20191081 Ver 1_Individual Application_20190812

"d"PTI
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
NC Department of Environmental Quality
Division of Water Resources
Water Quality Permitting Section
512 N. Salisbury St., Archdale Bldg. 9t'
Floor
Raleigh, NC 27604
Attention: Mr. David Bailey Ms. Karen Higgins
Regulatory Project Manager Supervisor
Raleigh Field Office 401 & Buffer Permitting Branch
Subject: 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):
1000A Ted Johnson Parkway • Greensboro, North Carolina 27409 • Phone: [phone] • Fax: [phone] • www.flyfrompti.com

Mr. David Bailey and Ms. Karen Higgins
August 8, 2019
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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,

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August 8, 2019
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above) adjacent to and north of the Honda Aircraft Company Maintenance Repair and
Overhaul (MRO) facility (Chimney Rock site, EA Figure 6).
The 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
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 (see FAA Comparative Safety Analysis, EA Appendix A). 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. 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 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 PTAA. 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 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

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August 8, 2019
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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 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.
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. The
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. 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. 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
Airport Layout Plan (ALP). The 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. 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 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.
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

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August 8, 2019
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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.
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. The
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. These 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. The 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. The 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. Therefore, 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. 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 2,104 parking spaces and 16,900 square feet of buildings,

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August 8, 2019
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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. The specific location of such SCM
within the development site is dictated by stormwater management design protocols as discussed
in the enclosed Stormwater Management Report. This 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. 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.
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. These potential temporary
impacts, if any, will be restored immediately following construction completion and removal of
temporary protection measures.
Wetland
Impact or for r Area
Site Temporary Impact Wetland Type NCWAM (acres)
1 P WD4 LOW 0.07
3 P Parking#1 WD2
T
Headwater
Forest
HIGH
0.01
0.02
Total: 0.10

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August 8, 2019
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Riparian Buffer Impacts
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
T SCM#3 Exempt SB
41
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.
• 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
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

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August 8, 2019
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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 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 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. The 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

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August 8, 2019
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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. The 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 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.
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 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.

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August 8, 2019
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There 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 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. 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 (NRHP) 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. The 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. The 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. The 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). The 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

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August 8, 2019
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Prevention Control and Countermeasures (SPCC) plan. Stormwater management specifications
include:
• Water quality treatment for the 1 -inch storm event;
• The 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.
The 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. This 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. The SCMs
will also provide appropriate flood control and discharge to existing wetlands at non-erosive
rates. The 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
Through the NEPA process, FAA has explored practicable Project alternatives and impact
minimization prior to addressing compensatory mitigation (sequencing). The 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.

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August 8, 2019
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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.
The 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.
The 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
kA�,' ►v
J. Alex Rosser, P.E.
Deputy Executive Director
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
https.-Aprojects.mbakercorp.com/PTIA/404/RentalCarApp. pdf

U.S. ARMY CORPS OF ENGINEERS
APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT
OMB APPROVAL NO. 0710-0003
EXPIRES: 28 FEBRUARY 2013
33 CFR 325. The proponent agency is CECW-CO-R.
Public reporting forthis collection of information is estimated to average 11 hours per response, including the time for reviewing instructions, searching
existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding
this burden estimate or any other aspect of the collection of information, including suggestions for reducing this burden, to Department of Defense,
Washington Headquarters, Executive Services and Communications Directorate, Information Management Division and tothe Office of Management and
Budget, Paperwork Reduction Project (0710-0003). Respondents should be aware that notwithstanding any other provision of law, no person shall be
subject to any penalty for failing to comply with a collection of information if it does not display a currently valid OMB control number. Please DO NOT
RETURN your farm to either of those addresses. Completed applications must be submitted to the District Engineer having jurisdiction over the location of
the proposed activity.
PRIVACY ACT STATEMENT
Authorities: Rivers and Harbors Act, Section 10, 33 USC 403; Clean Water Act, Section 404, 33 USC 1344; Marine Protection, Research, and Sanctuaries
Act, Section 103, 33 USC 1413; Regulatory Programs of the Corps of Engineers; Final Rule 33 CFR 320-332. Principal Purpose: Information provided on
this form will be used in evaluating the application for a permit. Routine Uses: This information may be shared with the Department of Justice and other
federal, state, and local government agencies, and the public and may be made available as part of a public notice as required by Federal law. Submission
of requested information is voluntary, however, if information is not provided the permit application cannot be evaluated nor can a permit be Issued. One set
of original drawings or good reproducible copies which show the location and character of the proposed activity must be attached to this application (see
sample drawings and/or instructions) and be submitted to the District Engineer having jurisdiction over the location of the proposed activity. An application
that is not completed in full will be returned.
(ITEMS 1 THRU 4 TO BE FILLED BY THE CORPS)
1. APPLICATION NO.
2. FIELD OFFICE CODE
3. DATE RECEIVED
4. DATE APPLICATION COMPLETE
(ITEMS BELOW TO BE FILLED BY APPLICANT)
5. APPLICANTS NAME
8. AUTHORIZED AGENT'S NAME AND TITLE (agent is not required)
First - J. Middle -Alex Last - Rosser
First - Richard Middle -B Last - Darling
Company - Piedmont Triad Airport Authority
Company- Michael Baker International
E-mail Address-rossera(a�gsoair.org
E-mail [e-mail]
6. APPLICANT'S ADDRESS:
9. AGENT'SADDRESS:
Address- 1000A Ted Johnson Parkway
Address- 200 Centreport Drive, Suite 350
City- Greensboro State- NC Zip- 27409 Country -USA
City- Greensboro State- NC Zip- 27409 Country -USA
7. APPLICANTS PHONE NOs. w/AREA CODE
10. AGENTS PHONE NOs. w/AREACODE
a. Residence b. Business c. Fax
a. Residence b. Business c. Fax
[phone] [phone]
[phone] [phone]
STATEMENT OF AUTHORIZATION
11. 1 hereby authorize, Richard Darling to act in my behalf as my agent in the processing of this application and to furnish, upon request,
supplemental information in support of this permit application. n
SI NATURE OF APPLICANT DATE
NAME, LOCATION, AND DESCRIPTION OF PROJECTOR ACTIVITY
12. PROJECT NAME OR TITLE (see instructions)
GSO Rental Car Facilities Relocation
13. NAME OF WATERBODY, IF KNOWN (if applicable)
14. PROJECT STREET ADDRESS (if applicable)
unnamed tributaries to Horsepen Creek
Address Inman Road
15. LOCATION OF PROJECT
City- Greensboro State- NC Zip -
Latitude: -N 36.120991 Longitude: -W -79.911210
16. OTHER LOCATION DESCRIPTIONS, IF KNOWN (see instructions)
State Tax Parcel ID 151274, 151275, 151291, 151296 Municipality Greensboro
Section - Township - Range -
ENG FORM 4345, OCT 2012 PREVIOUS EDITIONS ARE OBSOLETE. Page 1 of 3

17. DIRECTIONS TO THE SITE
The project area is located on the east side of Inman Road, approximately 0.4 mile south of its intersection with Fleming Road, in
Greensboro, Guilford County, North Carolina. Please refer to FAA EA and 404 Application Transmittal Letter for more detailed
information.
18. Nature of Activity (Description of project, include all features)
PTAA is obligated to remove obstructions to the visibility of Taxiway E from the ATCT as determined by FAA Comparative Safety
Analysis. The "Proposed Action" is to resolve this visibility obstruction and includes the following four key components:
1. Removal of Existing Rental Car Facilities and adjacent structures and re-grading to allow line-of-sight from the ATCT to Taxiway E;
2. Clean fill disposal at future aerospace development approved in 2001 and adjacent Worldwide Drive (Air Cargo site);
3. Construction of paved parking areas for the Proposed New Rental Car Facilities at Inman site; and
4. Clean fill disposal at Chimney Rock site.
Please refer to FAA EA and 404 Application Transmittal Letter for more detailed information.
19. Project Purpose (Describe the reason or purpose of the project, see instructions)
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 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.
Please refer to FAA EA and 404 Application Transmittal Letter for more detailed information.
USE BLOCKS 20-23 IF DREDGED AND/OR FILL MATERIAL IS TO BE DISCHARGED
20. Reason(s) for Discharge
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 separation of public versus rental car terminal access, and advanced site preparation of dedicated
aerospace tracts.
Please refer to FAA EA and 404 Application Transmittal Letter for more detailed information.
21. Type(s) of Material Being Discharged and the Amount of Each Type in Cubic Yards:
Type Type Type
Amount in Cubic Yards Amount in Cubic Yards Amount in Cubic Yards
300,000 c.y. clean fill at Air Cargo site 600,000 c.y. clean fill at Chimney Rock site
22. Surface Area in Acres of Wetlands or Other Waters Filled (see instructions)
Acres 0.14 ac. riparian wetlands, 1.72 ac. open water.
or
Linear Feet 68 l.f. perennial stream, 91.f. intermittent stream
23. Description of Avoidance, Minimization, and Compensation (see instructions)
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 is similarly restricted.
Please refer to FAA EA and 404 Application Transmittal Letter for more detailed information.
ENG FORM 4345, OCT 2012 Page 2 of 3

24. Is Any Portion of the Work Already Complete? E]Yes XNo IF YES, DESCRIBE THE COMPLETED WORK
25. Addresses of Adjoining Property Owners, Lessees, Etc., Whose Property Adjoins the Waterbody (If more than can be entered here, please attach a supplemental list)_
a. Address- Adjoining NCDOT Right -of -Way; OWNER: NCDOT; 1546 Mail Service Center
City - Raleigh State - NC Zip - 27699
b. Address- Parcel 151276 (PIN 7836154038) at 5725 Inman Rd. - OWNER: Chambers, Ronnie Talmage; 6823 Pepperdine Rd.
City - Greensboro State - NC Zip - 27410
c. Address- Parcel 151276 (PIN 7836148 867) at 5723 Inman Rd. - OWNER: BellSouth ; 1155 Peachtree St. NE, Room 16H02
City - Atlanta State - GA Zip - 30309
d. Address -
City - State - Zip -
e. Address -
City - State - Zip -
26. List of Other Certificates or Approvals/Denials received from other Federal, State, or Local Agencies for Work Described in This Application.
AGENCY TYPE APPROVAL" IDENTIFICATION DATE APPLIED DATE APPROVED DATE DENIED
NUMBER
FAA NEPA EAfFONSI 2019-07-12
NCDEQ 401 Certification
NCDEQ Buffer Allowance
" Would include but is not restricted to zoning, building, and flood plain permits
27. Application is hereby made for permit or permits to authorize the work described in this application. I certify that this information in this application is
complete and accurate. I further certify that I possess the authority to undertake the work described herein or am acting as the duly authorized agent of the
applicant.
C� J,&//1r----, 8181901 q 48/7/2019
I I A OF APPLICANT DATE SIGNATURE OF AGOnT DATE
The Application must be signed by the person who desires to undertake the proposed activity (applicant) or it may be signed by a duly
authorized agent if the statement in block 11 has been filled out and signed.
18 U.S.C. Section 1001 provides that: Whoever, in any manner within the jurisdiction of any department or agency of the United States
knowingly and willfully falsifies, conceals, or covers up any trick, scheme, or disguises a material fact or makes any false, fictitious or
fraudulent statements or representations or makes or uses any false writing or document knowing same to contain any false, fictitious or
fraudulent statements or entry, shall be fined not more than $10,000 or imprisoned not more than five years or both.
ENG FORM 4345, OCT 2012 Page 3 of 3

INTERNATIONAL Memorandum
TO: J. Alex Rosser, PE DATE: July 25, 2019
FROM: Richard Darling SUBJECT: GSO Rental Car Facilities Relocation
PROJECT ALTERNATIVES
The fundamental precept of the Clean Water Act (CWA) Section 404(b)(1) Guidelines is that discharges of dredged or fill
material into waters of the United States, including wetlands, should not occur unless it can be demonstrated that such
discharges, either individually or cumulatively, will not result in unacceptable adverse effects on the aquatic ecosystem.
The Guidelines specifically require that "no discharge of dredged or fill material shall be permitted if there is a
practicable alternative to the proposed discharge which would have less adverse impact on the aquatic ecosystem, so
long as the alternative does not have other significant adverse environmental consequences." Based on this provision,
the applicant is required in every case to evaluate opportunities for use of non -aquatic areas and other aquatic sites that
would result in less adverse impact on the aquatic ecosystem. A permit cannot be issued, therefore, in circumstances
where a less environmentally damaging practicable alternative for the proposed discharge exists.
Reasonable alternative locations and concepts to proposed project components are evaluated and summarized in the
following text. Alternatives to removing the existing rental car (RAC) facilities and locating new facilities are limited by
the project Purpose and Need. Locating appropriate sites to haul excess fill from both these sites are similarly limited by
distance, suitability, aviation safety, and economics. Environmental concerns apply additional limitations to alternatives,
but opportunities with significant efficiencies are also presented.
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 RAC 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.
Proposed New Rental Car Facilities
Site Requirements for the relocated RAC facilities are based on the existing characteristics — approximately 2,400 total
parking spaces required in four co -located sites within no more than three driving miles of the GSO Terminal. A review
of Guilford County GIS for adequately sized sites within suitable distance of the GSO Terminal revealed no available
parcels without potential similar or more severe impacts to aquatic resources. Potential sites not owned by PTAA would
require such significant additional time and effort to purchase, re -zone, and secure FAA approval as to be inconsistent
with the project need and purpose to resolve the line -of -site issue. Only two sites with potentially reasonable location
for RAC parking not owned by PTAA were identified in a GIS search of suitably sized and zoned parcels (Figure 1). Both
of these are located over 4 miles from the RAC pickup/drop-off and because they are neither owned by PTAA nor
considered in the ALP for RAC, they are not available to meet the project need and purpose.
Page 1 of 5

G50 Rental Car Facilities Relocation
Project Alternatives
The only other potential areas with adequate size for relocation of the RAC facilities include the proposed aerospace
development sites owned by Airport Authority. Each of these five tracts (Figure 2) appear adequately sized for the
combined RAC facilities but are strategically located with runway/taxiway frontage — significant for aerospace
development, but not necessary for airport RAC facilities. These sites would also involve additional driving distances to
the Terminal and potential RAC 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 RAC facilities. Development as RAC facilities would be an inefficient and
inappropriate use of these Airport properties and interfere with PTAA's aerospace development mission.
Memorandum Page 2 of 5 July 25, 2019

650 Rental Car Facilities Relocation
Project Alternatives
Figure Z Aerospace Development sites
Available
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Not depicted on Figure 2 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 RAC facilities or roadway due to its significance for future
aviation development. The Inman site (also not shown on Figure 2) is the only suitable location not obligated for
aerospace but with adequate size, orientation, and proximity, for RAC facility development.
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 RAC facilities. 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
Memorandum Page 3 of 5 July 25, 2019

G50 Rental Car Facilities Relocation
Project Alternatives
is consistent with the approved Airport Layout Plan (ALP). The Environmental Impact Statement / Record of Decision
(EIS/ROD) 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 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.
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 RAC 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 RAC 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.
Proposed Spoil Embankment
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. The Chimney Rock site is preferred due to the
minimization of haul distance and potential environmental impacts associated with driving heavy equipment and
vehicles.
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 Air Traffic Control Tower (ATCT), contrary to FAA requirements. The ability of all RAC
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 RAC 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 Airport's mission. If Worldwide Drive is
not connected, as planned, the RAC 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.
Memorandum Page 4 of July 25, 2019

650 Rental Car Facilities Relocation
Project Alternatives
Least Environmentally Damaging Practicable Alternative
Based on the considerable deliberation of potential impacts to environmental resources discussed the EA, the Airport
Sponsor is advancing the 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 impacts to the extent practicable. The Proposed
Action includes relocating all the existing RAC facilities from their current location to the Inman site and developing that
site with appropriate access.
Memorandum Page 5 of 5 July 25, 2019

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PIEDMONT TRIAD AIRPORT AUTHORITY INTERNATIONAL ermitDrawings August 7, 2019

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