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HomeMy WebLinkAbout20151065 Ver 1_Pre App Email_20140728Homewood, Sue From: Homewood, Sue Sent: Monday, July 28, 2014 2:58 PM To: Richard Darling (RDarling@mbakerintl.com) Cc: Bailey, David E SAW Subject: PTIA Taxiway Richard, As we discussed via phone recently, the Division of Water Resources defers to the USACE to determine LEDPA for any project subject to the Clean Water Act Section 404. The Division will provide comments to the USACE as they request them. Therefore we will not be providing any written comments at this time in response to the June 26, 2014 letter from PTAH. During our phone conversation you requested any general comments regarding the EA so that you may be prepared to submit a complete 404/401 application in the future. I offer the following comments for your future consideration: The level of detail necessary for a complete Secondary and Cumulative Impact Analysis will be dependent on the USACE's determination of the project limits/boundary. Therefore these comments are only generic in nature as some may be more relevant or less relevant depending on the project limits. The EA indicates a potential significant increase in employees at the Proposed Project, however it also indicates that it would not have a substantial effect on demand for local services or infrastructure. These statements do not seem to be in harmony with each other. The determination that the full Project will not have a substantial demand for public services may need to be provided in more detail. For example: details should be provided for utility and road access or improvements for the future Project. The EA states that water quality impacts from new impervious surfaces associated with the project can be treated via appropriate BMPs. At this time the Water Supply Watershed Management and Protection Rules in place for PTAA may not adequately address impervious surfaces and their impact to downstream water quality. Please let me know if you have any questions regarding my comments. Sue Homewood NC DENR Winston-Salem Regional Office Division of Water Resources — Water Quality Programs 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-4964 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.