20000846 Ver 1_Complete File_20030103 (7)

PIEDMONT TRIAD INTERNATIONAL AIRPORT
ENVIRONMENTAL IMPACT STATEMENT
Greensboro, N.C.

COMMENT/RESPONSE
DATABASE

a

1
i r-7
Piedmont Triad International Airport
Environmental Impact Statement
Comment / Response Database
How to Use the Database
This document contains an index of those parties who submitted comments to the FAA
during the EIS study.
The document includes the name of each party providing a comment and a unique
Letter Code to identify the submittal. Comment Codes are also provided, which indicate
the summarized comments applicable to that particular submittal. Federal, State, and
Local Agency letters are in order numerically by Letter Code and include the area of
government the individual is associated with. Public comments are listed alphabetically
by last name.

Each "Letter Code" consists of six characters that represent three fields of information
describing each unique comment submittal. The first character makes up the first field
and serves as an "event code", which describes the period during the study for which
the comment was submitted. There are three event codes:
S = Comments received during the EIS Scoping Process
P = Comments received between the EIS Scoping and the release of the DEIS
D = Comments received during the DEIS review period
t
M

1]
11
The second character represents the second field, which serves as an "affiliation code"
that places the party commenting into one of six categories:
F = Comment from a Federal agency
S = Comment from a State agency
L = Comment from a Local agency
P = Comment from the general public
E = Comment by e-mail
N = Comment by petition
The last four characters represent the third field, which identifies the specific comment
submittal numerically. For example, the "Letter Code", "SP0245", describes the
comment submittal as being the 245th comment received during the Scoping process
from the general public. Comment codes for each commentator are organized by
category. For example, Comment Code 1-1 describes the comment was made
concerning the Purpose and Need and is the first comment under that category.
All comment submittals have been treated equally by the FAA.
11

Piedmont Triad International Airport
Environmental Impact Statement
Comment Categories
The summarized comments provided are organized into the following 30 categories.
Category Number Description
1 Purpose and Need
2
3 Alternatives
Noise
4 Land Use
5 Social Impacts
6 Induced Socioeconomic Impacts
7 Air Quality
8 Hazardous Materials
9 Water Quality
10 DOT Section 303
11 Historic, Architectural, and Archaeological
12 Biotic Communities
13 Endangered and Threatened Species
14 Wetlands
15 Farmlands
16 Energy and Natural Resources
17 Light Emissions
18 Solid Waste Impacts
19 Construction Impacts
20 Other Environmental Considerations
21 Public Involvement
22 Cost Considerations
23 EIS Process and Scope
24 Quality of Life
25 Floodplains
26 Environmental Justice
27 Surface Transportation
28 Design, Art, Architecture
29 Other
30 Safety
Irk,
I

t
1

f

t
t

t
C]

I
COMMENT SHEET S ?oaD
FAA SCOPING MEETING
August 17, 1998
Piedmont Triad Internatioanal Airport
Environmental Impact Statement
PLEASE PRINT
Please state your comments clearly and concisely regarding the Scoping Process and/or the EIS
Study.
Comments:
F?w A h t? S
4- C--v T, p r?.-? ,? ?? ?????-c h 5 -??;-?- mot, S

4- i

•
l? c
r

(1.-- i

0- le-
Ni rN ! L1

A- p,
•? F?l, 5 ? N V fL-ti'-?-? Wt ?t,Y, , ? ?? ? ? yM^ S ? ?-
i
Gar. ?i ?`?t ?? W ' t-+- h j! V')
.-1:7
Name: ?? L' X ?? L_ A
Organization: a -& 1 ;lhw A -1 A?
Address: i C3 hl f- -0 Ny -ntLe
Comments due at FAA by August 31, 1998
•-E-1-.` 2? - S?

e
Piedmont Triad International Airport
Federal Agency
Felix Davila
SF0001
27-53 Comment
The document should address mitigation measure due to the highway portion as well as PTIA-produced
noise.
Response
Mitigation measures with regard to highway noise impacts associated with the proposed project are
addressed in Section 6.3 of the FEIS.

3-10 Comment
A Noise Abatement Policy needs to be put into action in the surrounding area.

Response
The PTAA has committed to the development of a noise mitigation plan to reduce noise impacts to the
areas surrounding PTIA. For aircraft operations, this program includes the voluntary acquisition of
residential parcels within the DNL 70 to 75 dBA noise contours as well as the voluntary acoustical
treatment of residences within the DNL 65 to 70 dBA noise contour. For increased truck traffic noise,
roadway noise barriers were considered in several analysis areas to mitigate noise impacts. Two noise
barriers were initially considered feasible as discussed in Section 6.2 of the FEIS. However, both of these
noise barriers exceed NCDOT's cost criterion for "reasonableness". During the final design phase of the
proposed roadway improvements, the reasonableness of these two barriers should be re-evaluated
weighing the relative benefits against the adverse effects. Please see Section 6.3 of the FEIS for further
information.
27-6 Comment
The Federal Highway Administration (FHWA) needs to adopt this environmental document so
coordination with FHWA is important.
Response
The FHWA was invited to participate as a cooperating agency and accepted that responsibility with
respect to the preparation of this environmental evaluation in accordance with CEQ regulations. The FAA
has coordinated with and FHWA has been involved with the development and review of both the DEIS
and the FEIS.
1

1
agencyrpt_101801.xis I
NbLaftidl' L. WATT
12TH DISTRICT
NORTH CAROLINA

u
1

1

i
t

I
1

COMMITTEES
BANKING AND FINANCIAL SERVICES
JUDICIARY
-
Congregg of the Z.rtiteb Otateg ?
10ouge of Repregentatibeg
Wag;bington, DC 20515-3312
August 19, 1998
Melvin L. W
MLW/tak
PLEASE RESPOND TO:
? 1230 LONGWORTH HOB
WASHINGTON, DC 20515
[phone]
FAX: [phone]
nc [e-mail]
Mr. Tommy Roberts, Project Manager
Federal Aviation Administration
Atlanta Airport District Office
1701 Columbia Avenue
Suite 2-260
Atlanta, GA 30337-2746
Dear Tommy:

I am writing in support of Federal Express' intent to locate its Mid-Atlantic hub at the Piedmont 4-'
Triad International Airport.
A Federal Express Mid-Atlantic hub will provide an important economic boost to the Triad and ! 6
North Carolina as a whole. Over the next 15 years, the hub will contribute an estimated $2.4 -
billion to the Triad's economy, accounting for nearly $160 million annually. Projections indicate
that the Mid-Atlantic hub will provide 3200 new jobs, as well as an influx of new business i
associated with Federal Express' operations. Furthermore, Federal Express is an acknowledged'
industry leader in noise pollution minimization, employee community involvement and minority
hiring practices. The hub will provide a new and important industry to North Carolina, as well as
an economic jumpstart necessary for the future well-being of our citizens.
0
The success of the Federal Express hub project is instrumental to the future growth of the Triad
region. Feel free to contact my Charlotte office if I can be of any further assistance.
S ' cerely,
at
t
324 N. COLLEGE ST.
SUITE 201
CHARLOTTE. NC 28202
[phone]
FAX: [phone]
? 301 S. GREENE ST.
SUITE 210
GREENSBORO, NC 27401
[phone]
FAX: [phone]
? 315 E. CHAPEL HILL ST.
SUITE 202
DURHAM, NC 27701
[phone]
FAX: [phone]
PRINTED ON RECYCLED PAPER
Piedmont Triad International Airport
Federal Agency
Melvin L. Watt
SF0002
2-2 Comment
I support FedEx at Piedmont Triad International Airport.
Response
Comment noted.
6-6 Comment
There are economic benefits of the proposed runway and cargo facility, both directly and indirectly, that
benefits the whole community.
Response
Comment noted. See Section 5.4 and Appendix E of the FEIS.
6-12 Comment
New jobs will be created (directly and indirectly) as a result of the FedEx facility.
Response
Comment noted. See response to Comment 6-2.
5-8 Comment
FedEx is a proven high quality corporate citizen. It will strengthen the community.
Response
Comment noted.
24-3 Comment
The FedEx sorting facility will maintain and/or improve the quality of life in the Triad.
Response
Comment noted.
agencyrpt_101801.As
001L "1 0, co,
e 7'
o
SPATES of

'Mr. Tommy Roberts
Project Manager
FAA Atlanta ADO
1701 Columbia Avenue. Suite 2-260
College Park, Georgia 30337-2747
Dear Mr. Roberts:
S /`d) o 4> --S'
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Habitat Conservation Division
101 Pivers Island Road
Beaufort, North Carolina 28516
August 12, 1998
Please reference your August 3, 1998, letter concerning the preparation of an Environmental
Impact Statement for improvements to the Piedmont Triad International Airport in Guilford
County, North Carolina. Due to the location of this project, this work will not impact fishery
resources for which the National Marine Fisheries is responsible. Therefore, we will have no
comments or recommendations concerning this project.
If we can be of further assistance, please advise.
Sincerely,
L?H. Hardy
Chief, Beaufort Facility

?L?
1

i Vd'?
Piedmont Triad International Airport
Federal Agency
Larry H. Hardy
SF0003
12-3 Comment
U.S. Department of Commerce - National Oceanic and Atmospheric Administration - National Fisheries
Service has stated that the proposed project will not impact fishery resources for which the National
Marine Fisheries is responsible.
Response
Comment noted.
agencyrpt_101801. xls

t

1
1
1

JESSE HELMS
NORTH CAROLINA

L
Ll

J

J
I JESSE HELMS:b

Mr. Tommy Roberts
Project Manager
Federal Aviation Administration
Atlanta Airport District Office
1701 Columbia Avenue, Suite 2-260
College Park, Georgia 30337-2746
Dear Mr. Roberts:
August 21, 1998
S Foco ?
There are many benefits to the state of North Carolina, especially the Piedmont. Triad!
Area, as a result of Federal Express's decision to place its Mid-Atlantic Hub at the Piedmont-
Triad International Airport. I "
It will create a great number of jobs (1500 I'm told, when the HUB is fully operational.) /
and serve a magnet for other business development. Local, state, and federal revenue will 6 v
increase as a result of the investment Federal Express will make. That means more money for
local educational facilities, improved parks and recreation, and other local and state J C)
infrastructure.
The hub will have an economic multiplier effect for the region and the State. Wages will -1
be spent on the entire range of goods and services from businesses in the area.
I know that the FAA will take these economic and all other factors into consideration as
this project is evaluated.
Kindest regards.
2?nitcd ?tatc? ?cnatc
WASHINGTON, DC 20510-3301
Sincerely,
r
Piedmont Triad International Airport
Federal Agency
Jesse Helms
SF0004
6-6 Comment
There are economic benefits of the proposed runway and cargo facility, both directly and indirectly, that
benefits the whole community.
Response
Comment noted. See Section 5.4 and Appendix E of the FEIS.
6-10 Comment
FedEx will be bringing not only investment and jobs to our state, they will bring with them a wave of
customers and suppliers who will also create investment in our state's economy and our citizens.
Response
Comment noted. The economic impacts of the proposed project are discussed in Section 5.4 and
Appendix E of the FEIS.
6-17 Comment
FedEx will add to the area's tax base, which will help to fund vital services for the area.
Response
Comment noted. See response to Comment 6-10. As discussed in Section 5.4.5 of the FEIS and Section
6 of Appendix E of the FEIS, projected additional employment and population growth within the Six-
County Socioeconomic Study Area has the potential to generate fiscal benefits for each of the counties
included, reaching a total of nearly $15.4 million by 2019.
6-13 Comment
Proposed development at PTIA would represent an economy unlike any that has been seen for some
time.
Q
Response
Comment noted. See response to Comment 6-2.
agencyrpt_ 101801. xls
COMMITTEES: S FOCV5
TRANSPORTATION AND HOWARD COBLE

SIXTH DISTRICT
NORTH CAROLINA
JUDICIARY
CHAIRMAN 22 39 RAYBURN HOUSE OFFICE S_ -= •._
SUBCOMMITTEE
AND ON COURTS Congregg of the Uniteb btateg
WAPHONE:o12022)) 22553065
INTELLECTUAL PROPERTY FAX: [phone]
1L•OUDQ of ?Q?rP$,QtItCZt?u???, e-mail: howard.coble a?mail.ro,.se .
h
Rg
L `
??'
"'
?r
l! ouse.gov:cowe
www.
PRINTED ON RECYCLED PAPER Wag;bingtan, MC 20515-3306
August 27, 1998

¦ SEP 01 1998
¦ Mr. 'IYmny Roberts
Project Manager
Federal Aviation Administration
Atlanta Airport District Office
1701 Columbia Avenue, Suite 2-260
College Park, Georgia 30337-2746
Dear Mr. Roberts:
I can writing in response to a recent Public Sccping Meeting conducted by
the Federal Aviation Administratiom in Greensboro, North Carolina, as the
first step in carpleting an R irrammntal Fact Statement (EIS) for proposed
improvements at Piednrmt Triad International Airport. As you know, the
projects that are the main focus of the EIS are the proposed construction and
operation of a new 9,000-foot air-carrier runway designated as Runway 5L/23R,
and the construction and operation of a new Federal Express (FedEx) sorting
and distribution facility.
FedEx is expected to construct a one-million square-foot facility on 175
acres reflecting an initial capital investment of between $230 million and
$300 million at Piednnnt Triad International Airport. The Bryan School of
Business at the University of North Carolina at Greensboro recently conducted
a study which estimates that 3,200 full-time equivalent jobs will be created
in the Piedmont Triad region in the next decade generating a total annual
household income of over $65 million by locating this facility at PiedmaZt
Triad International Airport. Additionally, this study concludes that the
total regional economic impact of the FedE x facility will average $160 million b- ?1
per year with a cumulative impact of $2.4 billion after 10 years of operation.
We are excited about the possibility of having such a good corporate] 5-5
citizen like FedEx locate to the Piedmont Triad. As you know, FedEx has been `
consistently recognized nationally by Fbrtune, Mother Janes, and the National b_b
Minority Business Council for creating a good work envirimirent for its
employees. FedEx continues to demonstrate a strong commitment to the
cam n-Lities in which it is located. This dedication can be seen in its
research and development of "hush kits" to make planes quieter and by
¦ initiating an Adopt-a-School program in Nalus, Tennessee, that has been very 5-3
5
! successful.
As you may know, many residents around the airport have expressed
concerns about increased noise and pollution resulting from the construction
and operation of the FedEx facility. Over the past several months, we have
P.O. Box 1813
P.O. BOX 814 SUITE A SUITE 247 SUITE 200-B SUITE 101
124 WEST ELM STREET 1404 PIEDMONT DRIVE 324 WEST MARKET STREET 155 NORTHPOINT AVENUE 241 SUNSET A, I, GRAHAM, NC 27253-0814 LEXINGTON, NC 27293-1813 GREENSBORO, NC 27401-2544 HIGH POINT, NC 27262-7723 ASHEBORO. NC 27203-95=1
PHONE: [phone] PHONE: [phone] PHONE: [phone] PHONE: [phone] PHONF:(336,626-?:9C
FAX: [phone] FAX: [phone] FAX: [phone] FAX: [phone] FAX [phone]-:533

Mr. Tommy Roberts
Page 2
August 27, 1998
1
met with these residents and shared their concerns with both PrIA and FedEx.
During the EIS review, we know that you will hear many of these same concerns,J2 c?_ q
and we are hopeful that evezy effort will be made to resolve these J ,
differences.
Please be sure that these camients are included as part of the record for
the EIS review. If you could info= our office upon carpletion of this study Z9-
and FAA's decision we would be most grateful. Thank you for your assistance
in this matter.
Sincerely,
LV tOOBLE4-
Manber of Congress
HC:mb
1
i Howard Coble
SF0005

1

1
fl

Piedmont Triad International Airport
Federal Agency
29-12 Comment
Infrastructure improvements associated with the Hub will bring great benefits to PTIA and to the region for
many years to come. These improvements will enhance transportation facilities for existing companies
and assist our region in attracting new investment.
Response
Comment noted.
6-17 Comment
FedEx will add to the area's tax base, which will help to fund vital services for the area.
Response
Comment noted. See response to Comment 6-10. As discussed in Section 5.4.5 of the FEIS and Section
6 of Appendix E of the FEIS, projected additional employment and population growth within the Six-
County Socioeconomic Study Area has the potential to generate fiscal benefits for each of the counties
included, reaching a total of nearly $15.4 million by 2019.
5-8 Comment
FedEx is a proven high quality corporate citizen. It will strengthen the community.
Response
Comment noted.
6-6 Comment
There are economic benefits of the proposed runway and cargo facility, both directly and indirectly, that
benefits the whole community.
Response
Comment noted. See Section 5.4 and Appendix E of the FEIS.
3-231 Comment
FedEx's dedication can be seen in its research and development of "hush-kits" to make planes quieter.
Response
Comment noted.
5-35 Comment
I am pleased to know that FedEx, through their Adopt-A-School program, has become a national model
for a successful initiative to improve education in the communities where FedEx employees live.

Response
Comment noted.
' 29-4 Comment
During the EIS review, we (U.S. Congressmen) know that you will hear many of these same concerns and
we are hopeful that every effort will be made to resolve these differences.
agencyrpt_10180I.As
Response
All written comment letters and oral transcripts have been reviewed by the FAA over the course of the
EIS. The FAA has made every effort to comply with Federal, state and local laws and regulations that
apply to the proposed project.
29-6
Comment
Please be sure that these comments are included as part of the record for the EIS study. If you could
inform our office (U.S. Congressmen) upon completion of this study and FAA's decision we would be most
grateful.
Response
All written comment letters and oral transcripts are part of the FEIS. See supplemental documentation for
all public letters and transcripts. An executive summary of the FEIS will be sent to North Carolina
Congressmen.
agencyrpt_ 101801. xls
RICHARD BURR
' 51H DISTRICT, NORTH CAROLINA
COMMITTEE:'
COMMERCE
SUBCOMMITTEES:
HEALTH AND THE ENVIRONMENT
ENERGY AND POWER
OVERSIGHT AND INVESTIGATIONS
I August 27, 1998
i
Id

. 5
0,C)? WASHINGTON
1513 LONGWO off HOB
WASHINGTON, DC 20515
[phone]
FAX[phone]
Congregg of the abiteb *tateg
10ouge of Repreantatibeg
Waobington, RIC 20515-3305
Mr. Tommy Roberts
Project Manager
Federal Aviation Administration
1701 Columbia Avenue
Suite 2-260
College Park, Georgia 30337-2746
DC INFO LINE:
[phone]
E-MAIL: Richard. Bu rrNC05@mai I. house g=.
WWW-httpV/www.house.gov bur-
DISTRICT OFFICE.
2000 WEST FIRST STREE-
SUITE 508
PIEDMONT PLAZA TWO
WINSTON-SALEM. NC 27104
[phone]
FAX [phone]
/t?, I,:ef
AUG 3 1 1998
I Dear Tommy:

1

li

1
7
I am writing to you today to follow up on the Federal Aviation Administration's "Scoping"
meeting on the Environmental Impact Study for the proposed FedEx Mid-Atlantic Hub at the
Piedmont Triad International Airport.
FedEx intends to create an initial total of 700 full and part time jobs at the Hub which will
provide generous salaries, health care, vision care, dental care, profit sharing plans, and 5
retirement benefits to employees. In addition, the construction of the facility alone will generate
$4.1 million per year in new North Carolina tax revenue. In the first ten years, economic experts
project an economic impact of $1.4- $2.4 billion in the area. Procurement of construction .6'
materials and workers for the Hub alone will pump an estimated $230 million into the local
economy.
I believe that regional businesses with a desire to be more cost competitive and to have quicker
access to their customers and suppliers will begin locating closer to the Hub. This projection can PID
be proven by the growth of businesses near the Indianapolis, Indiana Hub and the Fort Worth.
Texas Hub. In Indianapolis, over 60 new manufacturing and distribution companies have
expanded or located near the Hub. In Fort Worth, the Hub has indirectly created 7,000 new jobs,
with the companies creating those jobs investing more than $700 million in the Fort Worth area.
A Mid-Atlantic Hub, with its proximity to state-of-the-art medical facilities in Charlotte and at
Wake Forest, Duke, and North Carolina Universities, will become an ideal location for regional
distribution companies which supply biomedical supplies, medical equipment, and other high
tech goods.
FedEx also places a high priority on its commitment as a responsible and philanthropic member 5-00
of any community that they join. FedEx has established an "Adopt-A- School" program ---
Memphis and has since expanded it nationwide. The Points of Light Foundation chose the
company as one of seven companies to be honored with a 1996 "Award for Excellence in a -
Corporate Community Service." In 1997, FedEx employees contributed $5.5 million to the
I PRINTED ON RECYCLED PAPER
Mr. Tommy Roberts ,
August 27, 1998
Page 2
United Way and $230,000 to local and national chapters of the March of Dimes.
These examples are only a few of the many positive impacts a FedEx Hub will have on this area
of North Carolina, and I appreciate you taking time out of your schedule to review my strong
endorsement of this project. If I can ever be of any assistance to you or your agency, please do
not hesitate to contact my office.
erely,
Richard Bu
Member of ongress
RB:bv
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Piedmont Triad International Airport
Federal Agency
Richard Burr
SF0006
5-15 Comment
FedEx will provide strong employee benefits for those employees working at the new sorting hub, even for
part-time employees.
Response
Comment noted.
6-17 Comment
FedEx will add to the area's tax base, which will help to fund vital services for the area.
Response -
Comment noted. See response to Comment 6-10. As discussed in Section 5.4.5 of the FEIS and Section
6 of Appendix E of the FEIS, projected additional employment and population growth within the Six-
County Socioeconomic Study Area has the potential to generate fiscal benefits for each of the counties
included, reaching a total of nearly $15.4 million by 2019.
6-10 Comment
FedEx will be bringing not only investment and jobs to our state, they will bring with them a wave of
customers and suppliers who will also create investment in our state's economy and our citizens.
Response
Comment noted. The economic impacts of the proposed project are discussed in Section 5.4 and
Appendix E of the FEIS.
5-8 Comment
FedEx is a proven high quality corporate citizen. It will strengthen the community.
Response
Comment noted.
29-17 Comment
Local charities will benefit from addition of a great corporate citizen.
Response
Comment noted.
6-6 Comment
There are economic benefits of the proposed runway and cargo facility, both directly and indirectly, that
benefits the whole community.
Response
Comment noted. See Section 5.4 and Appendix E of the FEIS.
agencyrpt_ 101801.xis
r7Yi L I 11777 1L.. 17
tt? .
?? w10t?

YUYJVJ l1JJ
S ?. ov7
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
01 IFORSrTN STREET
ATLANTA, GEORGIA 30303-0960
Tommy Robert&
Project manngur
FAA Atlanta ADO
1701 Columbia Ave.. Suite 2-260
Co11cgo park, GA 30337 - 2747
APR t 6 6W
SUBJECT: Piedmont. Triad International Airport
Dear Mr. Roberts:
0"r NiIL re&Am w 1r o)
FAX TRANSMITTAL ,
rye ,an ?`_.. - `•
0"Y ag
QipIJA ry rhw.. • - ._.. _.
Via. a ?J? Tao va Y sz z _ ?;
Fax W
A+?' 7r+/b•UI a,73_ {y1 , _!11l j?hl J I?YII?C :ti f•`J111w
We have reviewed the scoping package for a prnposal to construct a new 90004nor
' runway and associated taxiways at the above referenced airport. The Proposal also includes the
construction and operation of a new FedLx sorting and distribution facility.
The issue of most concern at an urban airport norrivilly ir; noise associated with aircraft
operations. A new runway means that. a new population of people will be exposed to aircraft 3-33
noise or to higher levcla of aircraft noise than at present. 77te inclusion of a Y dEx sorting and
distribution facility will cxpoae residents near the airport to both daytinx air operations and many
nighttime operations as well. Sleep disturbance will be a major concern for many residents.
The environmental impact statement and the public meetings associated with it. should
provide the residents living near the airpnrt with as much accurate and understandable information
on noise imposts tss possible, To help minimize dirarust. of your agency and the airport. authority,
a common situation in urban airpmt populations, your rlUiW inlhtTnnt.iun stratcgy should include I-0
an acknowledgment that noire will arff=t. people outside the noise contours but that mitigation of
those impacts will not nonrally be available to tltcnt.
I

1

General Conformity Section 176(c) of the Clean Air Act requires that federal actions
undergo a confornvty determination in areas that do not meet the National Amhiclu Air Quality
Standard. Title 40, Part 93 of the Code of Federal Regulations (01R) establishes the
requirements that federal agoncios neat meet under the Genet ill Conformity process. General
Cunfun*y rules for federal actions, such as the Piedmont Triad International Airport/ FED> X
Distributinti Center project, require a general conformity determination for projects that exceed
100 tons per year (TTY) of volatile organic compounds (VOCs) or nitrogen oxide4
(NOx) in ozone nonattairuncnt. This conformity analysis requires that the federal agency, in this
cave the Federal Aviation Administration (FAA), include the direct and indirect emissions in tlrc
air quality analysis. Directs emissions are dcfinod in 40 CFR Part 93.152 as "...those emissions uf'
a criteria pollutant or its precursors that are cimsed or initiated by the Federal Rction and occur at
the sane tune and place as the action." Indirect cmissions are defined in 40 CFR Part 93.152 as
"..,those emissions of a criteria pollutant or its prccursort; treat: 1) Are caused by the Federal
action, but may occur later in tiruc and/or may be further removed in distance from the action
Inlemot Address (URL) • http://www.9WA Vow
p9oWl0"QVYe14bh9.Prlnl9d Whll vu0418 Oil021 W LIIw On i",ryrli-(I Puj•I/r (Mlnbnuln 257(, POsir-on omn)
-?--7

YJ4i Sri I,?J 1L: 17 4u4...u-,1- i--t. LHIV.H H.)U
itself but are still reasonably foreseeable; oil 2) The Fcderal agency can practicably control and
will maintain control over due to n continuing program rctiponsihility of the Federal agency."
Indirect Emissions: The indirect cotission should cover the ciniQCions from when the runway
is anticipated to be at full capacity. Bccauso the Federal Fxpress facility uceds FAA approval for
its location, the emissions generated by the facility itulf mid the traffic entering and exiting the -7-757
facility are required to be covered in the indirect emissions. '
Public Involvement: 40 CFR Part 93.156 de Bribe s the public involvement procedures. these
include making available the draft conformity determination with supporting documentation
available for review, must make public its confrn•mity determination in a. daily newspaper for
circulation in the area effcctcd by action, and provide 30 days for eviTirnents prior to taking any
rorinal action on the draft conformity dct.crminat.ion.
Thank you for the opportunity to p.u-ticipate in this process. Allen Lucas (404/562-962.1)
will coordinate viii- agency's review of this pr0iect. Questions on air quality and conformity
should he directed to Ben Franco (404/562-9039).
Sincerely*1einzMucl1er5'. .?r ; Chief
Office of Environmental Assessment.
Environmental Accountability Division

J

Heinz Mueller
SF0007
Piedmont Triad International Airport
Federal Agency
3-33 Comment
I am concerned about noise factors so close to residential areas.

I?
u
J

11

Response
The EIS uses FAA's approved DNL noise metric as well as other supplemental noise metrics such as
single event noise levels (Sound Exposure Levels or SEL's) and average noise levels (Leq noise levels at
night - 10:00 p.m. to 7:00 a.m. or Leq(9)) to evaluate the noise impacts from the proposed project. SEL's
were used to evaluate sleep disturbance impacts, while the Leq(9) were used to represent noise impact at
night since the time would be typical of the air cargo operations at night. The FEIS addresses the fact that
a small percentage of the population has the potential to experience sleep disturbance. The study also
addresses the proposed mitigation plan for PTIA. The airport has committed to the voluntary acquisition
of all noise sensitive properties within the DNL 70 and 75 dBA noise contours, the voluntary sound
insulation of all property between the DNL 65 and 70 dBA noise contour, the installation of a noise and
operations monitoring system, and the development of a FAR Part 150 noise compatibility study. Please
see Sections 5.1.3, 5.1.4, and 6.3 in the FEIS for further information.
3-49 Comment
Your noise information strategy should include and acknowledge that noise will affect people outside the
noise contours but that mitigation of those impacts will not normally be available to them.
Response
Some people residing outside of the 65 DNL. noise contours have the potential to experience sleep
disturbance as a result of the proposed project. Sections 5.1.3 and 5.1.4 of the FEIS discuss these
potential impacts. At this time, the PTAA has committed to a Mitigation Program (see Section 6.3 of the
FEIS) that offers mitigation only to homeowners within the 65 DNL noise contours.
7-7 Comment
Hub operations should be in compliance with the Clean Air Act.
Response
Comment noted. The mechanism for demonstrating compliance with the Clean Air Act is the General
Conformity process which is the responsibility of the FAA. This insures that the FAA does not approve,
fund, or permit any project or action that is not consistent with the State Implementation Plan (SIP); a plan
developed by the state to attain and maintain the ambient Air Quality Standards. This General Conformity
process has been completed for this project and is described in greater detail in Section 5.5 of the FEIS
and in the Final General Conformity Determination, which is included in Appendix F of the FEIS.
7-75 Comment
Indirect emissions should cover the emissions from when the runway is anticipated to be at full capacity.
agencyrpt_ 101801. xis
Response I
All of the emission sources (eg. aircraft, ground service equipment, fuel facilities) are accounted for in the
EIS Air Emissions Inventory or, in the case of motor vehicles, included in the Transportation Improvement ,
Plan and Long Range Transportation Plan (LRTP) for the GreensboroNVinston-Salem/High Point area. In.
this way, both the direct (eg. on-site) and indirect (eg. off-site) emissions and their sources are covered.
L__l
21-21 Comment
Public involvement procedures, under 40 CFR Part 93.156, include making available the draft conformity
determination with supporting documentation available for review, must make public its conformity
determination in a daily newspaper for circulation in the area affected by action, and provide 30 days for
comments prior to taking any formal action on the draft conformity determination. '
Response
The mechanism for demonstrating compliance with the Clean Air Act is the General Conformity process
which is the responsibility of the FAA. This insures that the FAA does not approve, fund, or permit any
project or action that is not consistent with the State Implementation Plan (SIP); a plan developed by the
state to attain and maintain the ambient Air Quality Standards. The General Conformity process has been
completed for this project. Several versions of the Draft General Conformity Report have been published '
and reviewed by appropriate resource agencies and the public. A copy of the Final General Conformity
Determination is contained in Appendix F of the FEIS.

G

agencyrpt_101801.xls I

UNITED STATES DEPARTMENT OF COMMERCE
Office of the Under Secretary for
Oceans and Atmosphere
?°Tirn of Washington, D.C. 20230 f" D0O I
April 13, 2000
Ms. Donna Meyer
Environmental Program Specialist
Federal Aviation Administration
1701 Columbia Avenue, Suite 2-260
College Park, Georgia 30337
Dear Ms. Meyer:

' Enclosed are comments on the Draft Environmental Impact Statement
for Proposed Runway SL/23R, Proposed New Overnight Express Air
Cargo Sorting and Distribution Facility, and Associated
' Developments Greensboro, North Carolina. We hope our comments
can assist you. Thank you for giving us an opportunity to review
this document.
' Sincerely,
Susan B. Fruchter
NEPA Coordinator
1 Enclosure
ri

1
1
® Printed on Recycled Paper
`SO ?1M05gf9C
4
1 i
?9j4fM O? ?OJ

?f / ca-, 0 / I

1
MEMORANDUM FOR: Susan B. Fruchter
Acting NEPA Coordinator ,
FROM: Charles W. Challstrom
Director, National Geodetic Survey '
SUBJECT: DEIS-0004-01 Proposed Runway 5L/23R, Proposed New '
Overnight Express Air Cargo Sorting and Distributing Facility,
and Associated Developments Greensboro, North Carolina
The subject statement has been reviewed within the areas of the National Geodetic Survey's
(NGS) responsibility and expertise and in terms of the impact of the proposed actions on NGS
activities and projects.
All available geodetic control information about horizontal and vertical geodetic control 1
monuments in the subject area is contained on the NGS home page at the following Internet
World Wide Web address: http://www.ngs.noaa.gov. After entering the NGS home page,
please access the topic "Products and Services" and then access the menu item "Data Sheet."
This menu item will allow you to directly access geodetic control monument information from
the NGS data base for the subject area project.CThis information should be reviewed for '
identifying the location and designation of any geodetic control monuments that may be
affected by the proposed project.
If there are any planned activities which will disturb or destroy these monuments, NGS
requires not less than 90 days' notification in advance of such activities in order to plan for
their relocation. NGS recommends that funding for this project includes the cost of any '
relocation(s) required
For further information about these monuments, please contact Rick Yorczyk; SSMC3 8636,
NOAA, N/NGS; 1315 East West Highway; Silver Spring, Maryland 20910;
telephone: [phone] x142; fax: [phone]. '

7
u
Piedmont Triad International Airport
' Federal Agency
Susan Fruchter
' DF0001
29-106 Comment
' National Geodetic Survey information should be reviewed for identifying the location and designation of
any geodetic control monuments that maybe affected by the planning process. If there are any planned
activities which will disturb or destroy these monuments, NGS requires not less than 90 days notification
in advance of such activities in order to plan for their relocation. NGS recommends that funding for this
project includes the cost of any relocation(s) required.
I Response
Please see response to Comment 29-73.

n

agencyrpt_101801.x1s
i

7
L

r.

CIO! u71 Luuu lu. LGl -rv - r L......
F
L

1

t

P
[l

t
D t,;fo00,;-
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
lilt-w/265 JUN 2 20M
Ms. Donna M. Meyer
1?11vimnmental Program Specialist
Federal Aviation Admittistrution
17Ol .-olumbir. Avenue, Su'te ?='bQ
College Park. Georgia 30337
Dear Ms. Meyer:
'T'his is in response to the reyuesl for the. Department of the Interior's comments on the Draft l".nvironrrturial
Impact Statement for the expansion of the Piedmont Triad International Airport, City of Greenshort), Guilford
county, North Carolina.
Lin the absence of a Section 4(f) Evaluation and a selected alternative, we reserve our ccymnaents until it
preferred alternative has been selected and a Section 4(f) bwaluatiun has been prepared. It appears thrt. ;evcral I0
historic properties are within this project urea and may be affected by at least increased noise pollution]
We are opposed to environmental approval of this project until a Section-4(t) Evaluation has been hrepaaed 10-3
and reviewed by the l I.S. Department of the interio+
Genervl Comments
The Fish and Wildlife Service (Service) has reviewed the Draft Environmental Impact Statement (L)EIS), plated
April 20tH), for the proposed Runway 51J23R, a proposed new overnight express air cargo sorting and
clistrihutitm facility (hedEx Mid Atlantic Huh), and associated developments at Piedmont Triad International
Airport (1111A), near the City of Greensboro, Guilford County. North Carolina.
According to the DEIS. the Federal Aviation Administration (FAA) proposes one of six project plan% for
improvements to the existing airport layout that are intended to effectively meet the operational requirements
of the proposed air cargo huh. The preferred alternative project plan isW -A• This plan will permanently ely 32 disturb approximately 410 aces of varying biotic comtn ect ties, `d[ g sed, the peel [erred alternative w 111twe
and ;approximately 36 acres of floodplain. Of the six prof plans prop
the second greatust amount of impact to wetlands and the third greatest amount of impact to flot-odplain habitat.
"1'he proposed action would likely degrade or eliminate important habitat for many ecologically valttuhle Ja
aquatic, terrestrial, and avian specie] Various herpetofauna likely to inhabit this area include the upland
chorus frog (Pseuduc•ris feriarunt), green frog (Rana cla?nitans), bullfrog (Rana raucsbeianer), Eastern box
tuille (%errapene corn ina), and redbelly snake (Storeria occipitomaculata). Mammals, such as the white-
opossum (S?ylvilhgmv
tailed acct (Uducoilirtr.r rirginn Enci?ntch,.Ps) raccoonn(Proc.•yun r Eastern cottontail
./l?,rirlcrnua ), gray fox (ll racy,n cne

o iro?inirr?rer), may also occur in the vicinity of the proposed project area. Various neotropical avifuuna. such
ellow warbler (Dendroica petechiu), and hooded warbler
i
)
l '
, y
frons
uv
as the yellow-throated vireo (Vireo,t
are likely present on the preferred project site during various times of the year. Common
)
i
i
i
,
na
lr
a c
(Wilmm
ecies may include the black-capped chickadee (Parus carulienesiN), tufted titmouse. (Pares
i
s
an
p
resident av
hicnlar), red-bellied woodpecker (Melanerpes curolinwi), and raptors, such as the red-tailed hawk (Bure(;
LAny development in or around the preferred project site is Iiko:Iy j?-
vuria)
l (Stri
d '
_
ae
ow
. amairensis) and barre
to) permanently affect the local fauna by habitat loss, ftagmcntation, or degradation.
the proposed project include a permanently flooded stream and
?'he wetlands potentially impacted by
The functions of these wetland aretis include
i
es.
flooxlplain system of Brush Creek and its associated tributar
ification and recharge, flood and storm water abatement, sediment retention, and wildlife
groundwater pur
Notch Carolina has experienced several severe storm events, and the floodplain system
habitat. In recent years
has been vital in upland habitat protection and environmental recovery from the flooding crated by these
s a valuable storage area for storm and flexed waters by holding the water
'
'
hese wetlands serve a
T
storms.
temporarily and releasing it slowly, as well as serving its important habitat for wildlife. The proposes activities ,
will likely reduce or eliminate these significant natural biological function]
hc possible water'-related impacts of the proposed construction have been discussed in the Draft F IS.
E
discussion is qualitative in nature (for example, "... waters expecttA to be most affected
f th
e
lowever, much o
I
" (Draft EIS, Volume 1: DOCUMENTATION, Chapter 5.0 Environmental Consequences, Surface Wutr
sub-basins would be minimal . P
t
i
h
wo
ese
n t
utility, first paragraph, page 5.86); ". • • water quality impacts
1 No-Action Alternative, first paragraph, page 5-92); and " ... would impact a total of .
5
11
3
" '
.
.
.
(Section
" (Draft EIS, Surface Water Quality, second paragraph, page 5-142)). To the extent possible, additional
acts should be included in the Draft Hlti, to
d i
l
mp
ate
quantitative information regarding the possible water-re
ti
)
if
ica
on
allow for their more definitive, ident
In accordance with Executive Under 11988, we recommend making strong efforts to protect the I'loodplaitt
S
nd the associated wildlife from degradation by avoiding or minimizing wetland impact It has ,
i
ty a
commun
become increasingly important to protect the ecological integrity of floodplain systems, particularly to the
there is no effective replacement for the
th
i
i
at
on
n
vicinity of the project area. In addition. while it is our op
indirect loss of important fish and wildlife habitat, compensatory mitigation would satisfy the "nod
t o
di
rec
r
overall net loss" of wetlands. Ewe strongly recommend mitigating on-site within the project area for the
lanting native woodland vegetation.
d re
p
impacted wetlands, including establishing vegetated buffer zones an
mend the acreage of converted riparian habitat he mitigated at an appropriate ratio: ?:1
o
m
In addition, we rec
restoration, 4:1 enhancement, and 10;1 preservation '
The American bald eagle (Haliaeerus leueocephalus) is the only known federally-listed species in Guilford
ent in the project area; however.
i
s not pres
county. The DFIS indicates that preferred habitat for this species
en documented within five miles of the proposed construction site. Vascular plants.
ts have b
i
e
ve nes
two act
such as smooth coneflower (Echinacea luevigalu), Michaux's sumac (Rhus ndchauxii), and American
w to moderate potential to occur within the project area. Although
l
o
chul'I:seed (Schwedbeec umeylva [i), have a
rted in adjacent or nearby counties, none have ever been reported in Guilford
b '
een repo
these species have
County.
l
d
y _
versc
Mused on the information providLd in the DEIS, the Service concurs that this project is not likely to a
ecies currently proposed for ?
or s
t
bit
l h
p
,
a
a
affect any federally-listed species, their formally designated critica
Federal listing under the Act. I

3
' We believe that the requirements of Section 7 of the Act have been satisfied ?We remind you that obligations
under Section 7 consultation 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; (3) a new species is listed or
critical habitat determined that may be affected by the identified action.
The possible water-related impacts of the proposed construction have been discussed in the Draft EIS.
However, much of the discussion is qualitative in nature (for example, "...waters expected to be most
affected..." (Draft EIS, Volume 1: DOCYJMENTATION, Chapter 5.0, Environmental Consequences. Sur face
Water Quality, first paragraph, page 5-86); "...water quality impacts in these two sub basins would be
' minimal..." (Section 5.11.3.1 No-Action Alternative, fiust paragraph, page 5-92); and "...would impact a total
of...," (Draft EIS, Surface Water Oki . second paragraph, page 5-142). To the extent possible, additional
quantitative information regarding the possible water-related impacts should be included in the Draft E1S, to
ullow for their more definitive identification.
F

0

F
1?
Saecitlc Comments
Page 5-82, Section 5.6.1, Overview of Impacts Tearing areas of vegetation during construction would result
in short-term turbidity impacts in the surface waters of all three sub-basins in the proposed project area, and 1-33
mitigation treasures are proposed to minimize these impacts. However, because the proposed construction
will take a number of years to complete, the turbidity impacts might be more than short-term in their effects
We appreciate the opportunity to provide these comments.
Sincerely,
Willie R. Taylor
Director, Office of Environmental
Policy and Compliance
u°TIONAL FORM 99 (7.9o)
tFAX TRANSMITTAL
l?(?(?+? G Ih?l Ylt/TZ From
.
• of Pape.. ?

Piedmont Triad International Airport
Federal Agency '
Willie Taylor
DF0002 '
10-2 Comment
In the absence of a Section 4(f) Evaluation and a selected alternative, we (DOI) reserve our comments '
until a preferred alternative has been selected and a Section 4(f) Evaluation has been prepared. It
appears that several historic properties are within this project area and may be affected by at least
increased noise pollution. '
Response
As stated in Chapter 3, Alternatives, of the FEIS, the FAA has selected Alternative W1-A1 as the '
Preferred Alternative for the proposed project at PTIA. This alternative would not have a direct or indirect
impact to Section 303(c) resources. This alternative will have an indirect adverse impact from noise to one
(1) historic architectural property covered under Section 106, the Campbell-Gray Farm, which is eligible '
for listing in the National Register of Historic Places. The FAA, in consultation with the NCSHPO, has
determined that this property would be adversely affected by Alternative W1-A1, and a Memorandum of
Agreement (MOA) (Appendix G of this EIS) has been entered into by the FAA, SHPO and PTAA to '
mitigate the adverse noise impacts.
The FAA and SHPO have also concurred that the adverse effect to this property under Section 106 does
not constitute a constructive use under Section 303(c) because it does not substantially impair the historic
integrity of the site under which it was listed (Criterion C). Therefore Section 303(c) does not apply, and
Alternative W1-A1 would not result in indirect Section 303(c) impacts, and a separate Section 303(c)
Evaluation is not warranted.
10-3 Comment
We (DOI) are opposed to environmental ap
roval of this
ro
t
til
S
ti ,
p
p
jec
un
a
ec
on 4(f) Evaluation has been
prepared and reviewed by the U.S. Department of the Interior.
Response
Comment noted. Please see responses to Comment 10-2.
12-4 Comment '
The proposed action would likely degrade or eliminate important habitat for many ecologically valuable
aquatic, terrestrial, and avian species.
'
Response
Please refer to sections 5.9, 5.10, and 5.11 of the FEIS for details on potential impacts to wildlife habitats
and animal species.
12-5 Comment
Any development in or around the preferred project site is likely to permanently affect the local fauna by ,
habitat loss, fragmentation or degradation.
Response ,
Please refer to Sections 5.9, 5.10, and 5.11 in the FEIS for details on what the projected impacts to local
fauna and habitat will be.
agencyrpt 101801.x1s
' 14-8 Comment
The wetlands potentially impacted by the proposed project include a permanently flooded stream and
floodplain system of Brush Creek and its' associated tributaries. The functions of these wetland areas
include groundwater purification and recharge, flood and stormwater abatement, sediment retention and
wildlife habitat.....These wetlands serve as a valuable storage area for storm and flood waters by holding
the water temporarily and releasing it slowly, as well as serving as important habitat for wildlife. The
proposed activities will likely reduce or eliminate these significant biological functions.
Response
Please see response to Comment 14-4.
9-32 Comment
The possible water-related impacts of the proposed construction have been discussed in the EIS.
However, much of the discussion is qualitative in nature ...To the extent possible, additional quantitative
' information regarding the possible water-related impacts should be included in the Draft EIS, to allow for
their more definitive identification.
Response
The concentrations and types of pollutants expected from the operation of the proposed project and
reasonable alternatives are in Tables 5.6.3-5 and 5.6.3-6 in the FEIS.
25-3 Comment
In accordance with Executive Order 11988, we (DOI) recommend making strong efforts to protect the
floodplain community and the associated wildlife from degradation by avoiding or minimizing wetland
impacts.
Response
The initial development and evaluation of alternatives to the proposed project took into account the
avoidance and minimization of floodplain impacts. However, all of the reasonable alternatives would result
in unavoidable impacts to 100-year floodplain areas. PTAA's proposed Mitigation Program for the
' Preferred Alternative, contained in Section 6.3 of the FEIS, has identified mitigation measures to protect
beneficial floodplain values.
' 14-9 Comment
The USDOI strongly recommend mitigating on-site within the project area for the impacted wetlands,
including establishing vegetated buffer zones and replanting native woodland vegetation. In addition, we
recommend the acreage of converted riparian habitat be mitigated at an appropriate ratio: 2:1 restoration,
4:1 enhancement, and 10:1 preservation.
' Response
Comment noted. Please see Section 6.3 of the FEIS which contains a summary of the Wetland and
Stream Mitigation Plan for wetland impacts that has been submitted to the USACE, EPA and NCDENR.
' This plan includes both on-site and off-site mitigation.
13-2 Comment
Based on information provided in the DEIS, the Fish and Wildlife Service concurs that this project is not
likely to adversely affect any Federally-listed species, their formally designated critical habitat, or species
currently proposed for Federal listing under the (Endangered Species) Act. We believe that the
' requirements of Section 7 of the Act have been satisfied.
Response
Comment noted. Please refer to Appendix A for agency coordination.
i
agencyrpl_101801.x1s
9-33 Comment '
Clearing areas of vegetation during construction would result in short-term turbidity impacts to surface
waters of all three sub-basins in the proposed project area, and mitigation measures are proposed to '
minimize these impacts. However, because the proposed construction will take a number of years to
complete, the turbidity impacts might be more than short-term in their effects.
Response '
Comment noted. However, land disturbance takes place in the early steps of the proposed project. The
contractor will be required to abide by the terms of an NPDES permit, which requires the on-site
containment of sediments from the construction site with use of Best Management Practices (BMPs).
These BMPs are discussed in Section 6.2.4 of the FEIS.

F

1

0

agencyrpt_101801.x1s
frooo3
USDA UNITED STATES Natural Resources 3309 Burlington Road
DEPARTMENT OF Conservation Greensboro, NC 27405
AGRICULTURE Service Phone: [phone] X3
DATE: April 28, 2000
.?. .
MAY
SUBJECT: Correction- Appendix A
Draft EIS-Piedmont Triad International Airport
TO: Ms. Donna M. Meyer
Department of Transportation -
Federal Aviation Administration
1701 Columbia Ave, Suite 2-260 -
College Park, GA 30337-2747
This letter is to request a change on the index page for Appendix A, Agency Correspondence.
' The dates of 8-11-99 and 8-27-99 shows the U.S. Department of Agriculture, Soil Conversation
Service.
u

1
1

r

The correct agency name should be: U.S. Department of Agriculture, Natural Resources
Conservation Service. This agency name change was made several years ago by USDA and
is shown on the correspondence from our Resource Soil Scientist.
Please make the necessary changes.

-JOHN W. ANDREWS
District Conservationist
cc: W. E. Woody, NRCS Resource Soil Scientist
u

Piedmont Triad International Airport
Federal Agency '
John Andrews
DF0003
15-1 Comment
The correct agency name referenced in Appendix A, Agency Correspondence, letters dated 9/11/99 and '
8/27/99 should be Natural Resources Conservation Service.
Response '
Comment noted. This edit has been made in the FEIS.

i
1
1
1
1
agencyrpt
101801.xis '
_
1

t
`,aZED STgT??
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2 A ,Z REGION a
C, ATLANTA FEDERAL CENTER
.F \oa 61 FORSYTH STREET
tirg4 FRO1t_, ATLANTA, GEORGIA 30303-8960 .. _,.
June 19. 2000
4EAD-OEA
Ms. Donna M. Meyer
Department of Transportation
Federal Aviation Administration
1701 Columbia Avenue. Suite 2-260
College Park. Georgia 30337-2747
D Fx,>?-, V
SUBJECT: EPA Review of FAA DEIS for "Proposed Runway 5L/23R, Proposed
New Overnight Express Air Cargo Sorting and Distribution Facility,
and Associated Developments;" Piedmont Triad International Airport;
City of Greensboro, Guilford County, NC; CEQ No. 000101
' Dear Ms. Meyer:

7

H
0
0
1
Pursuant to Section 102(2)(C) of the National Environmental Policy Act (NEPA)
and Section 309 of the Clean Air Act, the U.S. Environmental Protection Agency (EPA) has
reviewed the subject Draft Environmental Impact Statement (DEIS) prepared by the Federal
Aviation Administration (FAA). This DEIS concerns the expansion of the Piedmont Triad
International Airport (PTIA) proposed by the Sponsor -- the Piedmont Triad Airport Authority
(PTAA). Our comments are summarized in this letter and detailed in the appended Detailed
Comments.
The proposed action involves the addition of the Sponsor's overnight express air
cargo runway and associated facilities. and would make PTIA a hub for Federal Express
(i.e.. FedEx Mid-Atlantic Hub). Initially. 48 daily express air cargo operations are proposed
during a late-night and early-morning time frame, with additional runway capacity being available
for future expansion. Because the PTIA site involves physical constraints. runway and
taxiing bridges over roadways are proposed as well as relocation of homes and businesses.
Environmentally, wetlands and floodplains would also be impacted.
Of the 42 action alternatives considered. the Sponsor identified five that satisfied its
criteria (W2-A. W3-A. N-D. N-E and W 1-A 1). These were evaluated and carried forward
throughout the DEIS. The No-Action Alternative was also evaluated in this way for comparison.
The Sponsor selected Alternative W2-A as the proposed alternative. which may or may not also
be FAA's federal preferred alternative in the Final EIS (FE1S). or FAA's selected alterr7atil'C in
the Record of Decision (ROD).
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Pnnted with Vegetable Oil Based inKs on Recycled Paper (Minimum 30% Posiconsumer,
b'FOD 6 y
1
[EPA has environmental objections with the Sponsor's proposal (W2-A) as well as all of
the other presented action alternatives for the FedEx hub. We therefore prefer the No-Action
Alternative which proposes some airport improvements but no cargo hub at PTIA. Specifically.
we base our environmental objections on the fact that we do not believe that the DEIS fully 2 go
describes the proposed air cargo operations and the associated potential noise impacts. nor the
mitigation of those impacts. We particularly disagree with runway alternatives oriented in a
general north-south direction (technically a northwest-southeast direction) such as N-D and N-E.
These runways are perpendicular to the existing runway layout and therefore seem to constitute a
traffic controller. safety and efficiency problem. Environmentally, such alternatives would also
expose flyover noise issues to a new set of people living near the airport that did not expect to be 3 -2ZI
so directly impacted since the existing PTIA runways are oriented in a general east-west
(technically, northeast-southwest) direction.
Given the physical constraints of the PTIA site
and that several alternatives (including
the Sponsor's W2-A) would include runway and taxiing bridges (i.e., roadway tunnels). we
recommend that the safety of the alternatives be identified and compared in the FEI?] The safety
history of such runway bridges at existing or former airports should also be documented in the
FEIS. In addition, the FEIS should discuss FAA's regulations (and/or any other regulations)
regarding Runway Safety Areas (RSAs) just beyond the end of runways and the Runway
Protection Zones (RPZs) beyond the RSAs. Of interest are the compatible versus incompatible
land uses that regulations would allow in these areas. Such land uses should then be related to the
project proposed.
We understand that the FHWA North Carolina Division has determined that only general
conformity and not transportation conformity would apply for the proposed PTIA project, which
includes various transportation actions such as roadway relocations and runway bridges over
roadways. We further understand that FHWA, as a cooperating agency to FAA for the present
EIS, would likely adopt the FAA EIS for their NEPA roadway actions.Eince roadway projects
are associated with the PTIA proposal and since FHWA is a cooperating agency to FAA for the
DEIS. the FEIS should substantiate the decision that transportation conformity does not apply for ?? -?
this proposed project Transportation conformity criteria discussed in the appended Detailed
Comments including funding. approval and inclusion in a conforming transportation plan. should
be discussed and applied to the present project.
e-
Lin regard to noise documentation. we believe that the DEIS does not provide a detailed
description of the proposed air cargo facility and its potential impacts, particularly from a
day-to-day operational point of view. The FEIS should disclose this operational information,
such as when the FedEx air cargo flights would be arriving, how long are they on the ground, '
and when they depart. Specific time frames should be provided for each operatio2?i(e.g., in
the year 2005, the 16.4 FedEx arrivals per Table 5.1.2-4 will take place between 11 pm and 1
am). Table 1.3-1 indicates that air cargo operations will only take place five days a week (52
weeks @5 days =260 days). The FEIS should identify which of the seven nights per week the
FedEx operations will take place. Since there are already ongoing air cargo operations at the

J
J

C

t

airport, the FEIS also needs to describe these operations in relationship to the proposed FedEx
operations (operational information, etc.). L The additional noise situation of noisy takeoff and
landing events during the sensitive nighttime period of operation should also be better 3??09
characterized. A metric more specific to this relatively short four-to-five hour time frame
should be used for the analysis to supplement the averaged metrics (DNL and Leq(9)
descriptors) used in the DEISM.
In regard to noise effects,LEPA is concerned that the parallel runway proposal would 3-410
not only increase overall airport noise, but that new intrusive noise would be introduced almost
daily due to the proposed air cargo express flight operations during sensitive late-night and
early-morning time periodsJThe DEIS proposes that all FedEx landings and takeoffs would
come from and go toward the southwestern section, which would impact those scattered
residences located there and avoid the more concentrated single family homes located in the 3 _Z3 3
northeastern section.rAs a FedEx hub, we believe the potential is great for operational expansion
on the new parallel runway beyond the proposed 48 daily operations, which would then generate
even more noise during this nighttime perio CI addition, as capacity eventually grows at PTIA 3
and use of the cargo runway for FedEx as well as other commercial airlines increases, we
anticipate that the single family residences in the northeastern section of Greensboro (which are
currently not forecasted in the DEIS to be located within the DNL. 65 contour per Fig. 5.1.4-2 for
W2-A). could receive greater noise impacts and ultimately be included in the DNL 65 dB conto`2
LEPA believes that noise mitigation was not adequately addressed in the DEIS. The
proposed action does not include adequate non-operational (land use) noise mitigation that is -3-111
needed to reduce/remove non-compatible residential land uses in the projected DNL >65 dB
contour If the Sponsor's Alternative W2-A is pursued at PTIA, additional land use and
possible operational mitigation would be needed to relieve the aircraft noise impacts for all
residents within these contours. Of particular concern are those residents in the southwestern
section that would be impacted by the proposed night FedEx operations (arrivals on 5R/5L and
departures on 23R/23L). Although page 6-9 provides a short discussion of possible non-
operational noise mitigation measures that may be implemented, no FAA/PTIA commitment to
mitigate is provided. We strongly recommend that these possible measures be implemented.
There should be an aggressive residential acquisition program that might initially target all
residents that would be impacted by the nighttime FedEx aircraft operations. Acoustical
treatment (storm doors and windows and other insulation) should also be provided to residents
within these contours that prefer not to be purchased. Also, noise impacts should be
documented within the DNL 60 dB contour, since noise impacts do exist outside the DNL 65
dB contour.
It appears that the airport authority does not participate in FAA's FAR Part 150 Noise
Compatibility Program. Participation in the Part 150 program may be very useful in future
years as it will allow the public to be involved in a formal noise mitigation process as aircraft
operations increase in years beyond 2009. [We strongly encourage the PTAA to participate in
the Part 150 Program]

,`- oo ?l
4
Although there may not be a project EJ impact, FAA should reconsider EJ effects
after incorporation of the information requested in the Detailed Comments and a reassessment
is made. While noise impacts at various levels can be expected for residents living near an
airport, any selected FAA action alternative should minimize such noise impacts for the affected 2-6--`q
general public. Moreover.tthe EJ analysis should insure that affected minority and low-income
populations in the area are not disproportionately impacted through alternative selection. runway
orientation, flight paths, hours of operation and other operational and land use considerations.
FAA mitigative methods such as residential purchases and sound-proofing treatments shoulp
consider all communities during the FAA Part 150 process of mitigating residents toward the
DNL 65 dB contour (i.e.. DNL 75, 70 and 65 dB contours). However, special attention should
be given to EJ communities that may exist within the 65 dB contour (where mitigation is
often incomplete) if, due to the overall health and societal conditions that may exist in the EJ
community, noise impacts would have, or likely would have, a substantive cumulative effect
on such conditions.
Page 5-210 states that "[c]oordination with the cities of Greensboro. high Point. and
Winston-Salem as well as Guilford County indicate that there are no other known major planned
developments in the PTIA area that need to be considered on a cumulative basis." However it
seems unrealistic that no substantive projects are planned within the foreseeable future for the
greater Greensboro area. The FEIS should revisit this and further discuss potential federal or 20-F
non-federal projects and their specific impacts (particularly those impacts similar to the proposed
action) within a 10-15 year horizon
EPA rates this DEIS as an "EO-2," i.e.. we have Environmental Objections to the
Sponsor's proposal and request some additional information in the FEIS. We base this rating
primarily on the fact we do not believe that the DEIS fully describes the proposed air cargo
operations and the associated potential noise impacts, nor fully address the mitigation of those
impacts.
We appreciate the opportunity to review the DEIS. Should you have questions regarding
our comments, feel free to contact Chris Hoberg of my staff at 404/562-9619.
Sincerely,

Heinz J. Mueller, Chief
Office of Environmental Assessment
Environmental Accountability Division
Enclosure
7

I

P

DETAILED COMMENTS

We offer the following detailed comments on the DEIS for FAA's consideration and
incorporation into the FEIS:
? Alternatives
* Sponsor's Preferred Alternative - At this early stage of the NEPA process. the action being
proposed is the Sponsor's (PTAA's) proposed alternative. which may or may of also be 2r
FAA's federal preferred alternative. PTAA has proposed Alternative W2-AtFAA's preferred
alternative will need to be identified in the FEIS and the FAA selected alternative will need to
be identified in the Record of Decision (RODD
LWe suggest that the Sponsor's proposed Alternative W2-A be so-designated (i.e.. as the
Sponsor"s proposal) in tables comparing the various alternatives and also be identified earlier in 2,82.
the documen as the Sponsor's selection In the Executive Summary. it does not become clear
that W2-A is the Sponsor's proposal until page S-11" even though this proposal was depicted
earlier (Fig. S-1: pg. S-3) and compared to other considered alternatives (Fig. S-2 and Table S-1).
Based on Tables S-1 and S-2 comparing alternatives. the Sponsor's Alternative W2-A is
predicted to impact a relatively large amount of wetlands (32.3 ac), a relatively moderate number
of floodplains (36.6 ac). relocate a relatively low number of homes (9) and businesses (10).
conflict with an equal number of hazardous waste sites (6)" impact the least number of people
(531) by a significant +1.5 dB DNL increase in noise. and is the least expensive ($2213M).
The Sponsor's airport selection criteria listed on page S-5, which were apparently best satisfied
v PTIA. include a "no unexpected or unresolvable environmental problems" criterion. The FEIS
should further discuss this concept since the overnight hub operations would result in significant=1 13
noise during late-night and early-morning hours. How do the Sponsor and Airport Authority plan
to resolve the noise elevations for residents living within the DNL >65 dB contours (or even
outside the DNL 65 contour where noise impacts also exist)
* EPA's Preference - EPA has environmental objections with the proposed project: specifically.
' we do not believe the DEIS fully describes the proposed air cargo operations and the associated
potential noise impacts as well as the mitigation of those impacts. Consequently. EPA has
environmental objections with the all of the presented action alternatives for the FedEx hub. and'
therefore prefers the No-Action Alternative (which proposes some airport improvements but no a-
cargo hub at PTIA).e believe that the proposed addition of an overnight cargo operation.
which introduces a new overnight noise, is substantively different from a general expansion of an

?oa?y i
6
airport for capacity, safety or other reasons. EPA further believes that in order for an overnight
air express operation to be reasonable environmentally, it would need to be removed from areas
of public development -- particularly residential communities -- where the airport is surrounded by
compatible land use with minimal sensitive noise receptors.7This does not appear to be the case at
PTIA where single family residences exist in the area, in both the southwest (scattered) and
northeast (concentrated) sections.
Although EPA prefers the No-Action Alternative, we offer the following comments on the five
action alternatives further evaluated in the DEIS:
o WA-2: F-if the Sponsor's proposed Alternative WA-2 is pursued at PTIA, additional
mitigation would be needed to relieve the aircraft noise impacts for all residents within the DNL
65+ dB contours. This would include federal purchase ("buyouts") of impacted residents and
acoustical treatment for remaining affected residences (also see Noise comments below).
H
E

1
o WA-3: This alternative is comparable to WA-2 but has less wetland impact and more
noise impact and relocations.
o N-D and N-E:CRunway alternatives that are oriented in a general north-south '
(technically, a northwest-southeast) direction, i.e., the fifteen X. N and S series alternatives in
Figure S-3 including N-D and N-E. should probably be rejected unless the Greensboro area has S
dramatically shifting wind direction These runways are perpendicular to the existing runway
layout and therefore seem to constitute a traffic controller. safety and efficiency problem. They
would also expose flyover noise issues to a new set of people living near the airport that did not
expect to be directly impacted, based on existing PTIA runways oriented in a general east-west
(technically, northeast-southwest) direction (except for crosswind Runway 14/32). We also note
that Alternative N-D is predicted to have the greatest wetland impact (36.8 ac) of all further
evaluated alternatives.
o WI-A I : LOf the five action alternatives evaluated. EPA believes that Alternative
W 1-A 1. although not without impacts, has some environmental mer Based on Tables S- I and
S-2 comparing alternatives, this alternative is predicted to impact the lowest amount of wetlands 2-86
(27.3 ac), a relatively moderate number of floodplains (25.4 ac), relocate a relatively high number
of homes (47) and businesses (21), conflict with an equal number of hazardous waste sites (6).
impact a relatively low number of people (549) by a significant +1.5 dB DNL increase in noise.
and is relatively inexpensive ($227.3M). This alternative also relocates roadways to areas north
of the proposed cargo runway (Fig. S-3) such that the runway bridge associated with the other
alternatives is avoided (although a taxiing runway bridge would still remain). On the other hand.
road construction impacts for these roadway relocations (including the highest stream relocation
impacts: 15,785.4 linear feet), exist with this alternative as well as a relatively high number of
home/business relocations. However, it is plausible that several of these prospective relocatees
might not oppose leaving the airport area due to increasing noise and other pollutants attributable
to the airport.

? Jr-ovoy

? RSAs and RPZs - Recently in Burbank. CA. a Southwest Airlines jet skidded beyond the
runway into the Runway Safety Area (RSA) and the clear zone (or Runway Protection Zone:
RPZ) and almost crashed into a gas station. ITThe FEIS should discuss FAA's regulations (and/or
any other regulations) regarding RSAs just beyond the end of the runway and the RPZs beyond 30-11
the RSAs in terms of compatible land use in these areas and incompatible land use there. as well
as how this relates to the proposed project,
We note that RPZs were discussed on page S-11 and elsewhere in the alternatives discussion.
Alternative W2-C was in part rejected since the proposed FedEx sorting/distribution center would
be located in the RPZ of proposed Runway 5L/23R. We agree with FAA's Advisory Circular
150/5300-13 concerning RPZs to the extent that it recommends "...that it is desirable that the
"
In fact, EPA believes the required compatible land use in this
RPZ remain clear of all objects.
area should be a cleared RPZ with no or little human interaction.
? Noise - In addition to the noise documentation. effects and mitigation comments provided in
the main letter, we offer the following specific noise concerns:

* Noise Metrics - Due to the unique operational characteristics of air cargo hub facilities, we
believe that disclosure of additional operational/noise information is required. While the
existing information on DNL (the accepted descriptor for airports) and 9-hour Leq (Leq(9)) is
useful, it does not provide a totally accurate view of the additional noise situation, i.e., noisy
takeoff and landing events occurring during a relatively short late-night and early-morning
timeframe. DNL data are based on average daily operations, which are obtained from total
annual operations (total operations divided by 365 days), while Leq(9) data are averaged over
9 hours. As previously noted, FedEx operations will only occur on 260 nights not 365 nights,
and it is also highly unlikely that FedEx operations will occur over a 9-hour period (ref:
supplemental 9-hour Leq data in Appendix B), but more realistically will be compressed into a
four-to-five-hour period.. While the current information/data is correct for the average daily
situation, it understates the noise exposure for an actual operational day since quieter time
periods (i.e., times/days without FedEx flights, holidays, etc.) are also part of the annual
(DNL) and 9-hour (Leq) average. Consequently, the actual noise impact during FedEx take-
offs and landings would be significantly greater than data for the averaged metrics (DNL and
Leq(9)) would suggest. EPA therefore requests that additional supplemental exposure
information/data be provided to more realistically represent the projected situations
F We also note that while the SEL supplemental data (Appendix B) is very useful, an explanation
' of the metric does not appear until Appendix C. This section should highlight the fact that the
SEL is 5-to-10 dB above the Maximum A-weighted sound level. In addition, Appendix C
refers to ALm for Maximum A-weighted sound level, while page 5-4 in Volume 1 refers to
Lmax. The FEIS discussion should be more consistent.

* Air Cargo Operations Air Cargo operations as well as other aircraft operations need to be 3403

,?" j oov -i I

clarified. ! For example page 1-5 (third paragraph), it states that the goal is to have two
widely-spaced parallel runways to support 48 daily FedEx air cargo operations (24 departures
and 24 landings) by 2005. Table 5.1.2-4 shows only 17.1 FedEx departures projected for 3"2Cl
2005, although there are 9.6 other cargo operations projected to occur. The same is true for
data contained in Table 5.1.2-D
* Runway Use Percentagees - A review of runway use percentages (Table 4.2.5-3) for 1998
indicates that Runway 23 is used approximately 75 % of the time for both arrivals and
departures. This is also true for the 2005 and 2009 No-Action Alternative. In Table 5.1.2-7,
it indicates that FedEx will use 23L/23R and 5R/5L for departures and arrivals. LWe believe
that the FEIS should provide wind information with a discussion to support that FedEx can
operate in this manner 95 % of the time
The FEIS needs to provide a discussion that clearly states that 95 % of the night FedEx
operations will take place to the southwest of the airport. This population would live under
both the approaches to runways 23L/23R and the departures on runways 5R/5L and would
therefore be exposed to the majority of FedEx aircraft operational noise. In order to reduce
the noise exposure to the population that lives to the northeast, departures from runway 5L and
arrivals on runway 23R have been restricted. While this may be the preferred operation (based
on averages), there should be some discussion that actual operations may change due to
directions by Air Traffic Control in response to local weather and requests by pilots. We also
believe that as both FedEx and other commercial aircraft operations increase, that there will be
increasing pressure to use Runway 5L for departures and 23R for arrivals. [We recommend
that the FEIS discuss/develop a process that the PTAA and FAA air traffic control will use to
include the public into the decision process when future runway use increases beyond those
stated in the DEIS (2.5 % to 5

r
* Airport Land Use - his clear that land use near airports should be zoned compatible with
noise and air quality impacts associated with airports. Since a northern parallel runway is now
being proposed (and was apparently included in the Master Plan Update for some time), it is
unclear as to why single family residences were allowed to be constructed in areas such as the
above-referenced northeastern section of the PTIA site While we agree that the NEPA
process was not completed at the time nearby residences were sold and that the Master Plan is
a living document that can be modified,;we suggest that the City of Greensboro carefully
consider zoning potential impact areas accordingly and make realtors aware of potential or - ??
planned airport expansions in order to advise home buyers of potential land use conflicts

* Mitigation =EPA believes that an aggressive federal buyout program is needed to
compensate for noise impacts within the DNL 65+ contours. However, we recognize that
complete residential buyouts within these contours is expensive and that current Congressional
allocations may not suffice. We also recognize that worst-case contours should be mitigated
first (DNL 75 and DNL 70 contours) followed by the DNL 65. The previously suggested
participation by the airport authority (PTAA) in the FAA 150 Program could perhaps supplement

F,

1

9
such federal funding limitations and allow for more complete compensation Present and other
FAA EISs should also provide full disclosure of noise impacts within the affected contours
outside of the DNL 65 contour. so that noise impacts will be documented regardless of the
current funding limitations in noise mitigation.
* Editorial - We note that in Appendix B of Volume 2, the supplemental metric data refers to
the 2005 and 2019 cases. We presume that the "2019" horizon year was intended to be
"2009". The FEIS should clarify this. Appendix I (air quality) also refers to 2019 and even
2025 (see specific comments below). The FEIS should discuss if this is accurate and if so,
the reliability of such long-termed projections.
Air Quality - We offer the following comments:
* General Comments
o Conformity - We understand that the FHWA North Carolina Division has determined
that only general conformity and not transportation conformity would apply for the proposed
PTIA project, which includes various transportation actions such as roadway relocations and
runway bridges over roadways. We further understand that FHWA. as a cooperating agency to
FAA for the present EIS, would likely adopt the FAA EIS for their NEPA roadway actions.
Since roadway projects are associated with the PTIA proposal and since FHWA is a cooperating
agency to FAA for the DEIS, the document should substantiate the decision that transportation
conformity does not apply for this proposed project. Transportation conformity mould apply if:
1) FHWA/FTA (Title 23) funds are used for the roadway project(s) and/or FHWA/FTA approval
is required., or 2) the project sponsor is a routine recipient or federal funds and the project is
regionally significant. The transportation conformity requirements would be satisfied if the
roadway project(s) is included in the currently conforming transportation plan/TIP and has not
changed, significantly in design or scope.
o Ozone -Ln order to give a more accurate assessment of the current state of air quality 74(o
in Guilford County, the FEIS should note that the county will likely be designated nonattainment
under the eight-hour ozone standard (e.g., pg. 4-61)'-
o Ground Transportation Emissions -1 The details of the analysis for ground ,,7
transportation emissions (e.g.. MOBILE,,input files. VMT, speeds) are not contained in the DEIS. ?'3
These should be contained in Appendix I,,)
* Specific Comments
o Pa. 4-61 (First Full Paragraph. Line 5) - The phrase "Nonattainment areas are further
classified as extreme..." should read "Ozone nonattainment areas are further classified as
extreme..."

10 t
o P2.4-61 (Second Paragraph of Section 4.3.6-2) -CO, should be added to the list of _
exhaust gas emissions from aircraft engines. It is a major aircraft exhaust gas and a greenhouse
gas.
o Pg. 4-62 - The term budget is used several times where it should read inventory.
o Pg. 5-74 (Section 5.5.2.4, Line _4) - "' f the airport, the emissions inventory includes
all motor vehicles traveling to, from and around the airport on..." The emissions impacts of
off-airport motor vehicles should include the emissions over the entire trip to/from the airport
from/to the trip origin/destination, not just in the vicinity of the airport. This can be estimated by
using the Piedmont Triad Regional travel demand model. This requirement is satisfied if the
proposed airport and runway improvements and the associated effects on trip-making in the
region are included in the currently conforming transportation plan/TIP 1
o Pg 5-77( Last Bullet of Section 5.5.4) - "The vast majority (74 percent) of emissions
associated with PTIA continue to be in the form of CO, followed by NOx (18 percent) and VOCs
(7 percent)." This comparison is not relevant.
o P2. 5-185 (First Paragraph of Section 5.19.3.1, Line 4 From Bottom) - Refer to the
sentence "Turbidity is considered a short-term impact because the elevated suspended solids
creating turbid conditions tend to dissipate soon after the land disturbance commences." The last
word of this sentence should read "concludes" or "ends", not "commences." This also occurs in
other areas of the text.
o PP. 6=10 iIn addition to infrastructure that helps reduce emissions by reducing the ? O
h
ld i
l
d
i
i
l
i
i
i
on measures s
ou
nc
u
e
dling, the poss
b
e m
t
gat
probability of on-site congestion and
strategies to reduce single-occupancy vehicle travel. increase high-occupancy vehicle travel.
and encourage transit ridership to/from the airport (if transit is available). '
o Pg. 6-11 -During the construction phases, a possible mitigation measure would be to ' s
give special consideration to contractors that use equipment that produce lower emissions
through diesel retrofit or other technologies
o Appendix I, pg. 2-2 -What is the basis for directing mixed use growth around various *? r
h 2025 f
f
i
2006
h
f
on
or purposes_o
transportat
rom years
t
roug
nodes throughout the Triad
modeling? Is this growth strategy enforceable or merely an aspiration?-,
o Appendix 1. 12g. 2-2 -The FEIS should contain the updated traffic forecast for the
No-Action Alternative. including the new interchanges at Bryan Blvd. and Old Oak Ridge Rd. and
the relocation of Regional Rd. Furthermore, the report should make it clear that the No-Action
ground transportation ,improvements have been included in the area's approved transportation plan
(and TIP. if applicable) This is implied in Appendix I, p. 2-5, but does not appear to be explicitly

L

11?
L-A

?rov-?y
stated.
o Appendix I, pg. 2-3 -)The discrepancies between build-out employment numbers among 7:23
the alternatives should be resolved and a consistent set of numbers should be used for the FEIS
analysis.
o Appendix I, pg. 2-3 -/'The FEIS should explain how the 2019 traffic projections were 27_Zq
adjusted upward using the 2025 projections with the projected air cargo facility employment
o Appendix I, pg. 2-3 (The FEIS should explain why it is expected that interpolating - s
between the 2019 adjusted traff c projections and the 1994 base year traffic to project horizon
year 2005 traffic would provide a more accurate prediction? More accurate than what?'
o Appendix I, pp,. 5-13 Section 5.5.7, Line 31 At is not necessarily true that "any
provisions for or enhancements to roadway or intersection projects that permit free-flow and
high-speed travel would have corresponding benefits to air quality." The MOBILES emission
factors for NOx and VOCs have minima in the intermediate speed ranges and increase at higher
speed For example: Strategies that reduce vehicle-miles traveled, combine trip-making,
encourage carpooling and encourage the use of alternative modes of transportation, do reduce
emissions and should be considered as possible mitigation measures.
? Wetlands and Water Quality - For the evaluated action alternatives, wetland losses are
predicted to range from 27.3 to 36.8 acres. The No-Action Alternative preferred by EPA is
predicted to impact approximately two-thirds less acreage (9.8 ac).
Wetland impacts and acreages are discussed in Table 5.11.2-1. Stream relocations are also
quantified in linear feet and ponds in -acres. Howeverotal wetland acreages do not include
stream relocation impacts (although pond acreages were included). Total wetland acreages
should reflect all three categories (floodplain wetlands, streams and ponds), since waterways are
also considered wetlands. The FEIS should show both dissected (individual) and lumped (total)
values for these wetland categories and report totals (or individuals and totals) in summary tables
such as Table S-2;
2 q-2 4
IgIJ0
-The quality of the wetlands directly and indirectly impacted should be better documented. For
example, terms such as Fooodplain Swamp used in Table 5.11.2-1 should be qualified (perhaps
in a footnote or in the text or appendix) to better determine quality and vegetation type (forested.
emergent, herbaceous, etc.). Based on the State's (Division of Water Quality) assigned 90 rating
for several of the wetlands discussed on the site, we assume that the wetland quality is generally
good and that the wetlands are functional. The specific functions oPhe wetlands (water quality,
habitat, ground-water recharge. etc.) should be provided in the FEIS.
Any unavoidable direct and secondary wetland impacts should be fully mitigated through
coordination with the U.S. Army Corps of Engineers (COE) and other agencies. Mitigative

Jf-?v'??f
12
approaches for wetland restoration, enhancement, creation, banking and/or acquisition should be
discussed. We note (pg. 5-141) that consultation with the COE and the State of North Carolina
has been initiated. EPA and the U.S. Fish and Wildlife Service (FWS) should also be included in
such consultation. Mitigative methods should result in the maintenance of existing wetland
functions to the extent feasible.
Although possible mitigative measures for wetland, floodplain and other losses were discussed
in the DEIS, no FAA commitment to ultimately mitigate was offered in the DEIS. Since
coordination with the COE and State are ongoing, inclusion of final mitigation plans is
presumably premature. If so, a commitment for FAA to provide all reasonable mitigation
measures requested by the resource agencies should nevertheless have been included in the
DEIS. If a final mitigation plan is not completed and included in the FEIS, a draft final plan
act
redicted wetland losses/im
ate
it
t
t
iti
FAA
h
l
i
l
d
d
i
p
p
comm
men
.
o m
g
ong w
an
t
nc
u
e
a
should be
? Hazardous Materials -Flable S-1 relates that all action alternatives are predicted to
conflict with six potentially hazardous material sites. However, review of Section 5.20 t
o
suggests that although old UST sites exist, other sites may only be suspected sites of
contamination. Coordination with EPA Region 4 and/or the State should nevertheless be
pursued to determine appropriate action. These sites should either be avoided, suitably
cleaned up, or suitably capped to allow unrestricted or designated use of the area.
? Environmental Justice (EJ) - Alternative screening Table S-2 indicates that no EJ impacts
exist for any of the action alternatives or the No-Action Alternative. Because of this conclusion,
Page 5-55 relates that no mitigation measures were offered. In addition to our comments in the
main letter, we offer the following:
In regard to the EJ analysis in the DEIS, we appreciate that demographic data were provided in
Chapter 4 on Table 4.2.2-9. From this table, we note that Guilford County has a slightly elevated
but still comparable percentage of African-Americans (26.4%) compared to the State of North
Carolina (22.0%). However,(nno site-specific demographic U.S. Census data were noticed. i.e.. _ c-
demographic percentages for the specific Census Block Group and its possible Sub-Group(s)
containing the project site. The FEIS should provide such information for all minorities This
would help insure that no "pockets"of minority concentrations are located at the PTIA site that
might be affected but were not obvious from the County average. Sub-Group percentages should
then be compared to the minority percentages for Block Groups, Guilford County, and the State
to determine if percentages are similar or if concentrations of minorities exist at PTIA and that
there is potential for disproportionate impacts to minorities.
1 Consistent with Executive Order 12898, another component of EJ are low-income populations.
As in the case for minorities, the percentage of low-income populations of the site should be compared to percentages of nearby areas using Census data for area designations such as Block
Groups, etQTable 4.2.2-11 provides low-income group data for populations in poverty and
,families in poverty for the U.S.. State, Guilford County, and the study area. Based on the

J; ova ?
13
percentages provided, we note that the study area has less poverty than the State or the U.S..
which suggests that there probably is no EJ impact for low-income populations. However. not all
of the data ar readily comparable since some are presented as percentages and others as actual
1
?'?
numbers (i.e.?the FEIS should provide a low-income percentage for Guilford County In Z
addition, the term study area is not defined in the table so that it is unclear if a conventional U.S.
Census Block Group or Sub-Block Group was used or another area designation (e.g., a five-mile
radius around the airport) was used. The FEIS should document and discuss, with an EJ impact
reassessment being provided.
If the site area contains a significantly greater percentage for minorities and/or low-income
populations than the surrounding area (Block Group and County) and the proposed project has
significant impacts (e.g., noise), then a potential EJ impact may exist for affected populations.
The FEIS should assess this. It should be noted that additional EJ assessment techniques are
available through EPA.
In the event an EJ impact does exist. the FEIS should discuss for which alternatives it exists
and prospective mitigation. Mitigation might include selection of the No-Action Alternative or