20191081 Ver 1_Public Notice_20190821

US Army Corps PUBLIC NOTICE
Of Engineers
Wilmington District
Issue Date: August 21, 2019
Comment Deadline: September 20, 2019
Corps Action ID Number: SAW -2017-00103
The Wilmington District, Corps of Engineers (Corps) received an application from the
Piedmont Triad Airport Authority (PTAA) seeking Department of the Army
authorization to discharge dredged or fill material into 383 linear feet of stream channel,
0.08 acre of wetlands, and 1.72 acres of open water, and temporarily discharge dredged
or fill material into 0.02 acre of wetlands, associated with the relocation of existing rental
car facilities in order to eliminate a "I i ne-of-si ght" issue for a proposed air traffi c control
tower at the Piedmont Triad International Airport (GSO), in Greensboro in Guilford
County, North Carolina.
Specific plans and location information are described below and shown on the attached
plans. This Public Notice and all attached plans are also available on the Wilmington
District Web Site at
http://www.saw.usace.army.mil/Missions/Re ug IatoryPermitProgra�aspx
Applicant: Mr. J. Alex Rosser, P.E.
Piedmont Triad Airport Authority
1000A Ted Johnson Parkway
Greensboro, North Carolina 27409
Agent: Mr. Richard B. Darling
Michael Baker International
200 Centreport Drive, Suite 350
Greensboro, North Carolina 27409
Authority
The Corps evaluates this application and decides whether to issue, conditionally issue, or
deny the proposed work pursuant to applicable procedures of the following Statutory
Authorities:
❑ Section 404 of the Clean Water Act (33 U.S.C. 13 44)
❑ Section 10 of the Rivers and Harbors Act of 1899 (33 U.S.C. 403)
❑ Section 103 of the Marine Protection, Research and Sanctuaries Act of 1972
(33 U.S.C. 1413)
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Location
Location Description
Project Area (acres): —188 Nearest Town: Greensboro
Nearest Waterway: Unnamed Tributaries to Brush Creek and Horsepen Creek
River Basin: Cape Fear
Latitude and Longitude: 36.120991 N, -79.911210 W
Existing Site Conditions
The proposed project area (see Federal Aviation Administration [FAA] Environmental
Assessment [EA] Section 1 Figure 1.) is located within the Carolina Slate Belt of the
R edmont Physiographic Province. This region's geology consists of weakly
metamorphosed sedimentary and volcanic rocks. Project area geomorphology generally
includes flat and developed uplands bisected by relatively narrow undeveloped drainages
sloping south to north in the vicinity of the proposed Worldwide Drive/Air Cargo and
Chimney Rock/Spoil Embankment sites, and from north to south in the vicinity of the
proposed Inman/Rental Car Facilities site. Elevation across the sites range from
approximately 904 feet above mean sea level (MSL) in the vicinity of the Worldwide
Drive/Air Cargo site, to 812 feet MSL in the downstream extent of the undeveloped
drainage in the Chimney Rock/Spoil Embankment site. Soils within the three component
locations (Chimney Rock, Inman, and Air Cargo sites) are mapped as Clifford sandy
loam (CkB, CkC), Clifford sandy clay loam (C1B2, C1C2), Iredell fine sandy loam (IrB),
Mecklenburg sandy clay loam (MhB2, MhC2), Poplar Forest sandy loam (PoC), Poplar
Forest clay loam (PpC2, PpD2, PpE2), and Urban land (Ur) mapping units. None of these
series are included on the 2014 National Hydric Soils List for Guilford County, North
Carolina. Average annual precipitation for Guilford County is 43.1 inches.
Historically, land use in this area of the North Carolina Piedmont was primarily farming,
with forested areas on the steeper slopes and bottomlands. Airport runways appear on
topographic maps of the current Piedmont Triad International Airport (GSO) property as
early as 1952 (just west of the proposed project areas), with the three component
locations (Chimney Rock, Inman, and Air Cargo sites) themselves a mixture of pasture,
row crops, forest, and widely scattered residential landuses according to 1955 aerial
photography. Existing development directly to the south of the proposed Worldwide
Drive/Air Cargo site took place between 1982 and 1993. The Chimney Rock and Inman
sites have remained generally undeveloped.
The undeveloped portions of the three component locations include maintained/disturbed
and early -mid successional mixed pine/hardwood forest terrestrial communities with
small streams, impoundments, and adjacent wetlands.
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Forested uplands consist of canopy species such as loblolly pine (Pinus taeda), Virginia
pine (Pinus virginiana), red maple (Acer rubrum), tulip poplar (Liriodendron tulipifera),
sweetgum (Liquidambar styraciflua), white oak (Quercus alba), southern red oak
(Quercus falcata), northern red oak (Quercus rubra), mockernut hickory (Carya
tomentosa), and black cherry (Prunus serotina). Understory species including canopy
species as well as American beech (Fagus grandifolia), red mulberry (Morus rubra),
persimmon (Diospyros virginiana), American holly (Ilex opaca), eastern red cedar
(Juniperus virginiana), flowering dogwood (Cornus florida), and sassafras (Sassafras
albidum). In mesic areas near streams and wetlands, species adapted to wetter conditions
such as willow oak (Quercus phellos), American elm (Ulmus americana), green ash
(Fraxinus pennsylvanicum), redbud (Cercis canadensis), river birch (Betula nigra), black
willow (Salix nigra), tag alder (Alnus serrulata), ironwood (Carpinus caroliniana), and
tulip poplar tend to dominate the canopy and sapling layers. Shrubs are thickest along
woodland edges and in mesic areas near streams, wetlands and pond edges, including
species such as Chinese privet (Ligustrum sinense), autumn olive (Elaeagnus umbellate),
highbush blueberry (TVaccinium corymbosum), strawberry bush (Euonymus americanus),
spicebush (Lindera benzoin), and various sedges. Vines present include poison ivy
(Toxicodendron radicans), Japanese honeysuckle (Lonicera japonica), Virginia creeper
(Parthenocisus quinquifolia), common greenbrier (Smilax rotundifolia), and muscadine
grape (Tlitis rotundifolia). Herbs within this community are sparse to frequent and include
Christmas fern (Polystichum acrostichoides), rattlesnake fern (Botrychium virginianum),
ebony spleenwort (Asplenium platyneuron), Japanese stilt grass (Microstegium
vimineum), large whorled pogonia (Isotria verticillate), Indian cucumber -root (Medeola
virginiana), Solomon's seal (Polygonatum biflorum), wild ginger (Asarum canadense),
ground cedar (Lycopodium complanatum), and spotted wintergreen (Pyrola americana).
The developed portions around these component locations are primarily roads, aircraft
hangars, concrete aprons, taxiway connectors, and support facilities, including parking
lots and stormwater ponds.
General area land use includes GSO and associated development, commercial and
industrial development to the south of GSO, and residential land to the north of GSO, as
well as several large state maintained highways (1-40,1-73,1-840). The Worldwide
Drive/Air Cargo site is surrounded by existing GSO development, with the exception of a
wooded area to its north that extends into wetland areas along Brush Creek preserved as
part of prior GSO permit requirements. The Chimney Rock site is bordered by existing
GSO and related infrastructure to the northwest and southwest, a currently undeveloped
area to the northeast, and Interstate Highway 840 (I-840) on the southeast. The Inman site
is bordered to the east, south, and northwest by I-840, Bryan Boulevard, and Inman Road,
respectively, and by commercial property to the northeast.
Michael Baker Engineering, Inc. conducted a jurisdictional delineation for the proposed
Worldwide Drive/Air Cargo site in 2015; the jurisdictional boundaries were verified by
the Corps, and a Jurisdictional Determination was approved on March 9, 2015 (Corps
Action ID: SAW -2015-00091).
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Pilot Environmental, Inc. conducted jurisdictional delineations for the Chimney Rock and
Inman sites in 2017, the jurisdictional boundaries at each site were verified by the Corps,
and Jurisdictional Determinations were approved on March 14, 2017 (Corps Action ID:
SAW-2017-00101) and March 17, 2017 (Corps Action ID: SAW-2017-00103 for the
Chimney Rock and Inman sites, respectively). All streams on these sites are considered
Relatively Permanent Waters, have intermittent or perennial flow regimes, and are
unnamed tributaries to Brush Creek or Horsepen Creek, which flow via Horsepen Creek
and Reedy Fork to the Haw River, a Traditionally Navigable Water. These streams all
carry the NC Division of Water Resources (NCDWR) best usage classification of "WS-
NSW." WS-III refers to those waters used as water supply for drinking, culinary, or
food processing purposes where a WS-I or II classification is not feasible. WS-III waters
are generally in low to moderately developed watersheds. NSW is a supplemental
classification intended for waters needing additional nutrient management due to being
subject to excessive growth of microscopic or macroscopic vegetation. There are no
designated Outstanding Resource Waters (ORW), High Quality Waters (HQW), Water
Supply I (WS-1), or Water Supply (WS-II) waters within 1.0 mile of the project area.
The wetlands within the proposed project component areas are all of the Headwater
Forest wetland type, according to the North Carolina Wetland Assessment Method
(NCWAM). These on-site features generally have plant assemblages containing trees and
shrubs such as red maple, sweetgum, and tulip poplar, and understory species such as soft
rush (Juncus effusus), Japanese stilt grass, blackberry (Rubus argutus), and common
greenbrier. Soils within these features are primarily loamy with a low chroma (10YR 6/1)
matrix and bright (7.5YR 5/8) redoximorphic concentrations. Typical of wetlands in
small stream valleys, these wetlands display hydrology indicators such as high water
tables, soil saturation, and water stained leaves.
Applicant's Stated Purpose
The purpose of the proposed project, as stated by the applicant, is the following:
The purpose of the Proposed Action is to eliminate a "line -of -sight" issue for the
proposed air traffic control tower (ATCT) created by existing rental car facilities, thereby
requiring the relocation of the facilities posing visibility obstructions. The Proposed
Action must be implemented in accordance with FAA design standards and Federal
Aviation Regulations while maintaining rental car service provider neutrality. Because
the parameters of the ATCT line -of -sight are not flexible, the only viable alternative is to
eliminate the obstruction and move the subject facilities.
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Background
Previous DA authorizations at GSO include the following permanent impacts to waters of
the US:
* NWP = Nationwide Permit; IP = Individual Permit.
**These projects were never constructed and the permits are expired; not included in total impacts.
The previously issued IP involving Runway 5L/23R and an overnight express cargo
facility at GSO (Corps Action ID SAW -2000-21655) authorized the currently proposed
stream impacts for the Worldwide Drive/Air Cargo site (see part 2 of the "Project
Description" section below). However, the IP expired without that section of the
overnight express cargo facility being constructed, and therefore the impacts proposed as
part of the Worldwide Drive/Air Cargo project component must be re-evaluated as newly
proposed impacts.
Project Description
The Piedmont Triad Airport Authority (PTAA) is obligated to remove obstructions to the
visibility of Taxiway E from the new proposed ATCT as determined by the FAA
Comparative Safety Analysis (FAA EA Appendix A). The Proposed Action includes the
following four components (FAA EA Section 1 Figure 2):
1) Site preparation and stabilization of approximately 49 acres of developed land
including Removal of Existing Rental Car Facilities and adjacent air cargo
structures and re -grading to allow line -of -sight from the ATCT to Taxiway E. See
FAA EA Section 1 Figure 3 and FAA EA Appendix A-2 "Site 1 —Existing Rental
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Stream
Wetland
Open Water
Action ID
Project Name
Date
Permit
Impacts
Impacts
Impacts
Type
(linVerified/Issued
ear feet
acres
acres
SAW -2015-00920
HAECO
April 25, 2015
IP
1,601
0.81
---
Stormwater outfall
NWP
SAW-2015-00091**
March 9, 2015
18
---
---
repair
18
Cross -field Taxiway/
SAW -2012-01547
Phase I Northwest
March 15, 2016
IP
394
---
5.96
Site Development
SAW -2011-01169
Honda Jet facility
December 19, 2012
NWP
136
---
---
connector
18
SAW -2007-00602
Ballinger Road
February 12, 2007
NWP
100
---
---
extension
14
SAW -2006-41354**
Runway Safety Area
February 14, 2008
IP
674
0.09
---
Improvements
Runway 5L/23R and
SAW -2000-21655
overnight express
December 8, 2003
IP
12,719
22.68
---
cargo facility
Runway 14 Safety
NWP
SAW -1998-20865
Area extension
May 21, 1998
23
760
0.3
---
SAW -1991-02137
Air cargo expansion
July 31, 1991
NWP
---
3
---
sediment basin
26
Total
15,710
26.79
5.96
* NWP = Nationwide Permit; IP = Individual Permit.
**These projects were never constructed and the permits are expired; not included in total impacts.
The previously issued IP involving Runway 5L/23R and an overnight express cargo
facility at GSO (Corps Action ID SAW -2000-21655) authorized the currently proposed
stream impacts for the Worldwide Drive/Air Cargo site (see part 2 of the "Project
Description" section below). However, the IP expired without that section of the
overnight express cargo facility being constructed, and therefore the impacts proposed as
part of the Worldwide Drive/Air Cargo project component must be re-evaluated as newly
proposed impacts.
Project Description
The Piedmont Triad Airport Authority (PTAA) is obligated to remove obstructions to the
visibility of Taxiway E from the new proposed ATCT as determined by the FAA
Comparative Safety Analysis (FAA EA Appendix A). The Proposed Action includes the
following four components (FAA EA Section 1 Figure 2):
1) Site preparation and stabilization of approximately 49 acres of developed land
including Removal of Existing Rental Car Facilities and adjacent air cargo
structures and re -grading to allow line -of -sight from the ATCT to Taxiway E. See
FAA EA Section 1 Figure 3 and FAA EA Appendix A-2 "Site 1 —Existing Rental
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Car Facilities —Existing Conditions" and "...Proposed Conditions." No impacts
to waters of the US are proposed for this project component,
2) Site preparation (including hauling of approximately 300,000 cubic yards clean
fill from the existing rental car facilities, above) of approximately 44 acres of
approved future aerospace development. Adjacent to this location, approximately
10 acres of clearing and grading for construction and continuation of utilities
along the proposed Worldwide Drive right-of-way, including electrical/lighting,
communications, and stormwater management (Air Cargo site). See FAA EA
Section 1 Figure 4 and FAA EA Appendix A-2 "Site 2 —Proposed Worldwide
Drive and Future Aerospace Development— Existing Conditions" and
"...Proposed Conditions." This project component would result in permanent
impacts (loss of waters) to 383 linear feet of stream channel;
3) Site preparation of approximately 57 acres of land including clearing and grading
for construction of paved parking areas for approximately 2,360 spaces and
infrastructure for approximately 16,900 square feet building space, including
connection of utilities, stormwater management, and communications for the
proposed New Rental Car Facilities (Inman site). See " Wetl and, Surface Water
and Ri pari an Buffer I mpacts" Sheets 1-4, FAA EA Section 1 Figure 5, and FAA
EA Appendix A-2 " Ste 3 — New Rental Car Facility (Inman Road) — Existing
Conditions" and "...Proposed Conditi ons." This project component would result
in permanent impacts (loss of waters) to 0.08 acre of wetlands and 1.72 acres of
open water, and temporary impacts to 0.02 acre of wetlands; and
4) Site preparation and stabilization of approximately 28 acres for proposed Spoil
Embankment of approximately 600,000 cubic yards of clean fill (from the Inman
site, above) adjacent to and north of the Honda Aircraft Company Maintenance
Repair and Overhaul (MRO) facility (Chimney Rock site). See FAA EA Section 1
Figure 6 and FAA EA Appendix A-2 "Site 4 — Spoil Embankment (Chimney
Rock Site) — Existing Conditions" and "...Proposed Conditions." No impacts to
waters of the US are proposed for this project component.
Project completion would be anticipated at least two years after commencement.
Additional information including the above reference figures and plans are also available
on the Wilmington District Web Site at
http://www.saw.usace.aimy.mil/Missions/Re ug latoiyPermitPro r� amaspx
Avoidance and Minimization
The applicant provided the following information in support of efforts to avoid and/or
minimize impacts to the aquatic environment:
MI Efforts to avoid impacts to environmental resources through alternatives analysis are
detailed in Section 3 of the EA, dated July 12, 2019, prepared by the FAA and
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available as supplemental information on the District Website at
http://www.saw.usace.aimy.mil/Missions/Re ug latoiyPermitPro r� amaspx.
MI Construction of stream culverts will minimize smothering of organisms by utilizing
" pump -around"; mini mi ze construction time, control turbidity through adherence to
the Erosion and Sedimentation Control (E&SC) Plan, avoid unnecessary discharge,
prevent creation of standing water, and prevent drainage of wet areas,
i; During construction, physiochemical conditions will be maintained, and potency and
availability of pollutants will be reduced, material to be discharged will be limited;
treatment substances may be added if necessary, chemical flocculants may be utilized
to enhance the deposition of suspended particulates in appropriate disposal areas;
e° The effects of dredged or fill material may be controlled by selecting discharge
methods and disposal sites where the potential for erosion, slumping or leaching of
materials into the surrounding aquatic ecosystem will be reduced. These methods
include using containment levees, sediment basins, and cover crops to reduce erosion;
g; Discharge effects will also be controlled by containing discharged material properly
to prevent point and nonpoint sources of pollution, and timing the discharge to
minimize impact, for instance during periods of unusual high-water flows,
e° The effects of a discharge will be minimized by the manner in which it is dispersed,
such as, where environmentally desirable, orienting dredged/fill material to minimize
undesirable obstruction to the surface water or natural flow, and utilizing natural
contours to minimize the size of the fill, using silt screens or other appropriate
methods to confine suspended particulates/turbidity to a small area where settling or
removal can occur, selecting sites or managing discharges to confine and minimize
the release of suspended particulates to give decreased turbidity levels and to
maintain light penetration for organisms; and setting limitations on the amount of
material to be discharged per unit of time or volume of receiving water,
Discharge technology will be adapted to the needs of the site. The applicant will
consider using appropriate equipment or machinery, including protective devices, and
the use of such equipment in activities related to the discharge of dredged or fill
material, employing appropriate maintenance and operation on equipment or
machinery, including adequate training, staffing, and working procedures; using
machinery and techniques that are especially designed to reduce damage to streams;
designing access roads and channel spanning structures using culverts, open channels,
and diversions that will pass both low and high water flows, accommodate fluctuating
water levels, and maintain circulation and faunal movement; employing appropriate
machinery and methods of transport of the material for discharge,
t; Minimization of adverse effects on populations of plants and animals will be achieved
by minimizing changes in water flow patterns which would interfere with the
movement of animals, managing discharges to avoid creating habitat conducive to the
development of undesirable airport wildlife hazards; avoiding sites having unique
habitat or other value, including habitat of threatened or endangered species; using
planning and construction practices to institute habitat development and restoration to
produce a new or modified environmental state of higher ecological value by
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displacement of some or all of the existing environmental characteristics; timing
discharge to avoid spawning or migration seasons and other biologically critical time
periods; and avoiding the destruction of remnant natural sites within areas already
affected by development.
Compensatory Mitigation
The applicant offered the following compensatory mitigation plan to offset unavoidable
functional loss to the aquatic environment:
In order to comply with FAA wildlife hazard avoidance protocols (FAA AC 150/5200-
33B) and the United States Environmental Protection Agency (USEPA) mitigation rule,
unavoidable impacts are proposed to be mitigated off-site. There are no adjacent
resources which would be impacted or require mitigation as a result of the Project.
Impacts to any nearby jurisdictional streams or wetlands will be avoided. Proposed
impacts to 1,221 linear feet of stream tributary to Brush Creek located at the Air Cargo
site have already been mitigated at the Causey Farm Mitigation site under Corps Action
ID SAW -2000-021655 (DWR File 00-0846), deemed successful in 2009 and 2010.
Mitigation required based on proposed impacts is estimated at 0.16 Wetland Mitigation
Units (WMU) based on 1:1 replacement for 0.07 acres LOW rated wetland WD4 and 3:1
replacement for 0.03 HIGH rated wetland WD2 impacts. 2.08 WMU are currently
avail able at PTAA' s Causey Farm mitigation site for use on future GSO projects, pending
Corps review and approval. PTAA is hereby requesting approval to apply 0.16 WMU
available at Causey Farm to mitigate the proposed GSO Rental Car Facilities Relocation
project impacts. The mitigation proposed will thus meet the estimated requirement.
Essential Fish Habitat
Pursuant to the Magnuson -Stevens Fishery Conservation and Management Act, this
Public Notice initiates the Essential Fish Habitat (EFH) consultation requirements. The
Corps' initial determination is that the proposed project would not effect EFH or
associated fisheries managed by the South Atlantic or Mid Atlantic Fishery Management
Councils or the National Marine Fisheries Service.
Cultural Resources
Pursuant to Section 106 of the National Historic Preservation Act of 1966, Appendix C of
33 CFR Part 325, and the 2005 Revised Interim Guidance for Implementing Appendix C,
the District Engineer consulted district files and records and the latest published version
of the National Register of Historic Places and initially determines that:
Properties ineligible for inclusion in the National Register are present within the
Corps' permit area; there will be no historic properties affected by the proposed
work. The Corps subsequently requests concurrence from the SHPO (or TIIPO).
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See section 4.7 of the EA, dated July 12, 2019, prepared by the FAA and
available as supplemental information on the District Website at
http://www.saw.usace.aimy.mil/Missions/Re ug latoiyPermitPro r� amaspx.
The District Engineer's final eligibility and effect determination will be based upon
coordination with the SHPO and/or THPO, as appropriate and required, and with full
consideration given to the proposed undertaking's potential direct and indirect effects on
historic properties within the Corps-indentified permit area.
Endangered Species
FXI The Corps determines that the proposed project
may affect, not likely to adversely affect federally listed endangered or threatened
species or their formally designated critical habitat.
The Corps initiates consultation under Section 7 of the ESA and will not make
a permit decision until the consultation process is complete.
This determination is made specific to the Schwei nitz' s sunflower (Helianthus
schweinitzii) and small whorled pogonia (Isotria medeoloides). The nearest
known populations for small whorled pogoni a and Schwei ni tz' s sunflower are
greater than 18 miles to the east and greater than 20 miles to the southeast,
respectively. Further, the application stated that there was no suitable habitat for
small whorled pogonia or Schwa nitz' s sunfl ower at the project site.
FXI The Corps determines that the proposed project may affect federally listed
endangered or threatened species or their formally designated critical habitat.
The Corps reviewed this project in accordance with (IAW) the NLEB Standard
Local Operating Procedures for Endangered Species (SLOPES) between the
USAGE, Wilmington District, and the Asheville and Raleigh USFWS Offices,
and determined that the action area for this project is located outside of the
highlighted areas/red 12 -digit HUCs and activities in the action area do not
require prohibited incidental take; as such, this project meets the criteria for the
4(d) rule and any associated take is exempted/excepted.
Pursuant to the Endangered Species Act of 1973, the Corps reviewed the project area,
examined all information provided by the applicant and consulted the latest North
Carolina Natural Heritage Database. Based on available information:
The Corps determines that the proposed project would not affect federally listed
endangered or threatened species or their formally designated critical habitat.
This determination is made specific for the Cape Fear shiner (Notropis
mekistocholas), Roanoke logperch (Percina rex), and Atlantic pigtoe (Fusconaia
masoni), whose habitat ranges do not include the project vicinity.
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FXI The Corps determines that the proposed project
may affect, not likely to adversely affect federally listed endangered or threatened
species or their formally designated critical habitat.
The Corps initiates consultation under Section 7 of the ESA and will not make
a permit decision until the consultation process is complete.
This determination is made specific for Schwei nitz' s sunflower (Helianthus
schweinitzii) and small whorled pogonia (Isotria medeoloides). The nearest
known popul ati ons for smal I whorled pogoni a and Schwei nitz' s sunflower are
greater than 18 miles to the east and greater than 20 miles to the southeast,
respectively. Further, the application stated that there was no suitable habitat for
small whorled pogonia or Schwa nitz' s sunfl ower at the project site.
The Corps determines that the proposed project may affect federally listed
endangered or threatened species or their formally designated critical habitat.
The Corps reviewed this project in accordance with (IAW) the NLEB Standard
Local Operating Procedures for Endangered Species (SLOPES) between the
USAGE, Wilmington District, and the Asheville and Raleigh USFWS Offices,
and determined that the action area for this project is located outside of the
highlighted areas/red 12 -digit HUCs and activities in the action area do not
require prohibited incidental take; as such, this project meets the criteria for the
4(d) rule and any associated take is exempted/excepted.
Other Required Authorizations
The Corps forwards this notice and all applicable application materials to the appropriate
State agencies for review.
North Carolina Division of Water Resources (NCDWR): The Corps will generally not
make a final permit decision until the NCDWR issues, denies, or waives the state
Certification as required by Section 401 of the Clean Water Act (PL 92-500). The receipt
of the application and this public notice, combined with the appropriate application fee, at
the NCDWR Central Office in Raleigh constitutes initial receipt of an application for a
401 Certification. A waiver will be deemed to occur if the NCDWR fails to act on this
request for certification within sixty days of receipt of a complete application. Additional
information regarding the 401 Certification may be reviewed at the NCDWR Central
Office, 401 and Buffer Permitting Unit, 512 North Salisbury Street, Raleigh, North
Carolina 27604-2260. All persons desiring to make comments regarding the application
for a 401 Certification should do so, in writing, by September 10, 2019 to:
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NCDWR Central Office
Attention: Ms. Karen Higgins, 401 and Buffer Permitting Unit
(USPS mailing address): 1617 Mail Service Center, Raleigh, NC 27699-1617
Or,
(physical address): 512 North Salisbury Street, Raleigh, North Carolina 27604
North Carolina Division of Coastal Management (NCDCM):
❑ The application did not include a certification that the proposed work complies
with and would be conducted in a manner that is consistent with the approved
North Carolina Coastal Zone Management Program. Pursuant to 33 CFR 325.2
(b)(2) the Corps cannot issue a Department of Army (DA) permit for the
proposed work until the applicant submits such a certification to the Corps and
the NCDCM, and the NCDCM notifies the Corps that it concurs with the
applicant's consistency certification. As the application did not include the
consistency certification, the Corps will request, upon receipt„ concurrence or
objection from the NCDCM.
❑ Based upon all available information, the Corps determines that this application
for a Department of Army (DA) permit does not involve an activity which would
affect the coastal zone, which is defined by the Coastal Zone Management (CZM)
Act (16 U.S.C. § 1453).
Evaluation
The decision whether to issue a permit will be based on an evaluation of the probable
impacts including cumulative impacts of the proposed activity on the public interest. That
decision will reflect the national concern for both protection and utilization of important
resources. The benefit which reasonably may be expected to accrue from the proposal
must be balanced against its reasonably foreseeable detriments. All factors which may be
relevant to the proposal will be considered including the cumulative effects thereof;
among those are conservation, economics, aesthetics, general environmental concerns,
wetlands, historic properties, fish and wildlife values, flood hazards, flood plain values
(in accordance with Executive Order 11988), land use, navigation, shoreline erosion and
accretion, recreation, water supply and conservation, water quality, energy needs, safety,
food and fiber production, mineral needs, considerations of property ownership, and, in
general, the needs and welfare of the people. For activities involving the discharge of
dredged or fill materials in waters of the United States, the evaluation of the impact of the
activity on the public interest will include application of the Environmental Protection
Agency's 404(b)(1) guidelines.
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Commenting Information
The Corps of Engineers is soliciting comments from the public, Federal, State and local
agencies and officials, including any consolidated State Viewpoint or written position of
the Governor, Indian Tribes and other interested parties in order to consider and evaluate
the impacts of this proposed activity. Any comments received will be considered by the
Corps of Engineers to determine whether to issue, modify, condition or deny a permit for
this proposal. To make this decision, comments are used to assess impacts on endangered
species, historic properties, water quality, general environmental effects and the other
public interest factors listed above. Comments are used in the preparation of an
Environmental Assessment (EA) and/or an Environmental Impact Statement (EIS)
pursuant to the National Environmental Policy Act (NEPA). Comments are also used to
determine the need for a public hearing and to determine the overall public interest of the
proposed activity.
Any person may request, in writing, within the comment period specified in this notice,
that a public hearing be held to consider the application. Requests for public hearings
shall state, with particularity, the reasons for holding a public hearing. Requests for a
public hearing will be granted, unless the District Engineer determines that the issues
raised are insubstantial or there is otherwise no valid interest to be served by a hearing.
The Corps of Engineers, Wilmington District will receive written comments pertinent to
the proposed work, as outlined above, until 5pm, September 20, 2019. Comments should
be submitted to David E. Bailey, Raleigh Regulatory Field Office,
3331 Heritage Trade Drive, Suite 105 , Wake Forest, North Carolina 27587, at (919)
554-4884 extension 30, or [e-mail].
Version 6.15.2017 Page 12

GSO Rental Car Facilities Relocation
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Environmental Assessment o° July 11, 2019

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Environmental Assessment July 11, 2019

GSO Rental Car Facilities Relocation
Environmental Assessment

GSO Rental Car Facilities Relocation
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PIEDMONT TRIAD AIRPORT AUTHORITY
August 8, 2019
U.S. Army Corps of Engineers
Wilmington District
Raleigh Regulatory Field Office
3331 Heritage Trade Dr., Suite 105
Wake Forest, NC 27587
Attention:
Subject:
Mr. David Bailey
Regulatory Project Manager
Raleigh Field Office
NC Department of Environmental Quality
Division of Water Resources
Water Quality Permitting Section
512 N. Salisbury St., Archdale Bldg. 9`"
Floor
Raleigh, NC 27604
Ms. Karen Higgins
Supervisor
401 & Buffer Permitting Branch
Application for Section 404 Permit, Section 401 Water Quality Certification, and
Jordan Buffer Exemption for Rental Car Facilities Relocation at Piedmont Triad
International Airport, Guilford County NC
The Piedmont Triad Airport Authority (PTAA) hereby applies for Individual Permit and Water
Quality Certification under Sections 404 and 401 of the Clean Water Act (CWA),
15A NCAC 2H .0500 as amended, and Jordan Buffer Exemption under 15A NCAC 2B .0267.
Unavoidable impacts to jurisdictional Waters of the United States (WOTUS) are anticipated for
required relocation of the existing rental car facilities at the Piedmont Triad International Airport
(GSO). This Project has been addressed in an Environmental Assessment (EA) with a Finding of
No Significant Impact (FONSI), enclosed, by the Federal Aviation Administration (FAA),
consistent with the National Environmental Policy Act (NEPA). Jurisdictional resources within
the Project area have been verified (SAW -2017-00101 and 00103, see EA Appendix A) by the
United States Army Corps of Engineers (USACE) with mitigation and riparian buffer rule
applicability determined by the North Carolina Department of Environmental Quality (NCDEQ)
Division of Water Resources (DWR) on January 20, 2017 (EA Appendix A).
Proposed Project
The PTAA is obligated to remove obstructions to the visibility of Taxiway E from the Air Traffic
Control Tower (ATCT) as determined by the Federal Aviation Administration (FAA)
Comparative Safety Analysis (EA Appendix A). The "Proposed Action" is to resolve this
visibility obstruction and includes the following four key components (EA Figure 2):
1000ATed Johnson Parkway • Greensboro, North Carolina 27409 • Phone: [phone] • Fax: [phone] • www.flyfrompti,com

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 2 of 13
1. Site preparation and stabilization of approximately 49 acres of developed land including
Removal of Existing Rental Car Facilities and adjacent air cargo structures and re -grading
to allow line -of -sight from the ATCT to Taxiway E (EA Figure 3),
2. Site preparation (including hauling of approximately 300,000 cubic yards clean fill from the
existing rental car facilities, above) of approximately 44 acres of approved future aerospace
development. Adjacent to this location, approximately 10 acres of clearing and grading for
construction and continuation of utilities along the Proposed Worldwide Drive right-of-
way, including electrical/lighting, communications, and stormwater management (Air Cargo
site, EA Figure 4),
3. Site preparation of approximately 57 acres of land including clearing and grading for
construction of paved parking areas for approximately 2,360 spaces and infrastructure for
approximately 16,900 square feet building space, including connection of utilities,
stormwater management, and communications for the Proposed New Rental Car Facilities
(Inman site, EA Figure 5), and
4. Site preparation and stabilization of approximately 28 acres for Proposed Spoil
Embankment of approximately 600,000 cubic yards of clean fill (from the Inman site,

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 3 of 13
above) adjacent to and north of the Honda Aircraft Company Maintenance Repair and
Overhaul (MRO) facility (Chimney Rock site, EA Figure 6).
M proposed project schedule is dependent on receipt of appropriate regulatory approvals
including documented compliance with the CWA. Removal of the existing rental car facilities is
contingent on completion of appropriate replacement with suitable access and functionality.
Notwithstanding concurrent scheduling of component construction to the extent practicable,
environmental protection measures for the proposed fill sites and haul roads would commence
along with project components exempt from permitting or otherwise regulatorily approved as
soon as possible, potentially in 2019. Project completion would be anticipated at least two years
after commencement.
Project Purpose and Need
M purpose of the Proposed Action is to eliminate a "line -of -sight" issue for the proposed
ATCT created by existing rental car facilities, thereby requiring the relocation of the facilities
posing visibility obstructions (see FAA Comparative Safety Analysis, EA Appendix A). o$
Proposed Action must be implemented in accordance with FAA design standards and Federal
Aviation Regulations (FAR) while maintaining rental car service provider neutrality. Because
the parameters of the ATCT line -of -sight are not flexible, the only viable alternative is to
eliminate the obstruction and move the subject facilities.
M existing Hertz rental car facility is located on high ground between the proposed ATCT and
Taxiway E and must be excavated to provide appropriate line -of -sight. To prevent competitive
disadvantage to Hertz, the remaining rental car facilities must also be relocated with Hertz. 02
new rental car facilities location will require appropriate vehicle access to and from the Terminal
area. Excess earth from both the existing Hertz site and proposed new rental car site must be
moved to the nearest appropriate respective locations. Ancillary needs with potential to be met
by a project alternative present the potential for significant efficiencies in cost -savings, aviation
safety, and regulatory compliance. Such needs include development of an additional terminal
public roadway to serve as redundant vehicle access and for emergency planning and evacuation,
separation of public versus rental car terminal access, and advanced site preparation of dedicated
aerospace tracts.
02 size, orientation, and proximity of a replacement site for rental car facilities must be
adequate to at least replace the existing facilities and not interfere with current or planned
aviation functions and FAA compliance of the Airport. Due to the significant economic growth
component of PTAA's mission, any proposed action must also be compatible with the planned
aerospace development tracts at GSO. Consideration of site alternatives for associated project
components (such as borrow, fill, haul routes, or site access) is similarly restricted by the aviation
and economic missions of the PTAH. M Proposed Action, including all components, must not
interfere with aviation or economic development specific to GSO.
M "Inman" site at the Northeast quadrant of the Inman Road / Bryan Boulevard intersection is
appropriately sized and situated for the combined rental car facilities to be relocated.
Continuation of Worldwide Drive (in the manner originally contemplated for its ultimate design)
from Old Oak Ridge Road to Air Cargo Road both connects the relocated rental car facilities and
provides an alternative Airport entry/exit for surface transportation. Moving fill excavated from

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 4 of 13
the Hertz rental car site to the aerospace development site adjacent to Worldwide Drive is the
most efficient solution for earthwork required to eliminate the Taxiway E visibility issue.
PTAA-owned land at the "Chimney Rock" site is the nearest appro riate location for
embankment of excess fill from excavation of the proposed Inman site. LU Proposed Action,
including connected projects, would eliminate the current ATCT line -of -sight obstruction to
Taxiway E, improve operational efficiency, facilitate emergency planning, and expedite
compliance with FAA requirements at GSO.
Alternatives to the Project
As summarized in the enclosed Project Alternatives Analysis, PTAA has exerted appropriate
effort to avoid siting project components with potential to impact environmental resources.
Because the Proposed Action is not water -dependent, alternatives to sites involving impacts to
WOTUS were assumed to exist and were explored to the extent practicable and available. oe
Inman Site is the preferred alternative for new location of the rental car facilities.
Access options from the Passenger Terminal to the Inman site are limited by existing land -use
and transportation infrastructure. M access road must be located between the Brush Creek
Conservation Easement (stream, wetland, and riparian buffer mitigation) and the adjacent
aerospace development site to avoid impacts to either and efficiently connect the new rental car
facilities. M only alternative route connecting Old Oak Ridge Road with Air Cargo Road to
avoid a stream crossing would isolate and divide the aerospace development site.02 s
alternative would also entail additional drive distance as the roadway required would be longer.
M preferred alignment for the extension of Worldwide Drive is consistent with the approved
Airport Layout Plan (ALP). M CWA Section 404 Individual Permit issued for Runway
5L/23R and associated developments (Action ID SAW -2000-21655) anticipated the preferred
alignment of Worldwide Drive, including the stream crossing, would be constructed once plans
were advanced for the aerospace development site. Impacts to jurisdictional resources (wetlands,
streams, and stream buffer) are anticipated to be minor and have already been mitigated.o$ s
alignment would avoid impacts to the existing Federal Express facility and allow for the planned
development specifically for the aerospace industry. Constructing Worldwide Drive with an
alignment that completely avoids jurisdictional resources would involve relocating the western
portion of the road to the south which would severely impact the approved aerospace
development - essentially reducing its size by more than 50 percent, and isolating it from
adjacent facilities. Ms alignment would also decrease the aerospace use of property that is
dedicated to accommodating aviation activity. Ms alignment would eliminate the potential to
construct nearly 15 future aircraft parking positions resulting in an uneconomic remnant of the
property. Significantly, this site is also located between parallel runways, which renders it a
premium aerospace development location. Other areas either on-, or off -airport property would
have to be identified to accommodate the demand for the planned aviation activity with extensive
coordination effort required to re -designate this area as non -aeronautical use. M proposed
Worldwide Drive stream crossing, therefore, becomes an unavoidable necessity to maintain the
integrity of this important aerospace development site, consistent with the approved ALP.
M use of fill material for site preparation on airport sites that may be recovered in the future for
airport -related development is an efficient use of resources and minimizes earthwork, haulin ,
and associated environmental impacts from repeated use of heavy equipment and vehicles. oz

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 5 of 13
closest available site for disposal of clean fill to be excavated from the rental car facilities is the
aerospace development tract adjacent to the FedEx Mid -Atlantic Hub, discussed in the previous
paragraph. Additional rationale for deposition of fill from the existing rental car facilities to the
aerospace development site is summarized as follows:
1) PTAA's mission includes planning and constructing economic development assets;
2) Ms location is PTAA's premier aerospace site due to setting between two runways
3) Ms location will be developed for a future tenant, if not for FedEx; and
4) Avoiding development of this site now would simply be postponing a significant element
of PTAA's mission and result in more expensive development in the future.
Stream and associated riparian buffer resources at the Chimney Rock site are completely avoided
by the proposed spoil (anticipated from the Inman site) embankment at that location. oz
Chimney Rock site is preferred due to the minimization of haul distance and potential
environmental impacts associated with driving heavy equipment and vehicles.
Affected Environment
Maintained/Disturbed and Mixed Pine/Hardwood Forest terrestrial communities were identified
at three component locations (Chimney Rock, Inman, and Air Cargo sites) included in the
Project. Mse communities, along with terrestrial wildlife, aquatic communities, and invasive
species, were summarized in the Biological Assessment appended to the EA. Approximately
37 acres mixed pine/hardwood forest would potentially be impacted by the Project. One of the
two man-made ponds may also be impacted. Wildlife potentially displaced include limited
terrestrial and aquatic species typical of the area. M North Carolina Stream Assessment
Method (NCSAM v2.1) and North Carolina Wetland Assessment Method (NCWAM v5) were
applied to streams and wetlands verified in the jurisdictional determinations at three Project
component locations and the results of these aquatic resource assessments were summarized in
the previously transmitted letter dated February 10, 2017 from Michael Baker International (see
EA Appendix A).
Minimization of Impacts
Given the lack of alternative site locations and restrictions on site access routes, four alternative
options for development of the Inman site for rental car facilities were considered in addition to
the "No -Action" Alternative. M first option (initially preferred by PTAA) contemplates
complete development of the site including direct impacts to natural resources. Due to the
presence of jurisdictional wetlands and streams on the site, significant effort was afforded to
avoiding these resources, consistent with CWA guidance, during the advancement of preliminary
designs. 82 refore, PTAA abandoned the complete site development option in favor of more
environmentally sustainable "avoidance" alternatives, as follows:
Inman Site Development Option 2 was conceived as an attempt to avoid direct impacts to
jurisdictional wetlands, streams, and riparian buffers to the extent practicable. M
environmental resources associated with these jurisdictional areas (such as fish, wildlife, plants,
floodplains, surface waters, and groundwater) are similarly avoided. Option 2 contemplates
21.66 acres of development including 2,104 parking spaces and 16,900 square feet of buildings,

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 6 of] 3
disturbing 52.6 acres and involving 816,000 cubic yards of cut. Because the existing Inman site
is entirely pervious, the development of the minimum acreage for the rental car facilities and
parking creates the need for stormwater management. Maximization of side -slope steepness at
the development perimeters to avoid the adjacent natural resources also exacerbates the necessity
for appropriate stormwater management. Appropriate areas will be developed as Stormwater
Control Measures (SCM) suitable for locations near airports. M specific location of such SCM
within the development site is dictated by stormwater management design protocols as discussed
in the enclosed Stormwater Management Report. F90s option is being advanced as the Preferred
Alternative.
In addition to the avoidance of direct impacts to natural resources, a third option was conceived
to explore the feasibility of re -locating stormwater management to facilitate specific and
appropriate continuity of a hydrologic source for the headwater streams and wetlands to be
preserved on-site. Option 3 contemplates 21.50 acres of development including 2,300 parking
spaces and 16,900 square feet of buildings, disturbing 52.6 acres and involving 816,000 cubic
yards of cut. Ms option significantly isolates a portion of the parking area and may result in
competitive disadvantage to one or more of the GSO rental car tenants. 42 refore, this option
was not advanced for further study.
Based on the limited space and vertical height restrictions (Runway Protection Zone) at the
proposed new rental car location, constraints of the site (jurisdictional resources on both sides
and in the middle of the facility), and lack of practicable alternatives; it was anticipated in the
draft EA that up to 1,662 linear feet stream channel and 1.8 acres of wetlands could be impacted
by the proposed Project.
PTAA has redesigned the new rental car facilities to reduce impacts to approximately 0.08 acres
wetlands, 1.72 acres open water, and no permanent riparian buffer. Temporary impacts
estimated at 0.02 acres wetland and 1,557 square feet riparian buffer are based on potential 10 -
foot incursion from permanent impact zone during construction. Mse potential temporary
impacts, if any, will be restored immediately following construction completion and removal of
temporary protection measures.
1 P WD4 LOW 0.07
P Parking#I Headwater 0.01
3 WD2 Forest HIGH
T 0.02
Total: 0.10

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 7 of] 3
Riparian Buffer Impacts
PTAA is further minimizing potential unavoidable adverse effects of the Project consistent with
FAA requirements and Section 404(b)(1) guidelines to the extent possible as follows:
• Construction of stream culverts will minimize smothering of organisms by utilizing
"pump -around", minimize construction time, control turbidity through adherence to the
Erosion and Sedimentation Control (E&SC) Plan; avoid unnecessary discharge; prevent
creation of standing water; and prevent drainage of wet areas.
• During construction, physiochemical conditions will be maintained, and potency and
availability of pollutants will be reduced, material to be discharged will be limited,
treatment substances may be added if necessary, chemical flocculants may be utilized to
enhance the deposition of suspended particulates in appropriate disposal areas.
•
M effects of dredged or fill material may be controlled by selecting discharge methods
and disposal sites where the potential for erosion, slumpin or leaching of materials into
the surrounding aquatic ecosystem will be reduced. LUbse methods include using
containment levees, sediment basins, and cover crops to reduce erosion.
• Discharge effects will also be controlled by containing discharged material properly to
prevent point and nonpoint sources of pollution, and timing the discharge to minimize
impact, for instance during periods of unusual high-water flows.
•
M effects of a discharge will be minimized by the manner in which it is dispersed, such
as, where environmentally desirable, orienting dredged/fill material to minimize
undesirable obstruction to the surface water or natural flow, and utilizing natural contours
to minimize the size of the fill; using silt screens or other appropriate methods to confine
suspended particulates/turbidity to a small area where settling or removal can occur,
selecting sites or managing discharges to confine and minimize the release of suspended
particulates to give decreased turbidity levels and to maintain light penetration for
organisms; and setting limitations on the amount of material to be discharged per unit of
time or volume of receiving water.
• Discharge technology will be adapted to the needs of the site. M applicant will consider
using appropriate equipment or machinery, including protective devices, and the use of
such equipment in activities related to the discharge of dredged or fill material;
employing appropriate maintenance and operation on equipment or machinery, including
adequate training, staffing, and working procedures; using machinery and techniques that
are especially designed to reduce damage to streams; designing access roads and channel
spanning structures using culverts, open channels, and diversions that will pass both low
Permanent
Reason
Zone 1 Zone 2
Impact
or
for
Impact Impact
Site
Temporary
Impact Type of Impact
Stream (sq. ft.) (sq. ft.)
4
Parking#2
405
5
T
Exempt
SB 41
SCM#3
6
1,111
Total: 0 1,557
PTAA is further minimizing potential unavoidable adverse effects of the Project consistent with
FAA requirements and Section 404(b)(1) guidelines to the extent possible as follows:
• Construction of stream culverts will minimize smothering of organisms by utilizing
"pump -around", minimize construction time, control turbidity through adherence to the
Erosion and Sedimentation Control (E&SC) Plan; avoid unnecessary discharge; prevent
creation of standing water; and prevent drainage of wet areas.
• During construction, physiochemical conditions will be maintained, and potency and
availability of pollutants will be reduced, material to be discharged will be limited,
treatment substances may be added if necessary, chemical flocculants may be utilized to
enhance the deposition of suspended particulates in appropriate disposal areas.
•
M effects of dredged or fill material may be controlled by selecting discharge methods
and disposal sites where the potential for erosion, slumpin or leaching of materials into
the surrounding aquatic ecosystem will be reduced. LUbse methods include using
containment levees, sediment basins, and cover crops to reduce erosion.
• Discharge effects will also be controlled by containing discharged material properly to
prevent point and nonpoint sources of pollution, and timing the discharge to minimize
impact, for instance during periods of unusual high-water flows.
•
M effects of a discharge will be minimized by the manner in which it is dispersed, such
as, where environmentally desirable, orienting dredged/fill material to minimize
undesirable obstruction to the surface water or natural flow, and utilizing natural contours
to minimize the size of the fill; using silt screens or other appropriate methods to confine
suspended particulates/turbidity to a small area where settling or removal can occur,
selecting sites or managing discharges to confine and minimize the release of suspended
particulates to give decreased turbidity levels and to maintain light penetration for
organisms; and setting limitations on the amount of material to be discharged per unit of
time or volume of receiving water.
• Discharge technology will be adapted to the needs of the site. M applicant will consider
using appropriate equipment or machinery, including protective devices, and the use of
such equipment in activities related to the discharge of dredged or fill material;
employing appropriate maintenance and operation on equipment or machinery, including
adequate training, staffing, and working procedures; using machinery and techniques that
are especially designed to reduce damage to streams; designing access roads and channel
spanning structures using culverts, open channels, and diversions that will pass both low

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 8 of] 3
and high water flows, accommodate fluctuating water levels, and maintain circulation and
faunal movement, employing appropriate machinery and methods of transport of the
material for discharge.
Minimization of adverse effects on populations of plants and animals will be achieved by
minimizing changes in water flow patterns which would interfere with the movement of
animals, managing discharges to avoid creating habitat conducive to the development of
undesirable airport wildlife hazards; avoiding sites having unique habitat or other value,
including habitat of threatened or endangered species; using planning and construction
practices to institute habitat development and restoration to produce a new or modified
environmental state of higher ecological value by displacement of some or all of the
existing environmental characteristics; timing discharge to avoid spawning or migration
seasons and other biologically critical time periods; and avoiding the destruction of
remnant natural sites within areas already affected by development.
Compensatory Mitigation
In order to comply with FAA wildlife hazard avoidance protocols (FAA AC 150/5200-33B) and
the United States Environmental Protection A ency (USEPA) mitigation rule, unavoidable
impacts are proposed to be mitigated off-site. LUre are no adjacent resources which would be
impacted or require mitigation as a result of the Project. Impacts to any nearby jurisdictional
streams or wetlands will be avoided. Proposed impacts to 1,221 linear feet of stream tributary to
Brush Creek located at the Air Cargo site have already been mitigated at the Causey Farm
Mitigation site under USACE Action ID SAW -2000-021655 (DWR File 00-0846), deemed
successful in 2009 and 2010. Mitigation required based on proposed impacts is estimated at
0.16 Wetland Mitigation Units based on 1:1 replacement for 0.07 acres LOW rated wetland
WD4 and 3:1 replacement for 0.03 HIGH rated wetland WD2 impacts.
2.08 WMU are currently available at PTAA's Causey Farm mitigation site for use on future GSO
projects, pending Corps review and approval. PTAA is hereby requesting approval to apply
0.16 WMU available at Causey Farm to mitigate the proposed GSO Rental Car Facilities
Relocation project impacts. M mitigation proposed will thus meet the estimated requirement.
Cumulative Impacts
No cumulative Project environmental effects are anticipated: Past GSO projects have included
the HAECO Facility Improvements, Honda MRO, Honda Connector Road, Taxiway D
Extension, Ballinger Road Extension, and the extension of Taxiway M. Only the HAECO and
Connector Road projects involved quantifiable impacts (Individual and Nationwide CWA
Section 404/401 Permits). Adjacent projects include the Cross -Field Taxiway and Site
Development Projects and NCDOT roadway improvements in the Project vicinity (I-73
Connector, US-220/NC-68 Connector, I-840, widening US -220, and widening Market Street).
No significant environmental impacts have been determined for these projects. Tree clearing for
the Runway 23L approach zone adjacent to the proposed New Rental Car Facilities location is
proposed to coincide with the Project construction time -frames, but this is limited to the 42 -acre
area north of Old Oak Ridge Road and the other side of I-73. Cumulatively, the Rental Car
Facilities Relocation would not add significant impacts, rather, the NCDOT roadway

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 9 of] 3
improvements anticipate such Airport development. Development of the proposed action would
not involve construction or development activity in residential areas, and there would be no
shifts in population movement or increase in the demands for public services. M proposed
action would not disrupt local traffic patterns or reduce the levels of service of roads serving the
Airport and its surrounding communities.
Fish and Wildlife
As of October 14, 2018, the United States Fish and Wildlife Service (USFWS) lists Small
Whorled Pogonia as threatened and Schweinitz's Sunflower as endangered in Guilford County.
Suitable habitat is not present at the any of the sites surveyed for the project. Identified forested
areas do not appear to include suitable persistent canopy breaks. A review of North Carolina
Natural Heritae Program (NCNHP) records indicated no known occurrences within 1.0 mile of
the Airport. oz USFWS previously listed small -whorled pogonia as a historic record in
Guilford County, indicating that this species was last observed within the County more than
50 years ago. However, a single plant was recently discovered near the Town of Gibsonville
approximately 20 miles east of the Airport.
M Project is anticipated to have no effect on these species - suitable habitat is not present at the
Project sites and review of NCNHP records indicated no known occurrences within 1 mile.
Habitat ranges for Endangered (Cape Fear shiner, Roanoke logperch) and At Risk (Atlantic
pigtoe) aquatic species listed do not include the project vicinity.
Habitat for the bald eagle primarily consists of mature forest in proximity to large bodies of open
water for foraging. Large dominant trees are utilized for nesting sites, typically within 1.0 mile
of open water. A desktop Geographic Information System (GIS) assessment of the Airport, as
well as the area within a 1.13 -mile radius (1.0 mile plus 660 feet) of the three sites, was
performed using 2016 color aerial photography. Lake Higgins (a water body large enough and
sufficiently open to be considered a potential feeding source) was identified within this search
radius. A survey of the Chimney Rock, Inman, and Air Cargo sites and the area within 660 feet
of these sites was conducted. No bald eagle nests were observed within this search polygon.
Review of the NCNHP database revealed no known occurrences of this species within 1.0 mile
of the Airport. Since there is potential foraging habitat within the review area, a survey of the
project study area and the area within 660 feet of the project limits for potential nesting habitat
was conducted. Most of the wooded areas within and near the project study areas are planted
pine or pine flatwoods that have previously been logged. As a result of planting and/or past
logging, most of the largest and oldest trees are even -aged stands without the "dominant" canopy
trees required for nesting by bald eagles.
As of October 14, 2018, the USFWS list no Candidate species for Guilford County. Federal
Species of Concern are not legally protected under the Endangered Species Act and are not
subject to its provisions, including Section 7, until they are formally yroposed or listed as
02 eatened or Endangered. Organisms that are listed as Endangered, 02 eatened, or Special
Concern on the NCNHP list of Rare Plant and Animal Species are afforded state protection under
the State Endangered Species Act of 1987 and the North Carolina Plant Protection and
Conservation Act of 1979.

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 10 of 13
o: re are no State -listed endangered or threatened species known to occur within 1 mile of the
Project. Current species listed for the "Guilford" 7.5 -minute United States Geographic Survey
(USGS) Topographic Quadrangle from March 3, 2017 search of the NCNHP database included
the Bald Eagle (State d2 eatened) and Greensboro Burrowing Crayfish (State Special Concern).
M North Carolina Wildlife Resources Commission (NCWRC) have recorded Greensboro
burrowing crayfish and Appalachian golden -banner (State Special Concern - Vulnerable) in the
Project vicinity. No Project activity contemplates take of species listed in the Migratory Bird
Treaty Act.
Historic, Cultural, Scenic, and Recreational Values
No National Register of Historic Places (NRNP) resources will be impacted by the Project
according to the HPOWEB map and the State Historic Preservation Office (SHPO) had no
comment in response to early NEPA coordination for the proposed Project. ve Project
components are located entirely within Airport -owned property. On May 26, 2019, a field
investigation of 15 architectural resources within the Area of Potential Effect (APE)
approximately 2000 feet from the center of the Inman site was conducted. M survey found that
none of the 15 properties is considered eligible for the NRHP under any criterion. A GIS
Predictive Model was used to identify areas within the Inman Site (excluding the two ponds) that
have a high probability for the presence of archaeological sites and that may be subject to direct
and indirect effects from the proposed relocation of the rental car facilities. M outcome of the
GIS Predictive Model was a spatial depiction of the project area that has a high probability for
the presence of historic and prehistoric archaeological resources based on an analysis of
environmental conditions and historic data. Four sites (two prehistoric lithic scatters and two
historic sites with building foundations and a scatter of artifacts) were identified on the 18 -acres
(about 30 percent) of the 57 -acre project APE that were identified as having a high -probability
for the presence of archaeological sites. None of the sites retains enough integrity to recommend
them as being eligible for the National Register. No further archaeological work was
recommended. No parks, national forest, wildlife refuge, recreational areas, Section 106,
Section 4(f), or Section 6(f) resources will be impacted by the Project. No National Wild and
Scenic Rivers, Nationwide Rivers Inventory (NRI) -listed rivers, river segments, or study rivers
are located at or near the Airport.
Stormwater
Application of appropriate stormwater management controls consistent with the State
Stormwater Design Manual, Water Supply Watershed Protection Program, and Jordan Water
Supply Nutrient Strategy regulations will address potential water quality and runoff quantity
changes resulting from the additional impervious surfaces (see enclosed Stormwater
Management Report and Plans). Protection of downstream drinking water sources will be
ensured through appropriate adherence to PTAA's watershed protection and inspection
protocols, mandated by the Water Supply Watershed Management and Protection Rules of the
PTAA and the PTAA 2001 Stormwater Management Plan (SMP). M Project will also be
subject to the Airport's Individual National Pollutant Discharge Elimination System (NPDES)
Industrial Stormwater Permit (NCS000508) including the Airport Stormwater Pollution
Prevention Plan (SPPP), discharge monitoring program, spill response procedures, and Spill

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 11 of 13
Prevention Control and Countermeasures (SPCC) plan. Stormwater management specifications
include:
• Water quality treatment for the 1 -inch storm event,
• o$ 1 -year 24-hour storm event discharge shall be less than the pre -development
discharge;
• GSO is low density (<24% built -upon area), and
• Retention / detention ponds (open water with accessible shore) not desired near Airport.
o existing rental car facilities, once demolished, will be converted into green space with some
existing pavement to remain. Since there is a net reduction in impervious surface, no additional
stormwater management is required.
Construction of Worldwide Drive and the adjacent aerospace development footprint was part of
the ultimate development included in the 2001 SMP which anticipated 80 acres of total
impervious surface draining to Pond F-1. Ms pond was also sized to minimize impacts to the
Brush Creek Conservation Easement. Based on the Project impervious surfaces for this area,
water quality requirements, and existing pond characteristics, Pond F-1 remains appropriate to
provide stormwater management for the development proposed at this location.
Appropriate SCMs will be provided at the proposed New Rental Car Facility at the Inman Road
site as bioretention cells with risers. Site infiltration testing and geotechnical investigation will
ensure that the SCMs provide for infiltration as required and that no ponding occurs. 11 SCMs
will also provide appropriate flood control and discharge to existing wetlands at non-erosive
rates. M outfalls will be strategically placed to provide suitable runoff to existing streams and
wetlands to avoid hydrologic impact to these natural features.
A shallow swale has been designed between the riparian buffer and the edge of spoil at the
Chimney Rock site to control runoff from the embankment. Since there is no change in
impervious surface here, no additional SCMs are proposed.
Prior to the commencement of construction, an E&SC plan for the Project will be submitted to
NCDEQ and PTAA will obtain the applicable E&SC approval and NPDES construction
stormwater permit. Potential temporary impacts to surface water quality as a result of Project
construction activities will be effectively mitigated through adherence to the approved E&SC
plan and NPDES permit requirements, as well as through compliance with FAA Standards for
Specifying Construction of Airports.
Other Federal, State, or Local Requirements
02 ough the NEPA process, FAA has explored practicable Project alternatives and impact
minimization prior to addressing compensatory mitigation (sequencing). M FAA has also
explored potential environmental impacts relating to Air Quality; Biological Resources; Climate,
DOT Section 4(f) Resources; Farmland, Hazardous Materials, Solid Waste, and Pollution
Prevention; Historical, Architectural, Archeological, and Cultural Resources; Land Use, Noise
and Compatible Land Use, Socioeconomics, Environmental Justice, Children's Environmental
Health and Safety Risks; Visual Effects; Water Resources; Cumulative Impacts; Permits and
Certifications, and Mitigation, as summarized in the EA.

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 12 of 13
In consideration of 15A NCAC 02H .0502 (a), the following information is summarized for
filing the Section 401 CWA Water Quality Certification application:
(1) the date of application - August 8, 2019;
(2) the name, address, and phone number of the applicant. If the applicant is not the property
owner(s), the name, address, and phone number of the property owner(s) -
Piedmont Triad Airport Authority; Mr. J. Alex Rosser, Deputy Executive Director;
1000A Ted Johnson Parkway; Greensboro, NC 27409; Telephone [phone];
(3) if the applicant is a corporation, the name and address of the North Carolina process
agency, and the name, address, and phone number of the individual who is the authorized
agent of the corporation and responsible for the activity for which certification is sought.
M corporation must be registered with the NC Secretary of State's Office to conduct
business in NC - see (2) above;
(4) the nature of the activity to be conducted by applicant — airport rental car facilities
relocation, see previous text and enclosures for details;
(5) whether the discharge has occurred or is proposed — proposed;
(6) the location of the discharge, stating the municipality, if applicable; the county; the
drainage basin; the name of the receiving waters; and the location of the point of
discharge with regard to the receiving waters - Piedmont Triad International Airport,
Guilford County, see permit drawings for specific discharge locations;
(7) a description of the receiving waters, including type (creek, river, swamp, canal, lake,
pond, or estuary) if applicable; nature (fresh, brackish, or salt); and wetland classification
— riparian wetlands, open water pond, and riparian buffer, tributary to Horsepen
Creek, see previous text for details;
(8) a description of the type of waste treatment facilities, if applicable - not applicable;
(9) a map(s) or sketch(es) with a scale(s) and a north arrow(s) that is legible to the reviewer
and of sufficient detail to delineate the boundaries of the lands owned or proposed to be
utilized by the applicant in carrying out the activity; the location, dimensions, and type of
any structures erected or to be erected on the lands for use in connection with the activity;
and the location and extent of the receiving waters, including wetlands within the
boundaries of the lands - see enclosed permit drawings;
(10) an application fee as required by G.S. 143-215.3D(e) - check enclosed; and
(11) a signature by the applicant for the federal permit or license or an agent authorized by the
applicant. If an agent is signing for the applicant, an agent authorization letter must be
provided. In signing the application, the applicant certifies that all information contained
therein or in support thereof is true and correct to the best of their knowledge — signed
application enclosed.
A lack of practical alternatives has been demonstrated pursuant to 15A NCAC 02H .0506(f).
After consideration of size and configuration of the proposed activity, and all alternative designs,
the basic Project purpose cannot be practically accomplished in a manner which would avoid or
result in less adverse impact to surface waters or wetlands.

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
Page 13 of 13
Minimization of impacts has been demonstrated pursuant to 15A NCAC 02H .0506(g) because
the surface waters are able to continue to support the existing uses after Project completion, and
the impacts are required due to the spatial and dimensional requirements of the Project, the
location of existing structural and natural features that dictate the placement and configuration of
the proposed Project, and the purpose of the Project and how the purpose relates to placement
and configuration.
M Project: (1) has no practical alternative; (2) will minimize adverse impacts to surface waters
based on consideration of existing topography, vegetation, fish and wildlife resources, and
hydrological conditions, (3) will not result in the degradation of groundwater or surface waters,
(4) will not result in cumulative impacts, based upon past or reasonably anticipated future
impacts, that cause or will cause a violation of downstream water quality standards; (5) provides
for protection of downstream water quality standards through on-site stormwater treatment; and
(6) provides for replacement of existing uses through mitigation. Additional regulatory
requirements are addressed in the EA.
We appreciate your consideration of this request. Please feel free to contact me
([e-mail], 336.665.5620) or Richard Darling ([e-mail], 919.481.5740) with
questions or comments. One (1) complete and collated original application with supporting
documentation is being provided to USACE with four (4) complete and collated copies to DWR
along with the application fee.
Sincerely,
PIEDMONT TRIAD AIRPORT AUTHORITY
� k'o�" ,v'_
J. Alex Rosser, P.E.
Deputy Executive Director
RD/AR:kh
Enclosures: FAA Environmental Assessment (38 pages with 3 appendices)
Eng Form 4345 (3 pages, PTAA signed)
Project Alternatives Analysis (5 pages)
Permit Drawings (4 sheets, full size and 11"X 17")
Stormwater Management Report (113 pages with 25 plan sheets)
DWR 401 Application Fee (PTAA $570 check)
cc: Sue Homewood, DWR-WSRO
Richard Darling, Michael Baker International
Mpsl/projects. mbakemorp. com1PT1A14041Renta1CarApp.pdf

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INTERNATIONAL Memorandum
TO: J. Alex Rosser, PE DATE: July 25, 2019
FROM: Richard Darling SUBJECT: CSO Rental Car Facilities Relocation
PROJECT ALTERNATIVES
Thefundamental precept of the (Jean Water Act (0,NA) fiction 404(b)(1) Guidelines isthat dischargesof dredged or fill
material intowatersof the United nates, indudingwetlands, should not occur unlessit can be demonstrated that such
discharges, either individually or cumulatively, will not result in unacceptable adverse effectson the aquatic ecosystem.
The Guidelinesspecifically require that "no discharge of dredged or fill material shall be permitted if there is a
practicable alter nati ve to the proposed discharge whi ch would have I ess adverse impact on the aquatic ecosystem, so
long asthe alternative does not have other significant adverse environmental consequences." Based on this provision,
the applicant is required in every case to evaluate opportunitiesfor use of non -aquatic areas and other aquaticsitesthat
would result in less adverse impact on the aquatic ecosystem. Apermit cannot be issued, therefore, in circumstances
where a less environmentally damagi ng practicable alternative for the proposed discharge exists.
Reasonable alternative locations and conceptsto proposed project components are evaluated and summarized in the
followingtext. Alternativestoremoving the existing rental car (RAC) facilities and locating new facilities are limited by
the project Purpose and Need. Locating appropriate sitesto haul excessfill from both these sites are similarly limited by
distance, suitability, aviation safety, and economics. Environmental concerns apply additional limitationsto alternatives,
but opportunitieswith significant efficiencies are also presented.
• • tea . , - c to
The only viable solution to resolving the Taxiway Evidbility issue isto remove the obstruction. The use of remote
camerasto transfer live video feed of hidden portions of the taxiway is a limited alternative, only temporarily applicable
for the existing tower due to its limited remaining life. The existing Hertz building and several feet of topography at this
location must be removed to comply with FAAsafety requirements. The excess material removed from the site would
be deposited at an existing, approved airport waste site (or similar). The excess material could then be recovered should
it be needed for future airport -related development. The temporary, on-site storage of excess material for future
airport needs is an efficient alternative and provides a means of reducing redundant and expensive earthwork and
hauling. The proposed aerospace development site adjacent to the FedEx Mid -Atlantic Hub (Air Cargo site) is suitably
dose to the existing RACfacilitiesto minimize haul distance and is also appropriately designated to receive such fill in
the context of future aviation development. There are no closer suitable sites.
Ste Requirementsfor the relocated RACfacilities are based on the existing characteristics—approximately 2,400 total
parki ng spaces required in four co -located siteswithi n no more than three driving miles of the G90 Terminal. Areview
of Guilford County GlSfor adequately sized siteswithin suitable distance of the C93Terminal revealed no available
parcelswithout potential similar or more severe impactsto aquatic resources. Potential sites not owned by PTAAwould
require such significant additional time and effort to purchase, re -zone, and secure FAAapproval asto be inconsistent
with the project need and purpose to resolve the line -of -site issue. Only two dteswith potentially reasonable location
for RAC parking not owned by PTAAwere identified in a GlSsearch of suitably sized and zoned parcels (Figure 1). Both
of these are located over 4 milesfrom the RAC pickup/drop-off and because they are neither owned by PTAAnor
considered in theAlPfor RAC, they are not available to meet the project need and purpose.
Page 14 5

GSO Fbntal Car Facilities Fblocation
Roject Alternatives
The only other potential areas with adequate dze for relocation of the PACfaci lities i nd ude the proposed aerospace
development dtesowned byAirportAuthority. Each of these five tracts (Figure 2)appear adequately dzedfor the
combined PACfacilities but are strategically located with runway/taxiway frontage—significant for aerospace
development, but not necessary for airport PACfacilities. These siteswould also involve additional driving distancesto
the Terminal and potential PACclevelopment complications arisingfrom their intimacy with airside operations. Dueto
the unique features of the other appropriately sized C90sites for aerospace development, these locations were
removed from consideration for the PACfacilities. Development as PACfadlitieswould bean ineffident and
inappropriate use of tCe3e Ai rport properties and interfere wit®'TAA s aerospace development mission.
Memorandum Page 2 of 5 Ily 25, 2019

GSO Fbntal Car Facilities Fblocation
Roject Alternatives
Rgure2 Aerospace Development Sites
Available Sites
i
TRACT 3
x
---� ----.--------------------------------
TRACT 5
1
qui!201Is VIEW1116F.,►�.r �`�''I
low
------------------------------------------------- _
Not depicted on Figure isthe aerospace development site dedicated in 2001, but as yet undeveloped. Thissite
remainstEI�Ajrport Sponsor's potentially most important location for aerospace development due to its location
between parallel runways, and adjacent to Taxiway E Air Cargo Fbad, and the existing FedEx Mid -Atlantic Hub. Thissite
was excluded from consideration for development of either PACfacilities or roadway due to its dgnificance for future
aviation development. The Inman site (also not shown on Figure 2) isthe only suitable location not obligated for
aerospace but with adequate size, orientation, and proximity, for PACfacility development.
Access optionsfrom the Passenger Terminal to the Inman site are limited by existing land -use and transportation
infrastructure. The access road must be located between the Brush Creek Conservation Easement (stream, wetland, and
riparian buffer mitigation) and the adjacent aerospace development siteto avoid impactsto either and efficiently
connect the new PACfacilities. The only alternative route connecting Cld Oak Fudge Road with Air Cargo Road to avoid a
stream crossingwould isolate and divide the aerospace development site. This alternative would also entail additional
drive distance asthe roadway required would be longer. The preferred alignment for the extension of Worldwide Drive
Memorandum Page 3 of 5 Ily25, 2019

GSO Fbntal Car Facilities Fblocation
Roject Alternatives
is consistent with the approved Airport Layout Ran (ALP). The Environmental Impact Statement/ Record of Decision
(8 SJ ROD) and subsequent CWA permits issued for Runway 5L/23R and assod ated developments anti d pat ed the
preferred alignment of Worldwide Drive, includingthe stream crossing, would be constructed once planswere advanced
for the aerospace development site. I mpactsto jurisdictional resources (wetlands, streams, and stream buffer) are
anticipated to be minor and have already been mitigated. This alignment would avoid impactsto the existing Federal
Expressfadlity and allow for the planned development specifically for the aerospace industry. Constructing Worldwide
Drive with an alignment that completely avoidsjurisdictional resourceswould involve relocati ngthe western portion of
the road to the south which would severely impact the approved aerospace development -essentially reducing its size
by more than 50 percent; and isolating it from adjacent facilities. This alignment would also decrease the aerospace use
of property that is dedicated to accommodating aviation activity. This alignment would eliminate the potential to
construct nearly 15 future aircraft parking positions resulting in an uneconomic remnant of the property. 9gnificantly,
thissite is also located between parallel runways, which renders it a premium aerospace development location. Other
areas either on-, or off-ai rport property would have to be identified to accommodate the demand for the planned
aviation activity with extensive coordination effort required to re -designate this area as non -aeronautical use. The
proposed Worldwide Drive stream crossing, therefore, becomesan unavoidable necessity to maintain the integrity of
this important aerospace development site, consistent with the approved ALP.
The use of fill material for site preparation on airport sitesthat maybe recovered in the future for airport -related
development is an effident use of resources and minimizesearthwork, hauling, and assodated environmental impacts
from repeated use of heavy equipment and vehides. The dosest available site for disposal of dean fill to be excavated
from the PACfacilities isthe aerospace development tract adjacent to the FedEx Mid -Atlantic Hub, discussed in the
previous paragraph. Additional rationalefor depodtion of fill from the existing PACfacilitiesto the aerospace
development site is summarized asfollows:
1) FFAAs misdon includes planning and constructing economic development assets,
2) TQ location is PTAA's premier aerospace site due to setting between two runways;
3) This location will be developed for a future tenant, if not for FedEx; and
4) Avoiding development of tEgsite nowwould dmply be postponing a significant element of FFAAs mission and
result in more expensive development in the future.
•••_-•'^•• •.
Stream and associated riparian buffer resources at the Chimney Rock site are completely avoided by the proposed spoil
(antidpated from the Inman site) embankment at that location. The Chimney Rock site is preferred due to the
minimization of haul distance and potential environmental impacts assodated with driving heavy equipment and
vehicles.
No -Action Alternative
The No -Action Alternative would avoid most environmental consequences, includingthe potential continued existence
of wetlands, streams, and forested uplands adjacent to the Inman / (Ad Oak Fudge Road intersection, but without
management in context of their developed surroundings. The no -action alternative does not meet the Project purpose
or need because continued existence of high -ground and structures at the Hertzfacility would prohibit appropriate
visibility of Taxiway Efrom the Air Traffic Control Tower (ATCT), contrary to FAA requirements. The ability of all RAC
facilitiesto function effidently at C90would be compromised by lack of growth or modernization potential. Alack of
redundant vehide entry/exit capability or separation of PACtrafficfrom private transport would continue to hinder C90
effidency and emergency planning. If the proposed fill site is not adequately prepared for aerospace development, C93
would be deprived of a specifically -planned economic development, contrary to Airport's mission. If Worldwide Drive is
not connected, as planned, the PACcompanies would be forced to use the main C90entrance for access to the
passenger terminal, requiring a significantly longer drive with consequent gas, mileage, and time inefficiencies.
Memorandum Page 4 of 5 Ily 25, 2019

GSD Fbntal Car Facilities Fblocation
Roject Alternatives
Least EnAronmentelly Daryiong Practicable Alternative
Based on the considerable deliberation of potential impacts to environmental resources discussed the EA the Airport
Sponsor isadvancingthe Option 2 alternative for development of the Inman site. This option is summarized in the as
the Proposed Action and contemplates avoidance and minimization of impactsto the extent practicable. The Proposed
Action indudesrelocating all the existing PACfacilitiesfrom their current location to the Inman site and developingthat
site with appropriate access.
Memorandum Page 5 of 5 Ily 25, 2019

X�
U.S. Department
of Transportation
Federal Aviation
Administration
July 23, 2019
Mr. Alex Rosser, P. E.
Deputy Executive Director
Piedmont Triad Airport Authority
1000 A Ted Johnson Parkway
Greensboro, NC 27409
RE: FONSI — Rental Car Relocation
Piedmont Triad International Airport (GSO)
Dear Mr. Rosser:
Memphis Airports District Office
2600 Thousand Oaks Blvd. Suite 2250
Memphis, TN 38118-2486
Phone:[phone]
The Federal Aviation Administration (FAA) Memphis Airports District Office has reviewed the
Environmental Assessment (EA) for the referenced project. Based on our review, the EA
supports a Finding of No Significant Impact (FONSI).
To finalize the environmental process for this action, please issue an announcement of
availability of the FONSI along with the final EA in a newspaper of general circulation.
If you have any questions related to this environmental review, please contact Aaron Braswell
of my staff at [phone] or at [e-mail].
Phillip J. Brad fl
Manager, Me ) his
Enclosure
District Office

DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
FINDING OF NO SIGNIFICANT IMPACT (FONSI)
Rental Car Facilities Relocation
Piedmont Triad International Airport
Greensboro, NC
I. IntroductionBackground
In accordance with the National Environmental Policy Act (NEPA), this Finding of No
Significant Impact (FONSI) announces final agency determinations and approvals for
those Federal Actions by the Federal Aviation Administration (FAA) that are necessary
to support the proposed developments at the Piedmont Triad International Airport in
Greensboro, North Carolina.
H. Proposed Federal Action
The airport sponsor has requested FAA funding assistance for the following project:
• Site preparation for the removal of terrain obstruction 49 acres of land including
removal of existing renting facilities and adjacent air cargo structures.
• Site preparation for 44 acres of future aviation development.
• Site preparation for 10 acres for future road (Worldwide Drive) and associated
right-of-way.
• Site preparation of 57 acres and construction of new rental car facilities.
• Site preparation of 28 acres for spoil embankment.
• Relocation of utilities.
III. Purpose and Need
The FAA has defined the purpose and need for implementing the proposed action as
being necessary to eliminate a line -of -site deficiency for the new air traffic control tower
(ATCT). The existing terrain and rental car facilities would preclude air traffic controllers
from adequately viewing the airfield. The criteria for establishing the new rental facilities
is based on meeting FAA airport design guidelines, compliance with imaginary airspace
surfaces in Federal Aviation Regulations (FARs), and fair business practices to have all
airport rental car facilities in the same geographic vicinity.
IV. Alternatives
Federal guidelines concerning the environmental review process require that all
reasonable and practicable alternatives that might accomplish the objectives of a
proposed project be identified and evaluated. Such an examination ensures that
alternatives are not prematurely dismissed and may lead to consideration of alternatives
that fulfill the project's purpose and need as well as enhance environmental quality or
have a less detrimental effect. The alternatives evaluated for this Environmental
Assessment (EA) are listed below.
GSO Airport Rental Car FONSI 1 7/232019

1. Inman Site Alternative 1
2. Inman Site Alternative 2 (Preferred Alternative and Proposed Federal Action)
3. Inman Site Alternative 3
4. Other site location Alternatives
5. No Action Alternative
These alternatives are described in Chapter 3 of the EA. As can be noted in the EA, other
sites located beyond the Inman Site, were not considered suitable for development. Three
development alternatives were considered at the Inman Site. The second Inman Site
Alternative was selected as the preferred alternative as it limited environmental impacts
and best satisfied the criteria outlined in the purpose and need statement.
V. Environmental Impacts
The EA analyzed all environmental categories based on FAA Order 505O,4B, "National
Environmental Policy Act Implementing Instructions for Airport Projects" (NEPA).
Those Resource Categories that the Sponsor's preferred alternative has the potential to
impact are discussed below. Mitigation measures for the environmental impacts are
discussed in Section VI.
V A. Air Quality and Greenhouse Gases
The proposed action is not expected to result in net increases in operating
emissions. The project will result in additional emissions during construction.
Based on air quality modeling, the construction emissions will be below the level
of significance.
V B. Biological Resources
The proposed action will impact 37 acres of mixed pine/hardwood forest,
including ponds, stream channels, and wetlands. As such, the action will impact
both terrestrial and aquatic species. Based on site assessment, the project locations
do not feature suitable habitat for state or federally -listed species, or the species
are not known to occur within a one -mile radius of the project site.
V C. Section 4(f) Lands
The proposed action will occur on airport owned property and will not impact
Section 4(f) Lands.
V D. Farmlands
The proposed action will occur on airport owned property and will not impact
farmlands.
V E. Hazardous Materials, Solid Waste, and Pollution Prevention
The proposed action will produce solid waste due to the demolition of existing
structures. Solid waste will be disposed of in proper facilities. No hazardous
materials are known to be present within the facilities to be demolished. If
hazardous materials are encountered during construction, contractors will follow
state protocols for treating and disposing of the waste.
C3SO Airport Rental Car FONSI 2 7/23/2019

V F. Section 106 Resources
Based on both a historical architecture survey and an archaeological survey, the
proposed undertaking will not affect potentially eligible resources to the National
Register of Historic Places (NRNP).
V G. Land Use
The proposed action will take place on existing airport property. The action is
consistent with local land use plans.
V H. Natural Resources and Energy Supply
The action will result in the use of natural resources and energy supply both
during construction and in operation. The resources to be consumed are in
sufficient supply and are readily available.
V I. Noise and Compatible Land Use
The proposed action is expected to create short-term noise impacts from
construction activities. Impacts are not expected to be significant due to the
limited duration. The action is not expected to alter aircraft activity.
V J. Socioeconomics, Environmental Justice, Children's Environmental
Health and Safety Risks
The proposed action is located on airport property. The action will result in a
temporary increase in economic activity during construction. No known impacts
are expected to disproportionately effect children or environmental justice
communities.
V K. Visual Effects
The proposed action has potential to impact residential areas near the project area.
However, given the extent of existing lighting in the project vicinity, including
airport and commercial development, the impacts are not expected to be
significant.
V L. Water Resources
The project site features several jurisdiction waters including wetlands, streams,
and ponds. Based on the sponsor's efforts to avoid many of these resources, the
propose action is expected to impact 0.1 acres of wetlands, 1.72 acres of open
water non- jurisdictional ponds, 1,694 linear feet of streams, and 184,674 square
feet of State protected riparian buffer. See mitigation in Section VI for more
information.
V M. Cumulative Effects
The proposed action was considered in conjunction with past actions and future
actions that are reasonably foreseeable. Based on the EA, the action will not lead
to cumulative significant impacts to any environmental categories identified in
FAA Orders 1050.1 F and 5050.4B.
GSO Airport Rental Car FONSI J 7/23/2019

VI. Environmental Mitigation
The Airport Sponsor shall be responsible for obtaining all necessary construction permits
or certifications as described in Section VI A. below prior to initiating construction
activities near or on the environmental resource requiring the permit. Project related
permits, certifications, and other mitigation measures required for the proposed action are
discussed below. It should be noted that best management practices (BMPs) are
considered standard operating procedure and are not considered mitigation; therefore,
they are not discussed in this section.
VI A. Permits and Certifications
The project will require the following permits or certifications:
1. USACE 404
2. NC Division of Water 401
3. NPDES General Storm Water Permit
VI B. Mitigation
Without proper mitigation, the proposed action may exceed the threshold of
significance. Mitigation shall be completed for the following environmental
categories:
Water Resources: It is anticipated that the action will impact up to 0.1
acres of jurisdictional wetlands; 1,694 linear feet of streams; and 184,674
square feet of riparian buffer. Mitigation is expected to occur via
compensation and use of a wetland mitigation bank such as the Causey
farm site or other mitigation banks within the local watershed. Anticipated
replacement ratios are 3:1 for wetlands; 2:1 for streams; and 2.4:1 for
buffer. The estimated mitigation cost for the preferred alternative, based
on a replacement ratio of 3:1 is $100,000.00.
VII. Public Involvement
The following agencies were consulted in the preparation of this EA:
• Federal Aviation Administration
• U.S. Department of Agriculture/Natural Resources Conservation Office
• U.S. Army Corps of Engineers
• U.S. Department of the Interior/Fish and Wildlife Service
• U.S. Department of the Interior, Office of Environmental Policy and Compliance
• U.S. Environmental Protection Agency
• N.C. Department of Administration, State Environmental Review Clearinghouse
A public notice was placed in the Winston-Salem Journal, High Point Enterprise, and
Greensboro News Record announcing the availability of the draft EA, the opportunity for
comment, and the opportunity to request a public hearing. The public review period
GSO Airport Rental Car FONSI 4 7/23/2019

lasted for 30 days and ended on July 7, 2019. No comments or requests for a public
meeting were made.
VIII. Decision
After careful and thorough consideration of the facts contained herein, the undersigned
finds that approval of the proposed development is consistent with existing national
environmental policies and objectives as set forth in Section 101(a) of the National
Environmental Policy Act of 1969 (NEPA) and that it will not significantly affect the
quality of the human environment or otherwise include any condition requiring
consultation uursuaN to Seo9n�2(WC) of NEPA.
Appro� ed:
'Ti•
Date: 7 r /
GSO Airport Rental Car FONSI 7232019

Environmental Assessment
FEDERAL AVIATION ADMINISTRATION
MEMPHIS AIRPORTS DISTRICT OFFICE
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
DIVISION OF AVIATION
Airport Name: Piedmont Triad International Airport (GSO)
Proposed Project: Rental Car Facilities Relocation
Project Location: Guilford County, North Carolina
Date Submitted to FAA/SBG: July 11, 2019
This environmental assessment becomes a Federal document when evaluated, signed, and dated by
the Responsible FAA/SBG Official.
Responsible F SBG Official Date

GSO Rental Car Facilities Relocation
Contents
Acronyms
1 Proposed Action........................................................................................................................
1
2 Purpose and Need.....................................................................................................................
8
3 Alternatives...............................................................................................................................9
3.1 Reasonable Alternatives Considered...............................................................................
9
3.2 No -Action Alternative...................................................................................................
14
3.3 Preferred Alternative......................................................................................................
15
4 Affected Environment and Environmental Consequences.....................................................
16
4.1 Air Quality.....................................................................................................................
16
4.2 Biological Resources (including fish, wildlife, and plants) ...........................................
17
4.3 Climate...........................................................................................................................20
4.4 Department of Transportation Act, Section 4(f)............................................................
21
4.5 Farmlands.......................................................................................................................21
4.6 Hazardous Materials, Solid Waste, and Pollution Prevention .......................................
21
4.7 Historical, Architectural, Archeological, and Cultural Resources .................................
23
4.8 Land Use........................................................................................................................
24
4.9 Natural Resources and Energy Supply..........................................................................
24
4.10 Noise and Compatible Land Use...................................................................................
25
4.11 Socioeconomics, Environmental Justice, Children's Environmental Health and Safety
Risks...............................................................................................................................
25
4.12 Visual Effects (including light emissions).....................................................................
26
4.13 Water Resources (including wetlands, floodplains, surface waters, groundwater, and
wild and scenic rivers)...................................................................................................
26
5 Cumulative Impacts................................................................................................................
28
6 Permits and Certifications.......................................................................................................
29
7 Mitigation................................................................................................................................30
7.1 Avoidance......................................................................................................................
30
7.2 Minimization..................................................................................................................30
7.3 Compensation................................................................................................................
31
8 References...............................................................................................................................33
9 Preparers.................................................................................................................................
34
9.1 Document Preparer........................................................................................................
34
9.2 Airport Sponsor..............................................................................................................
37
10 Agencies and Persons Consulted............................................................................................
38
Appendix A Supporting Documentation
Appendix B Regulatory Coordination
Appendix C Public Involvement
Environmental Assessment 11 July 11, 2019

GSO Rental Car Facilities Relocation
Acronyms
AC (FAA) Advisory Circular
ACEIT Airport Construction Emissions Inventory Tool
ALP Airport Layout Plan
AOA Air Operations Area
APE Area of Potential Effect
ATCT Air Traffic Control Tower
BMP Best Management Practice
BW Buffer Mitigation Unit
CEQ Council on Environmental Quality
CERCLIS Comprehensive Environmental Response Compensation and Liability Information
System
CFR Code of Federal Regulations
CWA Clean Water Act
DMS (NCDEQ) Division of Mitigation Services
DWM (NCDEQ) Division of Waste Management
DWR (NCDEQ) Division of Water Resources
E&SC Erosion and Sediment Control
EA Environmental Assessment
ECOS (USFWS) Environmental Conservation Online Svstem
EIS Environmental Impact Statement
EJ Environmental Justice
ESFO (USFWS) Ecological Services Field Office
FAA Federal Aviation Administration
FAR Federal Aviation Regulations
FEMA Federal Emergency Management Agency
FIRM Flood Insurance Rate Map
GDOT Greensboro Department of Transportation
GHG Greenhouse Gas
GIS Geographic Information System
GNR Greensboro News Record
GPD Greensboro Planning Department
GSO Piedmont Triad International Airport
HPE High Point Enterprise
HUC Hydrologic Unit Code
HVAC Heating Ventilation and Air -Conditioning
IPaC (USFWS) Information for Planning and Consultation
MRO Maintenance Repair and Overhaul
NAAQS National Ambient Air Quality Standards
NCAC North Carolina Administrative Code
NCDEQ North Carolina Department of Environmental Quality
Environmental Assessment 111 July 11, 2019

GSO Rental Car Facilities Relocation
NCDOT
North Carolina Department of Transportation
NCNHP
North Carolina Natural Heritage Program
NCSAM
North Carolina Stream Assessment Method
NCWAM
North Carolina Wetland Assessment Method
NCWRC
North Carolina Wildlife Resources Commission
NEPA
National Environmental Policy Act
NPDES
National Pollutant Discharge Elimination System
NRHP
National Register of Historic Places
NRI
Nationwide Rivers Inventory
PESA
Phase I Environmental Site Assessment
PTAA
Piedmont Triad Airport Authority
QA/QC Quality Assurance / Quality Control
RAC
Rent-A-Car
RIBITS
Regulatory In -lieu fee and Bank Information Tracking System
ROD
Record of Decision
RPZ
Runway Protection Zone
SBG
State Block Grant
SCH
State Clearinghouse
SCM
Stormwater Control Measure
SHPO
State Historic Preservation Office
SMP
Stormwater Management Plan
SMU
Stream Mitigation Unit
SPCC
Spill Prevention Control and Countermeasures
SPPP
Stormwater Pollution Prevention Plan
SRP
Spill Response Procedures
US
United States
USACE
United States Army Corps of Engineers
USDOT
United States Department of Transportation
USEPA
United States Environmental Protection Agency
USFWS
United States Fish and Wildlife Service
USGS
United States Geological Survey
UST
Underground Storage Tank
WMU
Wetland Mitigation Unit
WOTUS
Waters of the United States
WSJ
Winston-Salem Journal
WSRO
(NCDEQ) Winston-Salem Regional Office
WSWMP
(PTAA) Water Supply Watershed Management and Protection
Environmental Assessment 1v July 11, 2019

GSO Rental Car Facilities Relocation
1 Proposed Action
The Piedmont Triad Airport Authority (PTAA) is the "Airport Sponsor" of the Piedmont Triad
International Airport (GSO), west of the city of Greensboro in Guilford County, North Carolina
(Figure 1). The Airport Sponsor is obligated to remove obstructions to the visibility of Taxiway E
from the Air Traffic Control Tower (ATCT) as determined by the Federal Aviation Administration
(FAA) Comparative Safety Analysis (Appendix A, Attachment 1). The "Proposed Action" is to
resolve this visibility obstruction and includes the following four key components (Figure 2):
1. Site preparation and stabilization of approximately 49 acres of developed land including
Removal of Existing Rental Car Facilities and adjacent air cargo structures (Figure 3)
and re -grading to allow line -of -sight from the ATCT to Taxiway E;
2. Site preparation (including hauling of approximately 300,000 cubic yards clean fill from
the existing rental car facilities, above) of approximately 44 acres of future aerospace
development, approved previously (FAA, 2001). Adjacent to this location, approximately
10 acres of clearing and grading for construction and continuation of utilities along the
Proposed Worldwide Drive right-of-way, including electrical/lighting, communications,
and stormwater management (Air Cargo site, Figure 4),
3. Site preparation of approximately 57 acres of land including clearing and grading for
construction of paved parking areas for approximately 2,360 spaces and infrastructure for
approximately 16,900 square feet building space, including connection of utilities,
stormwater management, and communications for the Proposed New Rental Car
Facilities (Inman site, Figure 5), and
4. Site preparation and stabilization of approximately 28 acres for Proposed Spoil
Embankment of approximately 600,000 cubic yards of clean fill (from the Inman site,
above) adjacent to and north of the Honda Aircraft Company Maintenance Repair and
Overhaul (MRO) facility (Chimney Rock site, Figure 6).
The proposed project schedule is dependent on receipt of appropriate regulatory approvals
including documented compliance with the National Environmental Policy Act (NEPA) and Clean
Water Act (CWA). Removal of the existing rent -a -car (RAC) facilities is contingent on
completion of appropriate replacement with suitable access and functionality. Notwithstanding
concurrent scheduling of component construction to the extent practicable, environmental
protection measures for the proposed fill sites and haul roads would commence along with proj ect
components exempt from permitting or otherwise regulatorily approved as soon as possible,
potentially in 2019. Project completion would be anticipated at least two years after
commencement. The requested federal actions considered in this Environmental Assessment
(EA) include FAA acceptance of the NEPA analysis completed to support the Proposed Action
and issuance of an environmental finding necessary to allow Federal funding for those actions
determined eligible. FAA acceptance of a NEPA analysis document and issuance of a decision
document or finding is only a determination that the document satisfies applicable environmental
statutes and regulations.
Environmental Assessment 1 July 11, 2019

GSO Rental Car Facilities Relocation
Figure 1 Vroject Location
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Environmental Assessment 2 July 11, 2019
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Environmental Assessment 2 July 11, 2019
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Environmental Assessment 2 July 11, 2019

GSO Rental Car Facilities Relocation
Environmental Assessment July 11, 2019

GSO Rental Car Facilities Relocation
Environmental Assessment

GSO Rental Car Facilities Relocation
Figure 5 Proposed New Rental Car Facilities
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Environmental Assessment 6

GSO Rental Car Facilities Relocation
Environmental Assessment

GSO Rental Car Facilities Relocation
2 Purpose and Need
The purpose of this NEPA analysis is to allow the FAA to approve an update to the Airport
Sponsor's ALP depicting the Proposed Action, as previously defined in Section 1. A finding by
the FAA is a preliminary step in allowing the Airport Sponsor to proceed with the activities
described and seek federal funding participation for project components as determined eligible.
The purpose of the Proposed Action is to eliminate a "line -of -sight" issue for the proposed
ATCT created by existing rental car facilities, thereby requiring the relocation of the facilities
posing visibility obstructions. The Proposed Action must be implemented in accordance with FAA
design standards and Federal Aviation Regulations (FAR) while maintaining rental car service
provider neutrality. Because the parameters of the ATCT line -of -sight are not flexible, the only
viable alternative is to eliminate the obstruction and move the subject facilities.
The existing Hertz rental car facility is located on high ground between the proposed ATCT and
Taxiway E and must be excavated to provide appropriate line -of -sight (see Appendix A,
Attachment 1). To prevent competitive disadvantage to Hertz, the remaining rental car facilities
must also be relocated with Hertz. The new rental car facilities location will require appropriate
vehicle access to and from the Terminal area. Excess earth from both the existing Hertz site and
proposed new rental car site must be moved to the nearest appropriate respective locations.
Ancillary needs with potential to be met by a project alternative present the potential for significant
efficiencies in cost -savings, aviation safety, and regulatory compliance. Such needs include
development of an additional terminal public roadway to serve as redundant vehicle access and for
emergency planning and evacuation, separation of public versus rental car terminal access, and
advanced site preparation of dedicated aerospace tracts.
The size, orientation, and proximity of a replacement site for rental car facilities must be adequate
to at least replace the existing facilities and not interfere with current or planned aviation functions
and FAA compliance of the Airport. Due to the significant economic growth component of the
Airport Sponsor's mission, any proposed action must also be compatible with the planned
aerospace development tracts at GSO. Consideration of site alternatives for associated project
components (such as borrow, fill, haul routes, or site access) is similarly restricted by the aviation
and economic missions of the PTAH. The Proposed Action, including all components, must not
interfere with aviation or economic development specific to GSO.
The "Inman" site at the Northeast quadrant of the Inman Road / Bryan Boulevard intersection
(Figure 1, Figure 2, Figure 5) is appropriately sized and situated for the combined rental car
facilities to be relocated. Continuation of Worldwide Drive (in the manner originally contemplated
for its ultimate design) from Old Oak Ridge Road to Air Cargo Road (Figure 4) both connects the
relocated rental car facilities and provides an alternative Airport entry/exit for surface
transportation. Moving fill excavated from the Hertz rental car site to the aerospace development
(Figure 4) site adjacent to Worldwide Drive is the most efficient solution for earthwork required
to eliminate the Taxiway E visibility issue. PTAA-owned land at the "Chimney Rock" site
(Figure 6) is the nearest appropriate location for embankment of excess fill from excavation of the
proposed Inman site. The Proposed Action, including connected projects, would eliminate the
current ATCT line -of -sight obstruction to Taxiway E, improve operational efficiency, facilitate
emergency planning, and expedite compliance with FAA requirements at GSO.
MM
0rii
Environmental Assessment 8 July 11, 2019

GSO Rental Car Facilities Relocation
3 Alternatives
Alternatives are considered to the degree commensurate with the nature of the proposed action and
agency experience with the environmental issues involved. Generally, the greater the degree of
impacts, the wider the range of alternatives. Brief explanation is provided for why alternatives
considered were eliminated from further study. All reasonable alternatives and the No -Action
Alternative were evaluated and are summarized in the following subsections prior to consideration
of the Preferred Alternative.
3.1 Reasonable Alternatives Considered
Reasonable alternative locations and concepts to proposed project components are evaluated and
summarized in the following six subsections. Alternatives to removing the existing rental car
facilities and locating new facilities are limited by the project Purpose and Need as discussed in
Section 1. Locating appropriate sites to haul excess fill from both these are similarly limited by
distance, suitability, aviation safety, and economics. Environmental concerns, as discussed in the
following subsections, apply additional limitations to alternatives but opportunities with
significant efficiencies are also presented.
3.1.1 Removal of Existing Rental Car Facilities
The only viable solution to resolving the Taxiway E visibility issue is to remove the obstruction.
The use of remote cameras to transfer live video feed of hidden portions of the taxiway is a limited
alternative, only temporarily applicable for the existing tower due to its limited remaining life.
The existing Hertz building and several feet of topography at this location must be removed to
comply with FAA safety requirements. The excess material removed from the site would be
deposited at an existing, approved airport waste site (or similar). The excess material could then
be recovered should it be needed for future airport -related development. The temporary, on-site
storage of excess material for future airport needs is an efficient alternative and provides a means
of reducing redundant and expensive earthwork and hauling. The proposed aerospace
development site adjacent to the FedEx Mid -Atlantic Hub (Air Cargo site) is suitably close to the
existing rental car facilities to minimize haul distance and is also appropriately designated to
receive such fill in the context of future aviation development. There are no closer suitable sites.
3.1.2 Proposed New Rental Car Facilities
The only other potential areas with adequate size for relocation of the rental car facilities include
the proposed aerospace development sites owned by PTAH. Each of these five tracts (Figure 7)
appear adequately sized for the combined rental car facilities but are strategically located with
runway/taxiway frontage — significant for aerospace development, but not necessary for airport
rental car facilities. These sites would also involve additional driving distances to the Passenger
Terminal and potential rental car development complications arising from their intimacy with
airside operations. Due to the unique features of the other appropriately sized GSO sites for
aerospace development, these locations were removed from consideration for the rental car
facilities. Development as rental car facilities would be an inefficient and inappropriate use of
these Airport properties and interfere with PTAA's aerospace development mission.
Environmental Assessment 9 July 11, 2019

GSO Rental Car Facilities Relocation
Not depicted on Figure 7 is the aerospace development site dedicated in 2001, but as yet
undeveloped. This site remains the Airport Sponsor's potentially most important location for
aerospace development due to its location between parallel runways, and adjacent to Taxiway E,
Air Cargo Road, and the existing FedEx Mid -Atlantic Hub. This site was excluded from
consideration for development of either rental car facilities or roadway due to its significance for
future aviation development. The Inman site (also not shown on Figure 7) is the only suitable
location not obligated for aerospace but with adequate size, orientation, and proximity, for rental
car facility development.
Given the lack of alternative site locations and restrictions on site access routes, four alternative
options for development of the Inman site for rental car facilities were considered in addition to
the "No -Action" Alternative. The first option (Figure 8, initially preferred by the Airport Sponsor)
contemplates complete development of the site including direct impacts to natural resources.
Environmental Assessment 10 July 11, 2019

GSO Rental Car Facilities Relocation
Due to the presence of jurisdictional wetlands and streams on the site, significant effort was
afforded to avoiding these resources, consistent with CWA guidance, during the advancement of
preliminary designs. Therefore, the Airport Sponsor abandoned the complete site development
option in favor of more environmentally sustainable "avoidance" alternatives, presented in
Sections 3.1.3 and 3.1.4.
3.1.3 Inman Site Development Option 2
This option (Figure 9) was conceived as an attempt to avoid direct impacts to jurisdictional
wetlands, streams, and riparian buffers to the extent practicable. The environmental resources
associated with these jurisdictional areas (such as fish, wildlife, plants, floodplains, surface waters,
and groundwater) are similarly avoided. Option 2 contemplates 21.66 acres of development
including 2,360 parking spaces and 16,900 square feet of buildings, disturbing 52.6 acres and
involving 816,000 cubic yards of cut. Because the existing Inman site is entirely pervious, the
development of the minimum acreage for the rental car facilities and parking creates the need for
stormwater management. Maximization of side -slope steepness at the development perimeters to
avoid the adjacent natural resources also exacerbates the necessity for appropriate stormwater
management. Four stormwater management areas are therefore included downslope of the parking
areas. For preliminary planning purposes, these areas have been designed as ponds to determine
their approximate size and adequacy to match pre- and post -development runoff. However, due
to the concern for ponds to attract wildlife hazardous to aviation, these areas would likely be
developed as stormwater Best Management Practice (BMP) sites that are more suitable for
locations near airports. Designing the ponds as BMPs would be consistent with current FAA and
Environmental Assessment I I July 11, 2019

GSO Rental Car Facilities Relocation
North Carolina guidance. The specific location of such BMPs within the development site is
dictated by stormwater management design protocols and has the potential to impact the hydrology
of downstream and upstream water resources. This option is being advanced as the Preferred
Alternative (Section 3.3).
3.1.4 Inman Site Development Option 3
In addition to the avoidance of direct impacts to natural resources, this option (Figure 10) was
conceived to explore the feasibility of re -locating stormwater management to facilitate specific
and appropriate continuity of a hydrologic source for the headwater streams and wetlands to be
preserved on-site. Option 3 contemplates 21.50 acres of development including 2,300 parking
spaces and 16,900 square feet of buildings, disturbing 52.6 acres and involving 816,000 cubic
yards of cut. This option significantly isolates a portion of the parking area and may result in
competitive disadvantage to one or more of the GSO rental car tenants. Therefore, this option was
not advanced for further study.
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3.1.5 Proposed Worldwide Drive
Access options from the Passenger Terminal to the Inman site are limited by existing land -use and
transportation infrastructure. The access road must be located between the Brush Creek
Conservation Easement (stream, wetland, and riparian buffer mitigation) and the adjacent
aerospace development site to avoid impacts to either and efficiently connect the new rental car
facilities (see Figure 4). The only alternative route connecting Old Oak Ridge Road with
Air Cargo Road to avoid a stream crossing would isolate and divide the aerospace development
site. This alternative would also entail additional drive distance as the roadway required would be
longer. The preferred alignment for the extension of Worldwide Drive is consistent with the
approved ALP. The Environmental Impact Statement / Record of Decision (EIS/ROD) (FAA,
2001) and subsequent CWA permits issued for Runway 5L/23R and associated developments
anticipated the preferred alignment of Worldwide Drive, including the stream crossing, would be
constructed once plans were advanced for the aerospace development site. Impacts to
jurisdictional resources (wetlands, streams, and stream buffer) are anticipated to be minor and have
already been mitigated. This alignment would avoid impacts to the existing Federal Express
facility and allow for the planned development specifically for the aerospace industry.
Constructing Worldwide Drive with an alignment that completely avoids jurisdictional resources
would involve relocating the western portion of the road to the south which would severely impact
the approved aerospace development - essentially reducing its size by more than 50 percent, and
isolating it from adjacent facilities. This alignment would also decrease the aerospace use of
property that is dedicated to accommodating aviation activity. This alignment would eliminate the
potential to construct nearly 15 future aircraft parking positions resulting in an uneconomic
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remnant of the property. Significantly, this site is also located between parallel runways, which
renders it a premium aerospace development location. Other areas either on-, or off -airport
property would have to be identified to accommodate the demand for the planned aviation activity
with extensive coordination effort required to re -designate this area as non -aeronautical use. The
proposed Worldwide Drive stream crossing, therefore, becomes an unavoidable necessity to
maintain the integrity of this important aerospace development site, consistent with the approved
ALP.
As discussed in Section 3.1.1, the use of fill material for site preparation on airport sites that may
be recovered in the future for airport -related development is an efficient use of resources and
minimizes earthwork, hauling, and associated environmental impacts from repeated use of heavy
equipment and vehicles. The closest available site for disposal of clean fill to be excavated from
the rental car facilities is the aerospace development tract adjacent to the FedEx Mid -Atlantic Hub,
discussed in the previous paragraph. Additional rationale for deposition of fill from the existing
rental car facilities to the aerospace development site is summarized as follows:
1) PTAA's mission includes planning and constructing economic development assets;
2) This location is PTAA's premier aerospace site due to setting between two runways;
3) This location will be developed for a future tenant, if not for FedEx; and
4) Avoiding development of this site now would simply be postponing a significant element
of PTAA's mission and result in more expensive development in the future.
3.1.6 Proposed Spoil Embankment
Stream and associated riparian buffer resources at the Chimney Rock site (see Figure 6) are
completely avoided by the proposed spoil (anticipated from the Inman site) embankment at that
location. The Chimney Rock site is preferred due to the minimization of haul distance and
potential environmental impacts associated with driving heavy equipment and vehicles.
3.2 No -Action Alternative
The No -Action Alternative would avoid most environmental consequences, including the potential
continued existence of wetlands, streams, and forested uplands adjacent to the Inman /
Old Oak Ridge Road intersection, but without management in context of their developed
surroundings. The no -action alternative does not meet the Project purpose or need because
continued existence of high -ground and structures at the Hertz facility would prohibit appropriate
visibility of Taxiway E from the ATCT, contrary to FAA requirements. The ability of all rental
car facilities to function efficiently at GSO would be compromised by lack of growth or
modernization potential. A lack of redundant vehicle entry/exit capability or separation of rental
car traffic from private transport would continue to hinder GSO efficiency and emergency
planning. If the proposed fill site is not adequately prepared for aerospace development, GSO
would be deprived of a specifically -planned economic development, contrary to PTAA's mission.
If Worldwide Drive is not connected, as planned, the rental car companies would be forced to use
the main GSO entrance for access to the passenger terminal, requiring a significantly longer drive
with consequent gas, mileage, and time inefficiencies.
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3.3 Preferred Alternative
Based on the considerable deliberation of potential impacts to environmental resources discussed
in Sections 3.1.2, 3.1.3, and 3.1.4, the Airport Sponsor is advancing the Option 2 alternative for
development of the Inman site. This option is summarized in Section 3.1.3 and as the Proposed
Action in Section 1 and contemplates avoidance and minimization of impacts to the extent the
preliminary planning phase of this Proposed Action reasonably allows. The Proposed Action
includes relocating all the existing rental car facilities from their current location to the Inman site
and developing that site with appropriate access. Rationale for the preferred site access
(Worldwide Drive) and fill locations (Air Cargo site and Chimney Rock site) are discussed in
Sections 3.1.5 and 3.1.6 respectively.
ME
WIN
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4 Affected Environment and Environmental Consequences
This section succinctly describes the environmental conditions of the potentially affected
geographic areas. The discussion of the affected environment is necessary to understand the
impacts of the alternatives. Data and analyses are presented commensurate with the importance
of the impact. This section of the EA discusses, in comparative form, the reasonably foreseeable
environmental impacts of the proposed action and the no action alternative. The focus of this
analysis is on resources that would be directly or indirectly affected. The analysis includes
consideration of possible conflicts with the objectives of Federal, regional, state, tribal, and local
land use plans, policies, and controls for the area concerned, as well as other conflicts concerning
alternative uses of available resources. Relevant supporting documentation is included in
Appendix A and regulatory correspondence is attached in Appendix B. Thirteen environmental
impact categories are addressed in the following subsections:
L Air Quality
2. Biological Resources (including fish, wildlife, and plants)
3. Climate
4. Department of Transportation Act, Section 4(f)
5. Farmlands
6. Hazardous Materials, Solid Waste, and Pollution Prevention
7. Historical, Architectural, Archeological, and Cultural Resources
8. Land Use
9. Natural Resources and Energy Supply
10. Noise and Compatible Land Use
11. Socioeconomics, Environmental Justice, Children's Environmental Health and Safety
Risks
12. Visual Effects (including light emissions)
13. Water Resources (including wetlands, floodplains, surface waters, groundwater, and wild
and scenic rivers)
The no action, proposed action, and reasonable alternatives would not affect Coastal Resources
because Guilford County is not one of North Carolina's twenty coastal counties. Cumulative
Impacts, Permits and Certifications, and Mitigation are summarized in subsequent sections as they
have potential to involve multiple impact categories and consequences.
4.1 Air Quality
Air quality is the measure of the condition of the air expressed in terms of ambient pollutant
concentrations and their temporal and spatial distribution. Air quality regulations in the United
States are based on concerns that high concentrations of air pollutants can harm human health,
especially for children, the elderly, and people with compromised health conditions, as well as
adversely affect public welfare by damage to crops, vegetation, buildings, and other property.
Greenhouse gases (GHGs) are a separate component of air quality studies (see Section 4.3).
Guilford County is identified as unclassified/attainment for all National Ambient Air Quality
Standards (NAAQS) and as such, the region is not subject to Transportation Conformity under the
Clean Air Act. The Proposed Action is anticipated to have no meaningful impact on airside
operations and will not facilitate any additional aircraft activity. No net increase in operating
emissions is anticipated because of the Proposed Action. A construction -related emissions
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inventory analysis (Appendix A, Attachment 2) was completed to ensure that no meaningful air
quality impacts occur. It was determined that general conformity would be appropriate,
specifically a comparison of total construction emissions to the United States Environmental
Protection Agency (USEPA) de minimis values to ensure the project will not have meaningful air
quality impacts. Using FAA guidance and the accompanying Airport Construction Emissions
Inventory Tool (ACEIT), a conservative estimate of the total construction emissions was
developed. While the project is anticipated to take two years to complete, with no available
schedule the total two-year construction emissions were compared to the annual de minimis level
set by USEPA. The total estimated construction emissions were found to be significantly below
the de minimis levels. Therefore, the proposed action will not have a significant or meaningful
impact on regional or local air quality.
4.2 Biological Resources (including fish, wildlife, and plants)
Biological resources are valued for their intrinsic, aesthetic, economic, and recreational qualities
and include fish, wildlife, plants, and their respective habitats. Biological resources include
terrestrial and aquatic plant and animal species, game and non -game species, special status species
(state or Federally -listed threatened or endangered species, marine mammals, or species of
concern, such as species proposed for listing or migratory birds); and environmentally -sensitive or
critical habitats.
Assessment of natural communities and protected species was conducted in general accordance
with North Carolina Department of Transportation (NCDOT) Natural Environment Section
guidance and procedures.
Depending on final design, approximately 37 acres of mixed pine/hardwood forest, including
perennial stream channels and wetlands (Section 4.13), could be impacted by the Project. Two
man-made ponds would also be partially impacted, depending on final design. Wildlife displaced
could include the limited terrestrial and aquatic species typical of the area. Species observed or
expected for the Project sites are listed in the Biological Assessment completed for the United
States Fish and Wildlife Service (USFWS) On -Line Project Review (Appendix A, Attachment 4).
Loss of isolated potential habitat will be mitigated in conjunction with the mitigation (see
Section 6) of wetland, stream, and riparian buffer impacts (Section 4.13) and will not result in
fragmentation or impacts to off-site habitat. Terrestrial Communities, Terrestrial Wildlife, Aquatic
Communities, Invasive Species, Endangered Species Act Protected Species, Bald Eagle and
Golden Eagle Protection Act, Endangered Species Act Candidate Species, Federal Species of
Concern, and State -Protected Species are discussed in the following subsections.
4.2.1 Terrestrial Communities
Two terrestrial communities were identified at the three properties (Chimney Rock, Inman, and
Air Cargo sites): Maintained/Disturbed areas and Mixed Pine/Hardwood Forest. The location and
extent of these terrestrial communities within the study areas and the area of each cover type at
each site are detailed in the Biological Assessment (Attachment 4, Page A-29). A brief description
of each community type follows.
4.2.1.1 Maintained/Disturbed
Maintained/Disturbed areas dominate the Airport and include areas outside the Air Operations
Area (AOA) where vegetation is routinely or periodically mowed. Vegetation remnant in this
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community typically includes low growing grasses and herbs such as fescue, clover, wild onion,
lespedeza, Chinese privet, kudzu, and multiflora rose. Maintained/disturbed land generally
includes roadside shoulders, utility corridors, and maintained lawns associated with residential,
industrial, and recreational development. Maintained lawns and roadside shoulders generally
consisted of low -growing grasses and weedy forbs such as fescue, white clover, geranium,
dandelion, Carolina horse nettle, and wild onion. These areas include scattered native and
ornamental trees and saplings such as white oak, northern red oak, Virginia pine, mimosa, tree of
heaven, Bradford pear, Kentucky coffee tree and crepe myrtle. Utility corridors included similar
grass and forb species, but more commonly dominated by large weedy herbs and opportunistic
species such as lespedeza, goldenrod, sunflowers, milkweed, ragweed, and Queen Anne's lace,
and occasionally dense shrubs such as sweetgum, red maple, eastern red cedar, blackberry, smooth
sumac, and multiflora rose. Several areas are dominated by a dense growth of vines such as poison
ivy, Virginia creeper, English ivy, and kudzu.
4.2.1.2 Mixed Pine/Hardwood Forest
Small fragmented areas of Mixed Pine/Hardwood Forest occur generally along the margins of
roadways and along stream corridors and include forested communities of varying ages and levels
of disturbance. Canopy trees include loblolly pine, Virginia pine, red maple, tulip poplar,
sweetgum, white oak, southern red oak, northern red oak, mockernut hickory, and black cherry.
Saplings present include canopy species as well as American beech, red mulberry, persimmon,
American holly, eastern red cedar, flowering dogwood, and sassafras. In mesic areas near streams
and wetlands, species adapted to wet conditions such as willow oak, American elm, green ash,
redbud, river birch, black willow, tag alder, ironwood, and tulip poplar tend to dominate the canopy
and sapling layers. Shrubs are thickest along woodland edges and in mesic areas near streams,
wetlands and pond edges. These areas include Chinese privet, autumn olive, highbush blueberry,
strawberry bush, spicebush, and sedges. Vines present include poison ivy, Japanese honeysuckle,
Virginia creeper, common greenbrier, and muscadine grape. Herbs within this community are
sparse to frequent and include Christmas fern, rattlesnake fern, ebony spleenwort, Japanese stilt
grass, large whorled pogonia, Indian cucumber -root, Solomon's seal, wild ginger, ground cedar,
and spotted wintergreen.
4.2.2 Terrestrial Wildlife
Terrestrial communities in the study areas are comprised primarily of disturbed habitats that may
support a limited diversity of wildlife species. Mammals that commonly exploit habitats found at
the Airport include eastern grey squirrel, eastern cottontail, raccoon, white-tailed deer, groundhog,
and Virginia opossum. Birds that commonly use forest and forest edge habitats include American
crow, blue jay, Carolina chickadee, tufted titmouse, Carolina wren, downy woodpecker, yellow -
bellied sapsucker, northern mockingbird, sharp -shinned hawk, indigo bunting, eastern towhee,
northern cardinal, red -bellied woodpecker, and white -eyed vireo. Birds that may use the open
habitat within the study area include house finch, barn swallow, American kestrel, American robin,
European starling, mourning dove, great crested flycatcher, eastern bluebird, field sparrow, eastern
meadowlark, red -shouldered hawk, and turkey vulture. Reptile and amphibian species that may
use terrestrial communities located at the Airport include marbled salamander, white -spotted slimy
salamander, American toad, gray treefrog, spring peeper, eastern box turtle, eastern fence lizard,
five -lined skink, black racer, rat snake, eastern ribbon snake, and copperhead.
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4.2.3 Aquatic Communities
Aquatic communities at the project sites are supported by intermittent and perennial piedmont
streams and two open -water ponds. Perennial streams may contain gizzard shad, golden shiner,
rosyside dace, eastern silvery minnow, spottail shiner, tessellated darter, bluehead chub, creek
chub, margined madtom, redbreast sunfish, and northern dusky salamander. Intermittent streams
on-site are relatively small and may support aquatic communities of spring peeper, crayfish, and
various benthic macroinvertebrates. Open -water ponds may contain species such as common carp,
grass carp, yellow bullhead, pumpkinseed, bluegill, redfin pickerel, and eastern mosquitofish.
Aquatic -dependent wildlife expected to utilize these communities include painted turtle, yellow -
bellied slider, northern water snake, beaver, great blue heron, green heron, and belted kingfisher.
4.2.4 Invasive Species
Ten species from the NCDOT Invasive Exotic Plant List for North Carolina (NCDOT, 2012) occur
at the Airport. Five level 1 (Threat) invasive species were identified: Chinese privet, multiflora
rose, Japanese stilt grass, tree of heaven, and kudzu. Four level 2 (Moderate Threat) invasive
species were identified: mimosa, autumn olive, English ivy, and Japanese honeysuckle. One
level 3 (Watch List) invasive species was identified: Bradford pear.
4.2.5 Endangered Species Act Protected Species
As of October 14, 2018, the USFWS lists Small Whorled Pogonia as threatened and Schweinitz's
Sunflower as endangered in Guilford County (Appendix A, Attachment 3). A brief description of
these species' habitat requirements follows. Habitat requirements are based on the current best
available information from referenced literature and/or USFWS.
Small -whorled pogonia occurs in young as well as maturing (second to third successional growth)
mixed -deciduous or mixed-deciduous/coniferous forests. It does not appear to exhibit strong
affinities for a particular aspect, soil type, or underlying geologic substrate. In North Carolina, the
perennial orchid is typically found in open, dry deciduous woods and is often associated with white
pine and rhododendron. The species may also be found on dry, rocky, wooded slopes; moist
slopes; ravines lacking stream channels; or slope bases near braided channels of vernal streams.
The orchid, often limited by shade, requires small light gaps or canopy breaks, and typically grows
under canopies that are relatively open or near features like logging roads or streams that create
long -persisting breaks in the forest canopy.
Schweinitz's sunflower occurs in full to partial sun and is found in areas with poor soils, such as
thin clays that vary from wet to dry. It is believed that this species once occurred in natural forest
openings or grasslands. Many of the remaining populations occur along roadsides.
Suitable habitat is not present at the any of the three sites surveyed for the project. Identified
forested areas do not appear to include suitable persistent canopy breaks. A review of North
Carolina Natural Heritage Program (NCNHP) records indicated no known occurrences within
1.0 mile of the Airport. The USFWS previously listed small -whorled pogonia as a historic record
in Guilford County, indicating that this species was last observed within the County more than
50 years ago. However, a single plant was recently discovered near the Town of Gibsonville
approximately 20 miles east of the Airport.
The Project is anticipated to have no effect on these species - suitable habitat is not present at the
Project sites and review of NCNHP records indicated no known occurrences within 1 mile
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(Appendix A, Attachment 5). Habitat ranges for Endangered (Cape Fear shiner, Roanoke
logperch) and At Risk (Atlantic pigtoe) aquatic species listed do not include the project vicinity.
4.2.6 Bald Eagle and Golden Eagle Protection Act
Habitat for the bald eagle primarily consists of mature forest in proximity to large bodies of open
water for foraging. Large dominant trees are utilized for nesting sites, typically within 1.0 mile of
open water. A desktop Geographic Information System (GIS) assessment of the Airport, as well
as the area within a 1.13 -mile radius (1.0 mile plus 660 feet) of the three sites, was performed
using 2016 color aerial photography. Lake Higgins (a water body large enough and sufficiently
open to be considered a potential feeding source) was identified within this search radius. A survey
of the Chimney Rock, Inman, and Air Cargo sites and the area within 660 feet of these sites was
conducted. No bald eagle nests were observed within this search polygon. Review of the NCNHP
database revealed no known occurrences of this species within 1.0 mile of the Airport.
Since there is potential foraging habitat within the review area, a survey of the project study area
and the area within 660 feet of the project limits for potential nesting habitat was conducted. Most
of the wooded areas within and near the project study areas are planted pine or pine flatwoods that
have previously been logged. As a result of planting and/or past logging, most of the largest and
oldest trees are even -aged stands without the "dominant" canopy trees required for nesting by bald
eagles. It is more likely that bald eagles would utilize potential nesting sites within one mile of
the Cape Fear River and not near the project study areas. No water body large enough and
sufficiently open to be considered a potential feeding source for Bald Eagle is located within
1.13 miles of the Project and there are no known occurrences of this species within 1 mile of the
Project.
4.2.7 Endangered Species Act Candidate Species, Federal Species of Concern, and State -
Protected Species
As of October 14, 2018, the USFWS list no Candidate species for Guilford County. Federal
Species of Concern are not legally protected under the Endangered Species Act and are not subject
to its provisions, including Section 7, until they are formally proposed or listed as Threatened or
Endangered. Organisms that are listed as Endangered, Threatened, or Special Concern on the
NCNHP list of Rare Plant and Animal Species are afforded state protection under the State
Endangered Species Act of 1987 and the North Carolina Plant Protection and Conservation Act of
1979.
There are no State -listed endangered or threatened species known to occur within 1 mile of the
Project (see Attachment 4). Current species listed for the "Guilford" 7.5 -minute United States
Geological Survey (USGS) Topographic Quadrangle from March 3, 2017 search of the NCNHP
database included the Bald Eagle (State Threatened) and Greensboro Burrowing Crayfish (State
Special Concern). The North Carolina Wildlife Resources Commission (NCWRC) have recorded
Greensboro burrowing crayfish and Appalachian golden -banner (State Special Concern -
Vulnerable) in the Project vicinity (Appendix B, Correspondence 7). No Project activity
contemplates take of species listed in the Migratory Bird Treaty Act.
4.3 Climate
Scientific measurements show that Earth's climate is warming, with concurrent impacts including
warmer air temperatures, increased sea level rise, increased storm activity, and an increased
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intensity in precipitation events. Research has shown there is a direct correlation between fuel
combustion and GHG emissions.
A USEPA inventory program, the Greenhouse Gas Reporting Program is currently in place for
facilities with the potential to emit at least 25,000 tons/year of carbon dioxide (CO2) or
proportioned quantities of CO2 equivalents (40 CFR Part 60). The reporting requirement and
25,000 -ton threshold are for stationary sources; there are currently no federal standards for
reporting GHG emissions from aviation sources, as well as no significance thresholds. Due to the
short time that the GHG inventory program has been in effect and its limited scope, little data on
the relative importance of industrial operations and/or construction activities in contributing to
climate change is available. USEPA's inventory program is the current phase of an ongoing
investigation into the long-term climate change effects of GHG emissions and their sustained
presence in the atmosphere.
Additional GHG emissions anticipated from increase in ground vehicle use (additional distance
for rental car shuttling to and from the Passenger Terminal and new facilities) could be mitigated
by consideration of electric or hybrid -electric powered vehicles and the increased efficiency
afforded by newly designed rental car facilities.
4.4 Department of Transportation Act, Section 4(f)
Section 4(f) of the United States Department of Transportation (USDOT) Act of 1966 protects
significant publicly owned parks, recreational areas, wildlife and waterfowl refuges, and public
and private historic sites.
The Project components are located entirely within Airport -owned property. No parks, national
forest, wildlife refuge, recreational areas, USDOT Act Section 4(f), or Section 6(f) resources will
be impacted by the Project (Appendix A, Attachment 6).
4.5 Farmlands
Farmlands are defined as those agricultural areas considered important and protected by Federal,
State, and local regulations. Important farmlands include all pasturelands, croplands, and forests
(even if zoned for development) considered to be prime, unique, or of statewide or local
importance.
The Project components are located entirely on existing Airport property and will not impact
Prime, Unique, Statewide or Locally Important Farmland as defined in the Farmland Protection
Policy Act.
4.6 Hazardous Materials, Solid Waste, and Pollution Prevention
The following were evaluated in terms of existing and potential for impact by the Project:
• Waste streams that would be generated by the Project, potential for the wastes to impact
environmental resources, and the impacts on waste handling and disposal facilities that
would likely receive the wastes,
• Potential hazardous materials that could be used during construction and operation of the
Project, and applicable pollution prevention procedures,
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• Potential to encounter existing hazardous materials at contaminated sites during
construction, operation, and decommissioning of the Project; and
• Potential to interfere with any ongoing remediation of existing contaminated sites at the
proposed Project sites or in the immediate vicinity of the Project.
No significant or reportable spills or contamination incidents have been reported for the Project
sites under the Airport's Spill Prevention Control and Countermeasures (SPCC) plan (PTAA,
2018a) which was initiated in 2004. Pollution prevention is facilitated at GSO through Spill
Response Procedures (PTAA, 2018b) included in the SPCC plan and the GSO Stormwater
Pollution Prevention Plan (SPPP) (PTAA, 2018c). Rental car companies are potential generators
of hazardous waste. Because the proposed Project involves the same rental car tenants, they will
be responsible for updating their facility information with the USEPA. Three inactive
Comprehensive Environmental Response, Compensation, and Liability Information System
(CERCLIS) sites within 1 mile of the Project sites (Appendix B, Correspondence 2) are located in
adjacent or downstream watersheds. During construction and demolition, every feasible effort
will be made to minimize the generation of waste, to recycle materials for which viable markets
exist, and to use recycled products and materials in the development of this Project, where suitable.
Waste generated by this Project that cannot be beneficially reused or recycled will be disposed of
at a solid waste management facility approved to manage the respective waste type. Contractors
will be required to provide proof of proper disposal for waste generated from this Project
(Correspondence 4). Hazardous waste generated from the demolition, construction, operation,
maintenance, and/or remediation (e.g. excavated soil) from the proposed Project will be managed
in accordance with North Carolina Hazardous Waste Rules. Proposed Project activities generating
a solid waste will require determination whether it is a hazardous waste. If a Project site generates
more than 220 pounds of hazardous waste in a calendar month, the North Carolina Department of
Environmental Quality (NCDEQ) Division of Waste Management (DWM) Hazardous Waste
Section will be notified, and the site must comply with the small quantity generator requirements.
If a Project site generates more than 2200 pounds of hazardous waste in a calendar month, DWM
will be notified, and the facility must comply with the large quantity generator requirements
(Correspondence 8). The NCDEQ Winston-Salem Regional Office (WSRO) will be notified if
"orphan" Underground Storage Tank (UST)s are discovered during Project excavation activities.
Demolition of structures containing asbestos material will comply with applicable regulations,
including notification and removal prior to demolition.
Results of the Phase I Environmental Site Assessments (DESA) completed for the Project locations
(Appendix A, Attachment 7) indicated the following recognized environmental concerns (REC):
• Potential for impact to the existing Hertz Rental Car site from undocumented release of
petroleum or hazardous materials associated with the two 10,000 -gallon gasoline USTs
and associated dispensers, the automotive service and repair performed, and the former in -
ground hydraulic lifts at this facility.
• Potential for impact to the existing Enterprise Rental Car location from undocumented
releases of petroleum or hazardous materials associated with the 10,000 -gallon gasoline
UST and associated dispensers, the automotive service and repair performed, and the
former in -ground hydraulic lifts at this facility.
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• Potential for impact to the existing Avis/Budget Rental Car location from undocumented
release of petroleum or hazardous materials associated with the 10,000 -gallon gasoline
UST and associated dispensers, two 1,000 -gallon oil USTs, the automotive service and
repair performed, and the former in -ground hydraulic lifts at this facility.
• Potential for impact to the existing National/Alamo Rental Car location from
undocumented release of petroleum or hazardous materials associated with two 550 -gallon
used oil USTs, the automotive service and repair performed, and the former in -ground
hydraulic lifts at this facility.
• Potential for impact to the original cargo building location from undocumented releases of
petroleum or hazardous materials associated with the automotive service and repair facility
in this building.
• Potential for undocumented release from the Colonial Pipeline that is located immediately
north of the southern portion of the proposed new rental car facilities (Inman) site.
Appropriate measures will be undertaken to investigate and remediate potential undocumented
releases at the existing rental car facilities prior to completion of site re -grading.
4.7 Historical, Architectural, Archeological, and Cultural Resources
Historical, architectural, archeological, and cultural resources encompass a range of sites,
properties, and physical resources relating to human activities, society, and cultural institutions.
Such resources include past and present expressions of human culture and history in the physical
environment, such as prehistoric and historic archaeological sites, structures, objects, districts,
which are considered important to a culture or community. Historical, architectural, archeological,
and cultural resources also include aspects of the physical environment, namely natural features
and biota, that are a part of traditional ways of life and practices and are associated with community
values and institutions.
No National Register of Historic Places (NRNP) architectural resources will be impacted by the
Project according to the HPOVJEB map (Appendix A, Attachment 8) and the State Historic
Preservation Office (SHPO) had no comment in response to early coordination for the proposed
Project (Appendix B, Correspondence 10). On May 26, 2019, a field investigation of 15
architectural resources within the Area of Potential Effect (APE) approximately 2000 feet from
the center of the Inman site was conducted. The survey (Appendix A, Attachment 9) found that
none of the 15 properties is considered eligible for the NRHP under any criterion. A GIS Predictive
Model was used to identify areas within the Inman Site (excluding the two ponds) that have a high
probability for the presence of archaeological sites and that may be subject to direct and indirect
effects from the proposed relocation of the rental car facilities. The outcome of the GIS Predictive
Model (Attachment 10) was a spatial depiction of the project area that has a high probability for
the presence of historic and prehistoric archaeological resources based on an analysis of
environmental conditions and historic data. Four sites (two prehistoric lithic scatters and two
historic sites with building foundations and a scatter of artifacts) were identified on the 18 -acres
(about 30 percent) of the 57 -acre project APE that were identified as having a high -probability for
the presence of archaeological sites (Attachment 10). None of the sites retains enough integrity to
recommend them as being eligible for the National Register. No further archaeological work was
recommended.
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4.8 Land Use
Section 1502.16(c) of the Council on Environmental Quality (CEQ) Regulations requires the
discussion of environmental impacts including "[p]ossible conflicts between the proposed action
and the objectives of Federal, regional, State, and local (and in the case of a reservation, Indian
tribe) land use plans, policies and controls for the area concerned." Appropriate action has been
or will be taken, to the extent reasonable, to restrict the use of land adjacent to or in the immediate
vicinity of the airport to activities and purposes compatible with normal airport operations,
including landing and takeoff of aircraft. This assurance relates to existing and planned land uses.
The Project is consistent with current plans for development of the area in which the airport is
located. No community disruption or business relocation will result from the Project as it is located
entirely within Airport -owned property and consistent with planned land uses and zoning
(Appendix A, Attachment 11). A portion of the ultimate Runway Protection Zone (RPZ) for
Runway 23L is mapped in the ALP over the southeastern part of the proposed new rental car
location (Inman site, see Figure 5) as "Future RAC/Storage Remote Car Parking" (FAA, 2018).
The small area of parking surfaces in this location are being designed at elevations significantly
under critical elevation such that vehicle and structure heights are sufficiently below approach and
departure surfaces. Much of this area is planned for stormwater management due to low elevation
and includes streams and wetlands being avoided by project impacts. Development of the
proposed action would not involve any construction or development activity in residential areas,
and there would be no shifts in population movement or increase in the demands for public
services. Some streams, wetlands, and jurisdictional ponds may be impacted - reducing or
eliminating the current wildlife hazard potential of these areas to the Airport. The proposed
stormwater management system(s) may include new and/or existing water control/treatment
feature(s) and would be maintained to discourage waterfowl and/or other potentially hazardous
wildlife consistent with FAA Advisory Circular 150/5200-33B — Hazardous Wildlife Attractants
on or Near Airports.
4.9 Natural Resources and Energy Supply
The Project will involve consumption of natural resources (water, asphalt, aggregate, wood, etc.)
and use of energy supplies (coal, natural gas, fuel, etc.) due to construction, operation, and/or
maintenance of the proposed action or altemative(s). All elements of the Project will be designed
with a view to their aesthetic impact and conservation of resources such as energy, pollution
prevention, harmonization with the community environment, and sensitivity to the concerns of the
traveling public.
Project construction and operation will involve energy and natural resource consumption,
primarily electric power. Proposed buildings will include improved thermal efficiency, efficient
heating, ventilation, and air-conditioning (HVAC) and lighting equipment, and low -flow plumbing
fixtures. Energy -sustainable buildings and utilizing applicable forms of proven renewable energy
(e.g. solar power for supplemental electricity and lighting in the parking areas) will be considered.
During construction, overall diesel emission reduction activities will be considered through
various measures such as switching to cleaner fuels, retro -fitting current equipment with emission
reduction technologies, re -powering older engines with newer cleaner engines, replacing older
vehicles, and reducing idling through operator training and/or contracting policies. Contractors
will be required to use dust abatement measures, such as wetting, mulching, or seeding exposed
areas, where appropriate, to address air quality concerns. The Project is expected to have minimal
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impact on operational energy and natural resource consumption. There are no known issues related
to local energy suppliers meeting this increased demand for electric power.
4.10 Noise and Compatible Land Use
Noise is considered unwanted sound that can disturb routine activities (e.g., sleep, conversation,
student learning) and can cause annoyance. Noise is often the predominant aviation environmental
concern of the public. The compatibility of existing and planned land uses with proposed aviation
actions is usually determined in relation to the level of aircraft noise.
The proposed Project would not change Airport runway configurations, aircraft operations and/or
movements, aircraft types using the Airport, or aircraft flight characteristics. Therefore, existing
and future aircraft noise levels would not be affected (Appendix A, Attachment 12). Construction,
demolition activities, and new roadway could create non -aeronautical noise. Noise impacts are
not expected to be significant. Any impacts resulting from construction noise are expected to
occur during daytime hours and will be temporary in nature. Significant noise impacts from
construction are not anticipated.
4.11 Socioeconomics, Environmental Justice, Children's Environmental
Health and Safety Risks
Socioeconomics is an umbrella term used to describe aspects of a project that are either social or
economic in nature. A socioeconomic analysis evaluates how elements of the human environment
such as population, employment, housing, and public services might be affected by the proposed
action and alternative(s). Socioeconomic analysis is project specific and is dependent upon the
existence of a relationship between natural or physical environmental effects and socioeconomic
effects.
Environmental justice is the fair treatment and meaningful involvement of all people regardless of
race, color, national origin, or income with respect to the development, implementation, and
enforcement of environmental laws, regulations, and policies.
It is a high priority to identify and assess environmental health risks and safety risks that may
disproportionately affect children. Environmental health risks and safety risks include risks to
health or to safety that are attributable to products or substances that a child is likely to come in
contact with or ingest, such as air, food, drinking water, recreational waters, soil, or products they
might use or be exposed to. Children may experience a different intensity of impact as compared
to an adult exposed to the same event. Children are also more likely to exhibit behaviors that put
them at a greater risk for exposure to hazards. Children under age 5 are more susceptible than
adults to environmental hazards due to the fact they are more heavily exposed to toxins in
proportion to their body weight. Children under age 5 breathe more air, drink more water, and eat
more food per unit of body weight than adults do, so they may experience higher rates of exposure
to toxins, pollutants, and pathogens. Children between ages 5 and 18 may face higher risks of
exposure to hazardous chemicals due to their growing participation in activities outside of the
home.
Environmental Justice (EJ) indices for environmental variables in the Project area appear less than
national averages (Appendix A, Attachment 13). No additional employees are anticipated by
rental car tenants to staff the proposed new facilities. Construction employment would be
temporary and would not result in significant impacts. The Project is not expected to impact
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children, minority, and/or low-income populations as the Project is located entirely within existing
Airport property. Development of the proposed action would not involve any construction or
development activity in residential areas, and there would be no shifts in population movement or
increase in the demands for public services. The proposed action would not disrupt local traffic
patterns or reduce the levels of service of roads serving the Airport and its surrounding
communities.
4.12 Visual Effects (including light emissions)
Visual effects deal broadly and subjectively with the extent to which the proposed action or
altemative(s) would either: 1) produce light emissions that create annoyance or interfere with
activities; or 2) contrast with, or detract from, the visual resources and/or the visual character of
the existing environment. Visual effects are also discussed in other sections of the EA.
The Project has no potential for visual impacts to USDOT Act Section 106 resources, Section 4(f)
properties, protected coastal areas and rivers, scenic roads/byways, scenic trails, or sensitive
wildlife species. Lights associated with existing industry along Old Oak Ridge Road would be
supplemented by lighting proposed for the rental car facilities. In and of itself, this new lighting
could impact residential areas to the northwest. However, the impact is anticipated to be minimal
given the degree of existing lighting in the area. Existing lighting from the Bryan Boulevard
interchanges and commercial development along Inman and Fleming Roads would also diffuse
the Project's additional light emissions. In addition, because the new rental car facilities will be
significantly below the elevations of nearby residential areas, lighting will not be directly visible
and will be further shielded by surrounding landscape vegetation.
4.13 Water Resources (including wetlands, floodplains, surface waters,
groundwater, and wild and scenic rivers)
Water resources are surface waters and groundwater that are vital to society; they are important in
providing drinking water and in supporting recreation, transportation and commerce, industry,
agriculture, and aquatic ecosystems. Surface water, groundwater, floodplains, and wetlands do
not function as separate and isolated components of the watershed, but rather as a single, integrated
natural system. Disruption of any one part of this system can have consequences to the functioning
of the entire system. Potential direct disruption of these resources and potential for impacts to the
quality of the water resources is discussed. No National Wild and Scenic Rivers, Nationwide
Rivers Inventory (NRI) -listed rivers, river segments, or study rivers are located at or near the
Airport.
4.13.1 Wetlands
Wetlands, streams, and other waters, collectively "Waters of the United States" (WOTUS) are
regulated under the jurisdiction of the USACE and in North Carolina by the NCDEQ Division of
Water Resources (DWR). The North Carolina Stream Assessment Method (NCSAM version 2.1)
and the North Carolina Wetland Assessment Method (NCWAM version 5) were applied to streams
and wetlands verified in jurisdictional determinations (Appendix A, Attachment 14,
Attachment 15, Attachment 16, and Attachment 17) at the three applicable project component
locations. Thirteen jurisdictional aquatic features (Figure 4, Figure 5, Figure 6) were identified,
consisting of eight wetlands (totaling 1.83 acres) and four streams (totaling 3,526 linear feet).
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Additionally, two jurisdictional ponds (other waters, totaling 3.195 acres) were identified at the
Inman site.
Based on the limited space at the proposed new rental car location, constraints of the site
(jurisdictional resources on both sides and in the middle of the facility), and lack of practicable
alternatives; up to 1.83 acres (ac.) of wetlands and 3,526 linear feet (1.£) stream channel could be
impacted by the proposed Project Option 1. PTAA has redesigned the proposed new rental car
facilities (Option 2) to reduce direct impacts to only 0.1 ac. wetlands. Water quality impact
thresholds and mitigation for any unavoidable impacts to jurisdictional water resources will be
resolved through the CWA Section 404 and 401 permitting processes (Appendix B,
Correspondence 5, Correspondence 6) as discussed in Section 6.
4.13.2 Floodplains
No Federal Emergency Management Agency (FEMA) floodplains will be directly impacted by the
Project (Appendix A, Attachment 18). The floodplain of Brush Creek is within a dedicated
preservation/mitigation Conservation Easement and will be avoided during construction and
operation of Worldwide Drive. Potential impacts to floodplain mapped downstream of the
proposed new rental car facilities will be addressed through appropriate regulatory coordination
and stormwater management.
4.13.3 Surface Waters
The Preferred Alternative will result in approximately 80 acres of additional impervious surface.
Application of appropriate stormwater management controls consistent with the State Stormwater
Design Manual, Water Supply Watershed Protection Program, and Jordan Water Supply Nutrient
Strategy regulations will address potential water quality and runoff quantity changes resulting from
the additional impervious surfaces. Protection of downstream drinking water sources will be
ensured through appropriate adherence to PTAA's watershed protection (PTAA, 2019a) and
inspection (PTAA, 2019b) protocols, including Water Supply Watershed Management and
Protection Rules (PTAA, 2001a) and the PTAA Stormwater Management Plan (PTAA, 2001b).
The Project will be constructed consistent with State erosion and sediment control (E&SC) and
National Pollutant Discharge Elimination System (NPDES) construction stormwater management
regulations. Compliance with FAA Standards for Specifying Construction of Airports
(AC 150/5370-10) will further limit construction impacts to water resources. The Project will also
be subject to the Airport's Individual NPDES Industrial Stormwater Permit (NCS000508)
including the SPPP, discharge monitoring program (PTAA, 2019c), Spill Response Procedures,
and SPCC plan.
4.13.4 Groundwater
Potential impacts to groundwater at the subject site are similarly limited by restrictions imposed
by the regulations applicable to wetlands, floodplains, and surface waters. Based on adherence to
CWA regulations and applicable permits required (Section 6), no significant impacts to
groundwater are anticipated. Additional potential impacts to surface and groundwater associated
with hazardous materials are discussed in Section 4.6.
0
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5 Cumulative Impacts
The CEQ Regulations define a cumulative impact as "the impact on the environment which results
from the incremental impact of the action when added to other past, present, and reasonably
foreseeable future actions regardless of what agency (Federal or non -Federal) or person undertakes
such other actions" (see 40 CFR § 1508.7). Cumulative impacts can be viewed as the total
combined impacts on the environment of the proposed action or alternative(s) and other known or
reasonably foreseeable actions.
No cumulative Project environmental effects are anticipated: Past GSO projects have included the
HAECO Facility Improvements, Honda MRO, Honda Connector Road, Taxiway D Extension,
Ballinger Road Extension, and the extension of Taxiway M. Only the HAECO and Connector
Road projects involved quantifiable impacts (Individual and Nationwide CWA Section 404/401
Permits). Adjacent projects include the Cross -Field Taxiway and Site Development Projects and
NCDOT roadway improvements (Appendix B, Correspondence 3) in the Project vicinity (1-73
Connector, US-220/NC-68 Connector, I-840, widening US -220, and widening Market Street). No
significant environmental impacts have been determined for these projects. Tree clearing for the
Runway 23L approach zone adjacent to the proposed New Rental Car Facilities location is
proposed to coincide with the Project construction time -frames, but this is limited to the 42 -acre
area north of Old Oak Ridge Road and the other side of I-73. Cumulatively, the Rental Car
Facilities Relocation would not add significant impacts, rather, the NCDOT roadway
improvements anticipate such Airport development. NCDEQ will also evaluate cumulative
project impacts specific to water quality during the CWA Section 401 Water Quality Certification
process. Development of the proposed action would not involve construction or development
activity in residential areas, and there would be no shifts in population movement or increase in
the demands for public services. The proposed action would not disrupt local traffic patterns or
reduce the levels of service of roads serving the Airport and its surrounding communities.
ME
If
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6 Permits and Certifications
The Affected Environment and Environmental Consequences subsections include information to
demonstrate compliance with those applicable requirements. Anticipated permits, licenses, other
approvals, or reviews that may apply are identified as follows.
CWA Section 401 (Water Quality Certification), 403 (NPDES Permit NCS000508 update), 404
(Individual Permit), State Water Quality (15A NCAC 02H .0500), and NPDES Construction
General Stormwater (NCGO10000) permits will be required (Appendix B, Correspondence 9).
Based on preliminary discussion with USACE and NCDEQ, no unusual or insurmountable
impediments to permitting are anticipated (Correspondence 5, Correspondence 6). However,
because planned air -cargo development has not yet expanded to the aerospace development site,
Worldwide Drive has not been completed and portions of a stream, previously permitted to be
impacted in this vicinity, still exist. The USACE has preliminarily determined that a new
Individual Section 404 permit may be required for proposed impacts to jurisdictional resources
previously authorized by the Individual Permit issued for the FedEx Mid -Atlantic Hub (USAGE
Action ID SAW -2000-21655) due to its expiration in 2013. A corresponding Section 401
certification would also be required.
A 404/401 pre -application meeting was convened on June 24, 2019 at the USACE Raleigh
Regulatory Field Office. The 404/401 permit applications will be submitted consistent with
discussions at that meeting and this EA.
No open burning is anticipated with the Project. Demolition of structures containing asbestos
material will comply with applicable regulations, including notification and removal prior to
demolition. NCDEQ will be notified if "orphan" USTs are discovered during Project excavation.
Plans for water line relocations will be submitted to the DWR Public Water Supply Section.
ME
If
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7 Mitigation
As defined in the CEQ Regulations at 40 CFR § 1508.20, mitigation includes avoiding the impact,
minimizing the impact, rectifying the impact by repairing, rehabilitating, or restoring the
environment, reducing or eliminating the impact over time by preservation and maintenance
operations during the life of the action, and compensating for the impact by replacing or providing
substitute resources.
Unavoidable impacts to WOTUS and other biological and natural resources will be appropriately
mitigated through the CWA Section 401, 404, and State environmental permitting processes and
as anticipated in the following subsections. There are no adjacent resources which would be
impacted or require mitigation because of the Project and potential impacts to nearby
environmental resources will be avoided pursuant to the anticipated requirements of regulatory
permits and compliance. Based on impacts to CWA and State jurisdictional resources estimated
for the Preferred Alternative (Section 4.13), the proposed mitigation strategy is summarized in the
following subsections.
7.1 Avoidance
As summarized in Section 3, the Airport Sponsor has exerted appropriate effort to avoid siting
project components with potential to impact environmental resources through the required
alternatives analysis. Because the Proposed Action is not water -dependent, alternatives to sites
involving impacts to WOTUS were assumed to exist and were explored to the extent available.
7.2 Minimization
PTAA anticipates minimizing potential unavoidable adverse effects of the project consistent with
CWA Section 404(b)(1) guidelines to the extent practicable, as follows:
• Construction of stream culverts will minimize smothering of organisms by utilizing
"pump -around", minimize construction time, control turbidity through adherence to the
Erosion and Sedimentation Control (E&SC) Plan; avoid unnecessary discharge; prevent
creation of standing water, and prevent drainage of wet areas.
• During construction, physiochemical conditions will be maintained, and potency and
availability of pollutants will be reduced; material to be discharged will be limited;
treatment substances may be added if necessary; chemical flocculants may be utilized to
enhance the deposition of suspended particulates in appropriate disposal areas.
• The effects of dredged or fill material may be controlled by selecting discharge methods
and disposal sites where the potential for erosion, slumping or leaching of materials into
the surrounding aquatic ecosystem will be reduced. These methods include using
containment levees, sediment basins, and cover crops to reduce erosion.
• Discharge effects will also be controlled by containing discharged material properly to
prevent point and nonpoint sources of pollution, and timing the discharge to minimize
impact, for instance during periods of unusual high-water flows.
• The effects of a discharge will be minimized by the manner in which it is dispersed, such
as, where environmentally desirable, orienting dredged/fill material to minimize
undesirable obstruction to the surface water or natural flow, and utilizing natural contours
to minimize the size of the fill, using silt screens or other appropriate methods to confine
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suspended particulates/turbidity to a small area where settling or removal can occur;
selecting sites or managing discharges to confine and minimize the release of suspended
particulates to give decreased turbidity levels and to maintain light penetration for
organisms, and setting limitations on the amount of material to be discharged per unit of
time or volume of receiving water.
Discharge technology will be adapted to the needs of the site. The Airport Sponsor will
consider using appropriate equipment or machinery, including protective devices, and the
use of such equipment in activities related to the discharge of dredged or fill material;
employing appropriate maintenance and operation on equipment or machinery, including
adequate training, staffing, and working procedures, using machinery and techniques that
are especially designed to reduce damage to streams; designing access roads and channel
spanning structures using culverts, open channels, and diversions that will pass both low
and high water flows, accommodate fluctuating water levels, and maintain circulation and
faunal movement; employing appropriate machinery and methods of transport of the
material for discharge.
Minimization of adverse effects on populations of plants and animals will be achieved by
minimizing changes in water flow patterns which would interfere with the movement of
animals; managing discharges to avoid creating habitat conducive to the development of
undesirable airport wildlife hazards; avoiding sites having unique habitat or other value,
including habitat of threatened or endangered species; using planning and construction
practices to institute habitat development and restoration to produce a new or modified
environmental state of higher ecological value by displacement of some or all of the
existing environmental characteristics; timing discharge to avoid spawning or migration
seasons and other biologically critical time periods; and avoiding the destruction of
remnant natural sites within areas already affected by development.
7.3 Compensation
In order to comply with FAA wildlife hazard avoidance protocols and the USEPA mitigation rule,
unavoidable impacts are proposed to be mitigated off-site. Mitigation preliminarily anticipated to
be required based on proposed unavoidable impacts of the Preferred Alternative is summarized in
terms of wetland, stream, and riparian buffer mitigation units (WMU, SMU, BMU, respectively).
Specific mitigation ratios have not yet been discussed with regulatory agencies, so those used to
estimate potential impact compensation are preliminary only, based on applicable guidance, as
follows:
• 0.092 acre Wetland impact could require 0.28 WMU at 3:1 ratio;
• 1,694 linear feet Stream impact could require 3,388 SW at 2:1 ratio;
• 184,674 square feet Buffer impact could require 438,537 BMU.
Proposed impacts to 1,221 linear feet of stream tributary to Brush Creek located at the Air Cargo
site have already been mitigated at the Causey Farm mitigation site under USACE Action ID
SAW -2000-021655 (DWR File 00-0846), deemed successful in 2009 and 2010.
Additional successful mitigation in the form of 2.08 WMUs are currently available at PTAA's
Causey Farm mitigation site for use on future GSO projects, pending Corps review and approval
(USAGE, 2016).
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As of October 12, 2017, the USACE Regulatory In -lieu fee and Bank Information Tracking
System (RIBITS) presented five mitigation banks with 622.91 stream (SMU) and 2.67 wetland
(VVW credits under Federal jurisdiction available for the Project Service Area in the
Cape Fear 02 Hydrologic Unit (HUC 03030002). This availability is constantly changing and will
be reviewed and updated during CWA permitting for the project. Compensation for any remaining
balance of unavoidable impacts to wetlands, stream channels, and riparian buffers may be provided
by the NCDEQ Division of Mitigation Services (DMS). If required, an In -Lieu Fee Request will
be submitted to DMS pending approval by USACE and DWR.
Based on the approach summarized above, the cost of mitigating the anticipated stream, wetland,
and riparian buffer impacts for the Preferred Alternative (Option 2) is estimated at approximately
$100K. The cost of mitigating for the maximum impacts (Option 1) is estimated at approximately
$5.7M through the DMS (Appendix A, Attachment 19). If PTAA is required to use available
private mitigation bank(s), these estimates would likely be exceeded. Mitigation costs for the other
build alternatives would range between these two approximations. Due to the preliminary status
of design planning for the Inman Site, mitigation estimates are anticipated "worst -case -scenario'
and should be reduced during the Section 404/401 permitting process.
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8 References
FAA. (2001). Airports, Airport Environmental Records of Decision, North Carolina, Piedmont
Triad International Airport (GSO) (Greensboro, NC). Retrieved from Federal Aviation
Administration:
https://www.faa.gov/airports/environmental/records_decision/media/rod greensboro.pdf
FAA. (2018). Airport Layout Plan. Retrieved from Airport Master Plan Update:
http://airportmasterplan.homestead. com/ALP_Drawing_Set.pdf
NCDOT. (2012). Invasive Exotic Plants of North Carolina. Raleigh, NC. Retrieved from
https://connect.nedot. gov/resources/F,nvironmental/Compliance%20Guides%20and%20P
rocedures/Invasive_Exotic Plants Manual May_2012.pdf
PTAA. (2001a). Water Supply Watershed Management and Protection Rules of the Piedmont
Triad Airport Authority. Retrieved from PTIA Environment SharePoint, Watershed
Ordinance: https://projects.mbakercorp.com/PTIAJDocuments/PTIA WSWMP Rule.pdf
PTAH. (2001b). Stormwater Management Plan. Retrieved from PTIA Environment SharePoint,
2001 SMP: https://projects.mbakercorp.com/PTIAJDocuments/PTIA_SMP.pdf
PTAA. (2018a). Spill Prevention Control and Countermeasures Plan. Retrieved from PTIA
Environment SharePoint, Spill Prevention, SPCC Plan:
https://projects.mbakereorp.com/PTIA/SitePages/SPCC.aspx
PTAA. (2018b). Spill Response Procedures. Retrieved from PTIA Environment SharePoint,
Spill Prevention, Spill Response:
https://proj ects.mbakereorp. com/PTIA/SitePages/SRP. aspx
PTAA. (2018c). Stormwater Pollution Prevention Plan. Retrieved from PTIA Environment
SharePoint, NPDES, SPPP: https://projects.mbakercorp.com/PTIA/SitePages/SPPP.aspx
PTAH. (2019a). Watershed Reporting. Retrieved from PTIA Environment SharePoint,
Watershed Ordinance, Watershed Reporting:
https://proj ects.mbakereorp. com/PTIA/Watershed%20Management/Forms/Watershed%2
OManagement. aspx
PTAH. (2019b). Watershed Inspection. Retrieved from PTIA Environment SharePoint,
Watershed Ordinance, Watershed Inspection:
https : //projects. mbakercorp. com/PTIA/Stormwater%20Maintenance/Forms/AllItems. asp
PTAH. (2019c). Discharge Monitoring. Retrieved from PTIA Environment SharePoint,
Monitoring:
https://proj ects.mbakereorp. com/PTIA/SitePages/NPDE S%20Discharge%20Monitoring.
aspx
USAGE. (2016). Department of the Army Permit SAW -2015-00920. Section 404 Individual
Permit, HAECO Facility Improvements, Regulatory Division, Wilmington, NC.
Retrieved from https://projects.mbakercorp.com/PTIA/404/HAECO_IP.pdf
is
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Appendix A Supporting Documentation
Attachment 1 FAA Comparative Safety Analysis dated 10/31/2013 ......................................
A-1
Attachment 2 BAKER Air Quality Analysis dated 3/11/2019 ................................................
A-6
Attachment 3 USFWS Guilford County Listed Species dated 10/4/2018 .............................
A-18
Attachment 4 USFWS Raleigh ESFO On -Line Project Review (IPaC) dated 4/3/2017.......
A-20
Attachment 5 NCNHP Guilford Quadrangle Species/Community Search dated 3/3/2017...
A-39
Attachment 6 GDOT Road Projects Map dated 3/2/2017 .....................................................
A-40
Attachment 7 PILOT Phase I Environmental Site Assessments dated 11/7/2018 .................
A-41
Attachment 8 SHPO HPOWEB GIS Service dated 3/16/2017 ............................................
A-333
Attachment 9 LEGACY Architectural Investigations dated 6/3/2019 ................................
A-334
Attachment 10 LEGACY Archaeological Survey dated 7/19/2019 ......................................
A-362
Attachment 11 GPD Generalized Future Land Use Map dated 3/2/2017 ..............................
A-442
Attachment 12 PTAA Forecast 2014 Noise Exposure Map dated 11/2007 ..........................
A-443
Attachment 13 USEPA EJScreen Report dated 3/21/2017 ....................................................
A-444
Attachment 14 USACE Determination SAW -2017-00101 dated 3/14/2017 ........................
A-447
Attachment 15 USACE Determination SAW -2017-00103 dated 3/17/2017 ........................
A-451
Attachment 16 NCDEQ Mitigation and Buffer Determination dated 1/30/2017 ..................
A-455
Attachment 17 BAKER NCWAM and NC SAM dated 2/10/2017 ........................................
A-460
Attachment 18 FEMA FIRM Panels 7825, 7826, & 7836 dated 6/18/2007 ..........................
A-536
Attachment 19 NCDEQ Mitigation In -Lieu Fee Schedule effective 7/1/2019 ......................
A-537
Environmental Assessment A July 11, 2019

GSO Rental Car Facilities Relocation
Attachment 1 FAA Comparative Safety Analysis dated 10/31/2013
N
US. c.ror,ll
y rnrya•rvrn
Fedil Mullah
AdminirtraHon
9 ) IM
Mr Michie Elmore
Director of Development
Piedmont Triad Airport Autlwrdy
P O Box 35445
Greensboro, North Carolina 27425
Re'. Proposed ATCUTRACON Development
Dear Mt. Elmore
As agreed to during our work at the Airway Facilities Tower Integration Lab (AFTIL) concerning Ine
Fedaral Aviation Administrll (FAA) plan to replace the Air Traffic Control Tower (ATCT) and
Terminal Radar Approach Gonlrol facAltres (TRACON) at Pieemonl Toad International Airport tGSO)
1 am provlding your office wiln the impacts to GSO as a result 01 the proposed ATC T URACON
location
The Comparative Safety Analysis (CSA) oompleted for the proposed structure at Site 1b Identified
the controller's view of aircraft and vehicular mcriternent on the soinhem portion of TWY 'E' being
obstructed by the Emory building, Hertz Servwe Center ann embankment as a hazard with a medium
inllia' risk The mitigation strategy identified In the CSA tc etlminate Ink nsk Is to
a) Remove Emery Building
b) Remove Hertz Service Center
c) Lower visual obstructing grade of embonkinenl between P1'I Drive and Taxlway'E'
The Piedmont Triad Alport Authority (PTAA) Is Identified as the responsible party to complete the
mlgaticn with a planned comp'ebon date of prior to comrvssioning of tie now ATCT
Current FAA policy requires a written confirmation from the GSO Airport staling In" have advesed
Ore user community of the proposed new ATCT and the affects Ina above Impacts would have on
their operations at the airport Folli log yo„r coordination with the uset community, please complete
and return the enclosed form (Airport Concurrence Form) connrnung :he coord nation with the users
and the+ accep:ance of the above proposed airspace procerhres changes Receipt of this
completed form is necessary fa us to continue beyond the design phase of this prig
If there are any rernamtng questions concerning these findings. I can be reached at 202-385-8709
i
Sincerly,
Ed Tatem
ATO Terminal Fal PlannlnE
cc ATO Manning and Requirements Group AJV-E3
Technical Operations-EngineeringServices AJWEtlD
Al'O GSO AT Manager TEF-GSO
Environmental Assessment A-1 July 11, 2019

GSO Rental Car Facilities Relocation
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Environmental Assessment A-4 July 11, 2019
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Environmental Assessment A-4 July 11, 2019

GSO Rental Car Facilities Relocation
Environmental Assessment A_5 July 11, 2019

GSO Rental Car Facilities Relocation
Attachment 8 SHPO HPOWEB GIS Service dated 3/16/2017
Environmental Assessment A-333 July 11, 2019
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Environmental Assessment A-333 July 11, 2019

GSO Rental Car Facilities Relocation
Correspondence 12 USFWS Letter from Pete Benjamin dated 4/17/21117
United States Department of the Interior
' I -MI %ND Wil UI III tiGRV1iT
•� A.rlelvh tY I reld 1 tlffcc
No 0111LV I>tn W Jol
�' Y Itabl►If1 North iumllne :�A�r• Il;n
April I7, 2017
Richard Darling
Michael Baker Intcrttauonol
200 Centrepon Dr. Sone 1 11
(imvnsbaro. Kt.27409
Re: Rental ('at I•acititicw Relocation (sicdl coni 1 Had Inlenuitional Aql on (iuillord Co . NC
Mar Mr. Darling:
Ibis Irner is to infrrrni ,you that the Service has established an on-line project planning and
consultation process which assists developers and consultants in detemtining whedter it
Irxlerally-listed species or designated critical habitat nary be atYcctcd by a proposed proicet. For
lutun projects. please visit the Raleigh Field 011ice's project planning website at
hl1p::NwaN.fws.Hov!nj1g4 iWj-tltLl, Ifyou al'c Only scarching tun a list of tlpecics Ihal ntay be
prerrnt in the project's Action Arra, then you ntay use the Service's (nfonnation. Planning, and
Consultation System (IP"C' 1 wehsitc kl delcmiinc if any listed. proposed. or candidate spccle.
may be present in the Action Arra and generate a .rpecivs lilt. The ll'a(' wrbsi►e may be v irwed
at Ifttns: rrcy_v l'\�a yu\ ipncr. The [Pat' well site contains a complete atod licyurnily updated list
of all endangered and threatened specics protected by the provisions of the Endangered Species
Act of 1977, as amended (16 US,(', 1511 ct sego )(Act I. it list of federal species of concern' that
arc known to occur in each county in Noah c•onohina, and other r'ewurces.
Section 7 Otitic Act squires that all lederdl ugenctes lot their dt.;iignated non-federal
rcllm,wnlativel, in oonsultatiun with the Service, insure that ally action fi.4ktully authorized.
funded, or carried out by such agencies is not likely to jeopardize the continued exiodencc uruny
federally -listed endangered or Ihreatcned slx;cics. A biological asscssmcnt or evaluation may, be
prepared to lullill that requirement and in dcicrniining whether addiliunal comfultulion with the
Service is necesiatry, In addition to the federally -protected spceics list, intornmliun on the
species' life hl%tulles and habitutt, and infurmution oil completing a biological usscssutcni of
e\alllatl.11l and filet be lbuild oD four Well page at 111111::1w'\\'WI'letcsc CUCk the
%%ch the oticn lift updated inliamution orcluinges
I 'tl►u term -tWerul species of concern" refcle to Ihow specie% which the Service believe- right be In need of
carcentnaled con\enAlton locoioos Federal \pedes of cuncern receive no Ictrpl protection and Iffor &flit nation doc.
not Itrcrsfmrlty imply shut the \pealv%will ""dally be pr»pnsrd I'm livang n'.) federalh etu►eugclyd.x thlcnirned
%tocco s Nowevur. we rvwnrtnvnd that all pracaalble o,emures be taken tf. m oij oo uunuuuc ,LIf of .f nfp,,f i , b
lederal apvcla of wnicrrn
Environmental Assessment B_23 July 11, 2019

GSO Rental Car Facilities Relocation
If your project contains suitable habitat for any of the federal h -listed species known to be
present within the county where your project occur,, the proposed action has the potential to
adversely affect those specics. As such. we recommend that surreys be conducted to detemtinc
the species' presence or absence-.% ithin the project area. I'he use of North C'amlina Natural
I eritage program data should not he substituted for actual tical surveys.
If sou determine that the proposed action nav alYcet (i.e., likely to adversely allect or not likcly
to advcrwly allect) a federally -protected species, you should notify this office with your
determination. the results of your surveys. survey methodologies, and an analysis of the effects
of the action on listed species. including consideration of direct, indirect, and cumulative eflecis,
before conducting any activities that might affect the species. if you determine that the proposed
action will have no clTect (i.e., no beneficial or adverse. direct or indirect clTect) on fcdcmlh
listed species, them you arc not required to contact our office for concurrence (unless an
I n%ironmenial Impact Statement is prepared). lio%%cvcr, you should maintain a complete record
of the asw>snent. including steps leading to your detemtinatum of eflect, the qualified perx)nncl
conducting the a%scssnunt. habitat conditions. site photographs. and any other related articles.
With regard to the atxrvr•referenced project, we offer the follow ing remarks. Out comments are
submitted pursuant to. and in accordance with. provisions of the Lridangered Species Act.
Based on the information provided and other information available, it appears that the proposed
action is not likely to adversely alTect am federally -listed ctidangcrcd or thrv:nrned species, their
formally designated critical habitat. or species currently proposed for listing under the Act at
these sites. We believe that the requirements of section 7(a)1'_) of the Act have been satisfied for
your project. Please remember that obligations under section 7 consultation must be
reconsidered if ( I I 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 %%;L% not considered in this review; or. 13) a new specie's
is listed or critical habitat determined that may be affected by the identified action.
However, the Service is concerned atxrut the potential impacts the proposed action might have
on aquatic species. Aquatic resources arc highly susceptible to wdimentativm. Therefore. sur
recommend that all practicable mcasum be taken to avoid advcrsc impacts to aquatic species.
including implementing directional boring methods and stringent sediment and erosion control
mcawres. An erosion and sedimentation control plan should N. suhnimcd to and approved by
the North Carolina Division of Land Resources. Land Qualit% Section prior to construction.
Erasion and sedimentation controls should be metalled and maintained between the construction
site and am nearby down -gradient surface waters. In addition, vvc recommend maintaining
natural. vegetated butl'rn on all streams and cocks adjacent to the project site.
The Nonh Carolina Wildlife Resources Commission has developed a Guidance Memxrandunn la
copy can be found on our website at lhtip:"-%% fi s go% ralcigh) to address and mitigate
secondary and cumulative impacts to aquatic and terrestrial wildlife resources and water quality.
We recommend that you consider this document in the development of your projects and in
completing an initiation package for consultation (if necessan ).
httn://Vww.ncwildlife.or2/Portals101Conservin2ldocumentsl2002 GuidancellemorandumforSecondarvandCumulalivelmnactsndf
Environmental Assessment B_24 July 11, 2019

GSO Rental Car Facilities Relocation
We hope you find our web Page useful and informative and that following the Process described
above will reduce the lime required. and eliminate the need. for general correspondence for
species' lists. If you have any questions or comments please contact John Ellis of this office ai
(91918564520 ext. 26
tiincereh .
PBenjtunin
Field Supervisor
Environmental Assessment B_25 July 11, 2019

GSO Rental Car Facilities Relocation
Correspondence 10 SHPO Letter from Ramona Bartos dated 3/23/2017
North Carolina Department of Natural and Cultural Resources
Stair Historic Preservaliou Office
k+moon M norm.. Ad. ini-Inswr
t ✓<nrnun key
5ecmary ;Il%i II I Inndlln,
March 23, 2017
Richard Darling
Michael [faker lowt•national
'_00 Ccrilreport Drive. Suite 350
Greensboro. NC 27409
IIn0.Y �,r ArchlK+e1W Illane
Re: Rental Car Facilities Relocation, Piedmont Triad international Airport GSO. Guilford County
ER 17-033'_
Dear Mr. Darling:
Thank you for your letter of February 2.1, 2017. commming the above plrjcct.
We have conducted a review of dtc project and are aware of no historic resources which would he atlected
by the project. Ulteretore, we huve nu cuuuncut on the project as proposed.
The ubove comments are made pursuant to flection lob of the National historic Preservation Act and the
Advisory Council on I listuric Preservation's Regulations Ibr Compliance with Section 106 cudifled at 36
C17t Pan Rot).
Thank you I'or your clxiperation and consideration. If you have questions concx-ening the above comment,
contact Renee Gledhill-F•arlcy, environmentul review coordinator, at 919-807-6579 or
env imnmcntal.rcvictivrg ncdcr.am. In all future communication conceming IN, project, please cite the
atxne refrrrrncd tracking numb>Lr.
Sincerely,
Ramona M. 13urtos
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Environmental Assessment B_20 July 11, 2019

APPENDIX A-2:
EXISTING CONDITIONS EXHIBITS
PROPOSED AND FUTURE CONDITIONS EXHIBITS
Page 26 of 111

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