20191081 Ver 1_Public Notice Comments to USACE_20190919

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
fnvironmenta/Quality
September 19, 2019
Corps Action ID# SAW -2017-00103
D W R# 20191081
Guilford County
David Bailey
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Subject Project: GSO Rental Car Facilities Relocation
Dear Mr. Bailey:
On behalf of the NC Division of Water Resources, we respectfully request that you consider the
following comments within your review of the 404 Individual Permit request for the above referenced
property:
1. The Applicant states that the "Proposed Action" is to resolve visibility obstruction issues as
determined by the FAA. The applicant indicates that there are four key components of the
project. The Division offers the following comments regarding the key components of the
Proposed Action:
a. The application states that one component of this project is "site preparation of
approximately 44 acres of approved [emphasis added] future aerospace development'.
The 404 and 401 approvals for the future aerospace development have expired and were
specific to the project proposed (FedEx) at that time. Any development of this location
should be reviewed as a "new" project and follow standard 404/401 permitting procedures
for purpose and need, alternatives analysis, and avoidance and minimization as part of this
application.
b. The Applicant indicates that grading will occur for construction and continuation of utilities
along the Proposed Worldwide Drive right-of-way. The 404 and 401 approvals for
Worldwide Drive have expired and were specific to the project proposed (FedEx) at that
time. Worldwide Drive should be reviewed as a "new" project and follow standard
North Carolina Department of Environmental Quality I Division of Water Resources
D_E �� 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 2 769 9-1617
919.707.9000

Corps Action ID# SAW -2017-00103
DWR# 20191081
Page 2 of 3
404/401 permitting procedures for purpose and need, alternatives analysis, and avoidance
and minimization as part of this application.
c. The application indicates that excess earth from the car rental facilities relocation project
must be moved to the nearest appropriate respective locations for project efficiencies and
cost savings. The Division proposes that excess earth disposal into jurisdictional waters is
not justified in order to meet the FAA visibility obstruction issues.
d. The applicant states that "The Proposed Action, including all components, must not
interfere with aviation or economic development specific to GSO". The Division questions
whether interference with economic development justifies a project purpose under Section
404 of the Clean Water Act.
2. The Division has concerns regarding the statement "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 associate environmental
impacts from repeated use of heavy equipment and vehicles". Specifically, the Division is
concerned regarding the use of the word "may" and whether the proposed aerospace
development is speculative in nature and that the applicant is relying on the cost reductions and
improved logistics for the car rental facility relocation to justify the future aerospace
development project rather than justifying the aerospace development project on its own merit.
If cost reduction and logistics are to be used as justification for these impacts the Division
recommends that specific data be provided to support the justification. The applicant states
that "avoiding development of this site now with simply be postponing a significant element of
PTAA's mission..". The Division requests that the USACE consider the temporal environmental
consequences that would be realized should impacts be approved for a "future" development
that "may" occur.
3. Further analysis of the Proposed Project and final determination of the project Purpose and
Need may warrant a further review of, or updates to, the Alternatives Analysis that has been
provided within the application.
4. The Division has concerns that there will be indirect hydrological impacts to Stream SB as a
result of the loss of drainage area/hydrology source and the proposed locations of the
stormwater control measure outlets.
5. The Division has concerns that there will be indirect hydrological impacts to the stream within
the Brush Creek Conservation Area that is downslope of the future aerospace development and
Worldwide Dr impacts as a result of loss of drainage area/hydrology source and the proposed
treatment of stormwater through previously constructed pond F-1.
6. The Division has requested additional technical information from the applicant (attached) and requests
that the USACE review and consider the applicant's response prior to issuing any authorizations for this
project.

Corps Action ID# SAW -2017-00103
DWR# 20191081
Page 3 of 3
Thank you for your considering the Division's comments during your review of this Individual Permit. If
you have any questions, please contact Sue Homewood at 336-776-9693 or
[e-mail].
Sincerely,
Mac Haupt, Acting Supervisor
401 & Buffer Permitting Unit
cc: Richard Darling, Michael Baker International (via email)
Olivia Munzer, NCWRC (via email)
DWR WSRO
DWR —Wetlands and Buffer Permitting Branch

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
September 19, 2019
DWR # 20191081
Guilford County
Piedmont Triad Airport Authority
Attn:J. Alex Rosser
1000A Ted Johnson Parkway
Greensboro NC 27409
Subject: REQUEST FOR ADDITIONAL INFORMATION
GSO Rental Car Facilities Relocation
Dear Mr. Rosser:
On August 14, 2019, the Division of Water Resources — Water Quality Programs (Division) received your
application dated July 12, 2019, requesting an Individual Water Quality Certification and Jordan Lake
Buffer Authorization from the Division for your project. The Division has determined that your
application is incomplete and cannot be processed. The application is on -hold until all of the following
information is received:
1. If the U.S. Army Corps of Engineers requests a response to any comments received as a result of
the Public Notice, please provide the Division with a copy of your response to the USACE. 115A
NCAC 02H .0502(c)].
2. Please provide detailed site plans at a scale of no smaller than 1"=50' with topographic contours
shown for the future aerospace development and Worldwide Dr. Please locate all wetlands,
streams, and riparian buffers as overlays on the site plan. These drawings must include clear
impact drawings and/or insets that include all permanent fill (fill slopes, road shoulders,
dissipator pads, etc.) and any temporary fill as hatching or color coded. [15A NCAC 02H
.0502(b)]
3. Please provide a detailed engineering plan, profile view, and cross-section of all proposed
culverts. These drawings must include details regarding stream alignment in relation to pipe
alignment, pipe slope, pipe burial, and dissipater pad. [15A NCAC 02H .0502(b)]
4. Please clarify whether the Division of Energy, Mineral and Land Resources will require riprap
within any stream channels or wetlands as part of the Erosion & Sedimentation Control Plan
North Carolina Department of Environmental Quality I Division of Water Resources
D_E 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 2 769 9 1617
o.��-' 919.707.9000

Piedmont Triad Airport Authority
D W R# 20191081
Request for Additional Information
Page 2 of 3
approval. If riprap is required, please enumerate and clearly label the temporary and
permanent impacts on the site plan and submit a channel restoration detail. Riprap must be
located below the stream bed elevation. [15A NCAC 02H .0506(f) and (g)]
5. All work must be done "in the dry", therefore, dewatering methods will be necessary to
temporarily dewater the stream channel during pipe installation. Please provide a construction
sequence that details the method of dewatering to be utilized for any proposed culvert
installation and the sequence of construction events to be followed to ensure compliance with
this requirement. In addition, please ensure that the location of the temporary impacts are
shown on the construction drawings and clearly indicated in the revised impact table. [15A
NCAC 02H .0502(b)(3)]
6. Pursuant to 15A NCAC 02H.0506(a) a 401 Water Quality Certification may only be issued upon
determining that existing uses are not removed or degraded by a discharge to classified surface
waters. The application notes that impervious surfaces from the future aerospace development
and Worldwide drive will be treated in Stormwater Pond F-1. Please note that the rerouting of
any drainage area and surface flow has the potential to remove existing hydrology from features
adjacent to this project and therefore remove existing uses of the stream channels or wetlands.
Please provide a detailed hydrologic analysis of indirect impacts to the stream immediately
below these impact areas.
Pursuant to 15A NCAC 02H.0506(a) a 401 Water Quality Certification may only be issued upon
determining that existing uses are not removed or degraded by a discharge to classified surface
waters. Based on the information provided in the application and associated documents, the
current drainage area of Stream SB within the New Rental Car Facilities is proposed to be
rerouted through multiple stormwater wet detention basins. Please note that the rerouting of
any drainage area and surface flow has the potential to remove existing hydrology from features
adjacent to this project and therefore remove existing uses of the stream channels or wetlands.
Please provide a detailed hydrologic analysis of indirect impacts to the stream immediately
below theis impact areas.
8. You have indicated that the future aerospace development and worldwide drive meet the
definition of "Airport Facilities" per 15A NCAC 02B .0267 and that the impacts are identified
within the Table of Uses as "Allowable with Mitigation". Please submit a buffer mitigation plan
detailing the amount of buffer impact for Zone 1 and/or Zone 2 and how the impact will be
mitigated. [15A NCAC 02B.0267]
9. The Division is currently reviewing the Stormwater Management Plan submitted for the New
Rental Car Facilities and will send comments regarding the review by separate document.
Pursuant to Title 15A NCAC 02H .0502(e) and 15A NCAC 02B [Neuse] .0267, the applicant shall furnish all
of the above requested information for the proper consideration of the application. Please respond in
writing within 30 calendar days of receipt of this letter by sending one (1) copy of all of the above

Piedmont Triad Airport Authority
DWR# 20191081
Request for Additional Information
Page 3 of 3
requested information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC
27699-1617 OR by submitting all of the above requested information through this
link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note the DWR# requested on
the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be returned. The return of this project will
necessitate reapplication to the Division for approval, including a complete application package and the
appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for this
activity and any work done within waters of the state may be a violation of North Carolina General
Statutes and Administrative Code.
Please contact Sue Homewood at 336-776-9693 or [e-mail] if you have any
questions or concerns.
Sincerely,
Mac Haupt, Acting S pervisor
401 & Buffer Permitting Branch
cc: Richard Darling, Michael Baker International (via email)
David Bailey, USACE Raleigh Regulatory Field Office (via email)
Olivia Munzer, NCWRC (via email)
Chonticha McDaniel, Stormwater Engineer, 401 & Buffer Permitting Branch (via email)
DWR WSRO 401 files
DWR 401 & Buffer Permitting Unit