing infrastructure however it has not been ruled out by the applicant.
The applicant's siting criteria states that "The apron expansion needs to be adjacent to the
existing terminals.", however no further explanation is provided as to this requirement. It
would be beneficial for the applicant to identify the existing remain overnight (RON) area within
the airport for comparative analysis. It is also unclear whether this siting criteria negates the
need for Site Criterion A and B as it is more restrictive.
The applicant has not provided sizing criteria for the proposed Apron Expansion. The applicant
has stated that the 2013 MPU states "it is desirable for the terminal apron to be sized to
accommodate at least one or two additional aircraft beyond those projected ..." Therefore, the
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
Moana GwauNn �
919.707.9000

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applicant should be required to consider an expansion that would accommodate only one
additional aircraft as part of a proper avoidance and minimization analysis.
4. The applicant should clearly document any additional avoidance and minimization efforts such
as additional, or higher retaining walls, or reconfiguring the proposed Apron Expansion.
5. The Division has concerns that the proposed Apron Expansion has the potential for secondary
impacts since existing parking will be displaced and they have not provided a discussion of its
potential relocation needs.
6. The Division has requested additional 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 me at 336-776-9693 or [e-mail].
Sincerely,
Sue Homewood
DWR, Winston Salem Regional Office
cc: Clement Riddle, ClearWater Environmental Consultants Inc (via email)
Andrea Leslie, NCWRC (via email)
Byron Hamstead, USFWS (via email)
DWR ARO
DWR — Wetlands and Buffer Permitting Branch