This letter and attachments from the Federal EPA, Region IV, opposes the
expansion of Greensboro's Piedmont Triad International Airport. The
proposed action involves the addition of the Piedmont Triad Airport
Authority (PTAA) overnight express air cargo runway and associated
facilities, and would make PTIA a hub for Federal Express. The EPA states
that it does not believe that the DEIS fully describes the proposed air
cargo operations and the associated potential noise impacts, nor fully
addresses the mitigation of those impacts.
The EPA concludes that it has "environmental objections with the
all of the presented action alternatives for the FedEx hub, and
therefore prefers the No-Action Alternative (which proposes some airport
improvements but no cargo hub at PTIA)." The EPA requests additional
information in the Final Environmental Impact Statement (FEIS).
Regarding noise, EPA writes that it is "concerned that
the parallel runway proposal would not only increase overall airport
noise, but that new intrusive noise would be introduced almost daily due
to the proposed air cargo express flight operations during sensitive
late-night and early-morning time periods."
The document below is divided into two parts:
1) Comment Letter from Heinz J. Mueller
(EPA) to Donna Meyer (FAA) reviewing FAA and Piedmont Triad Airport
Authority's Draft Environmental Impact Statement (DEIS) in the context of
EPA's responsibilities under the National Environmental Policy Act (NEPA)
and the Clean Air Act (CAA).
2) Detailed Comments for FAA's consideration
and incorporation into the FEIS, including alternatives, EPA's preference,
noise, noise metrics, runway use percentages, air quality, ozone, ground
transportation emissions, wetlands and water quality, cumulative
impacts,and hazardous materials.
Comment Letter
United States Environmental Protection Agency
Region 4
Atlanta Federal Center
61 Forsyth Street
Atlanta, Georgia 30303-8960
June 19, 2000
4EAD-OEA
Ms. Donna M. Meyer
Department of Transportation
Federal Aviation Administration
1701 Columbia Avenue, Suite 2-260
College Park, Georgia 30337-2747
SUBJECT: EPA Review of FAA DEIS for "Proposed Runway 5L/23R, Proposed New Overnight Express Air Cargo Sorting and Distribution Facility, and Associated Developments;" Piedmont Triad International Airport; City of Greensboro, Guilford County, NC; CEQ No. 000101
Dear Ms. Meyer:
Pursuant to Section 102(2)(C) of the National Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act, the U.S. Environmental Protection Agency (EPA) has reviewed the subject Draft Environmental Impact Statement (DEIS) prepared by the Federal Aviation Administration (FAA). This DEIS concerns the expansion of the Piedmont Triad International Airport (PTIA) proposed by the Sponsor -- the Piedmont Triad Airport Authority (PTAA). Our comments are summarized in this letter and detailed in the appended Detailed Comments.
The proposed action involves the addition of the Sponsor’s overnight express air cargo runway and associated facilities, and would make PTIA a hub for Federal Express (i.e., FedEx Mid-Atlantic Hub). Initially, 48 daily express air cargo operations are proposed during a late-night and early-morning time frame, with additional runway capacity being available for future expansion. Because the PTIA site involves physical constraints, runway and taxiing bridges over roadways are proposed as well as relocation of homes and businesses. Environmentally, wetlands and floodplains would also be impacted.
Of the 42 action alternatives considered, the Sponsor identified five that satisfied its criteria (W2-A, W3-A, N-D, N-E and W1-A1). These were evaluated and carried forward throughout the DEIS. The No-Action Alternative was also evaluated in this way for comparison. The Sponsor selected Alternative W2-A as the proposed alternative, which may or may not also be FAA’s federal preferred alternative in the Final EIS (FEIS), or FAA’s selected alternative in the Record of Decision (ROD).
EPA has environmental objections with the Sponsor’s proposal (W2-A) as well as all of the other presented action alternatives for the FedEx hub. We therefore prefer the No-Action Alternative which proposes some airport improvements but no cargo hub at PTIA. Specifically, we base our environmental objections on the fact that we do not believe that the DEIS fully describes the proposed air cargo operations and the associated potential noise impacts, nor the mitigation of those impacts. We particularly disagree with runway alternatives oriented in a general north-south direction (technically a northwest-southeast direction) such as N–D and N-E. These runways are perpendicular to the existing runway layout and therefore seem to constitute a traffic controller, safety and efficiency problem. Environmentally, such alternatives would also expose flyover noise issues to a new set of people living near the airport that did not expect to be so directly impacted since the existing PTIA runways are oriented in a general east-west (technically, northeast-southwest) direction.
Given the physical constraints of the PTIA site and that several alternatives (including the Sponsor’s W2-A) would include runway and taxiing bridges (i.e., roadway tunnels), we recommend that the safety of the alternatives be identified and compared in the FEIS. The safety history of such runway bridges at existing or former airports should also be documented in the FEIS. In addition, the FEIS should discuss FAA’s regulations (and/or any other regulations) regarding Runway Safety Areas (RSAs) just beyond the end of runways and the Runway Protection Zones (RPZs) beyond the RSAs. Of interest are the compatible versus incompatible land uses that regulations would allow in these areas. Such land uses should then be related to the project proposed.
We understand that the FHWA North Carolina Division has determined that only general conformity and not transportation conformity would apply for the proposed PTIA project, which includes various transportation actions such as roadway relocations and runway bridges over roadways. We further understand that FHWA, as a cooperating agency to FAA for the present EIS, would likely adopt the FAA EIS for their NEPA roadway actions. Since roadway projects are associated with the PTIA proposal and since FHWA is a cooperating agency to FAA for the DEIS, the FEIS should substantiate the decision that transportation conformity does not apply for this proposed project. Transportation conformity criteria discussed in the appended Detailed Comments including funding, approval and inclusion in a conforming transportation plan, should be discussed and applied to the present project.
In regard to noise documentation, we believe that the DEIS does not provide a detailed description of the proposed air cargo facility and its potential impacts, particularly from a day-to-day operational point of view. The FEIS should disclose this operational information, such as when the FedEx air cargo flights would be arriving, how long are they on the ground, and when they depart. Specific time frames should be provided for each operation (e.g., in the year 2005, the 16.4 FedEx arrivals per Table 5.1.2-4 will take place between 11 pm and 1 am). Table 1.3-1 indicates that air cargo operations will only take place five days a week (52 weeks @5 days =260 days). The FEIS should identify which of the seven nights per week the FedEx operations will take place. Since there are already ongoing air cargo operations at the airport, the FEIS also needs to describe these operations in relationship to the proposed FedEx operations (operational information, etc.). The additional noise situation of noisy takeoff and landing events during the sensitive nighttime period of operation should also be better characterized. A metric more specific to this relatively short four-to-five hour time frame should be used for the analysis to supplement the averaged metrics (DNL and Leq(9) descriptors) used in the DEIS.
In regard to noise effects, EPA is concerned that the parallel runway proposal would not only increase overall airport noise, but that new intrusive noise would be introduced almost daily due to the proposed air cargo express flight operations during sensitive late-night and early-morning time periods. The DEIS proposes that all FedEx landings and takeoffs would come from and go toward the southwestern section, which would impact those scattered residences located there and avoid the more concentrated single family homes located in the northeastern section. As a FedEx hub, we believe the potential is great for operational expansion on the new parallel runway beyond the proposed 48 daily operations, which would then generate even more noise during this nighttime period. In addition, as capacity eventually grows at PTIA and use of the cargo runway for FedEx as well as other commercial airlines increases, we anticipate that the single family residences in the northeastern section of Greensboro (which are currently not forecasted in the DEIS to be located within the DNL 65 contour per Fig. 5.1.4-2 for W2-A), could receive greater noise impacts and ultimately be included in the DNL 65 dB contour.
EPA believes that noise mitigation was not adequately addressed in the DEIS. The proposed action does not include adequate non-operational (land use) noise mitigation that is needed to reduce/remove non-compatible residential land uses in the projected DNL ³65 dB contours. If the Sponsor’s Alternative W2-A is pursued at PTIA, additional land use and possible operational mitigation would be needed to relieve the aircraft noise impacts for all residents within these contours. Of particular concern are those residents in the southwestern section that would be impacted by the proposed night FedEx operations (arrivals on 5R/5L and departures on 23R/23L). Although page 6-9 provides a short discussion of possible non-operational noise mitigation measures that may be implemented, no FAA/PTIA commitment to mitigate is provided. We strongly recommend that these possible measures be implemented. There should be an aggressive residential acquisition program that might initially target all residents that would be impacted by the nighttime FedEx aircraft operations. Acoustical treatment (storm doors and windows and other insulation) should also be provided to residents within these contours that prefer not to be purchased. Also, noise impacts should be documented within the DNL 60 dB contour, since noise impacts do exist outside the DNL 65 dB contour.
It appears that the airport authority does not participate in FAA’s FAR Part 150 Noise Compatibility Program. Participation in the Part 150 program may be very useful in future years as it will allow the public to be involved in a formal noise mitigation process as aircraft operations increase in years beyond 2009. We strongly encourage the PTAA to participate in the Part 150 Program.
Although there may not be a project EJ impact, FAA should reconsider EJ effects after incorporation of the information requested in the Detailed Comments and a reassessment is made. While noise impacts at various levels can be expected for residents living near an airport, any selected FAA action alternative should minimize such noise impacts for the affected general public. Moreover, the EJ analysis should insure that affected minority and low-income populations in the area are not disproportionately impacted through alternative selection, runway orientation, flight paths, hours of operation and other operational and land use considerations. FAA mitigative methods such as residential purchases and sound-proofing treatments should consider all communities during the FAA Part 150 process of mitigating residents toward the DNL 65 dB contour (i.e., DNL 75, 70 and 65 dB contours). However, special attention should be given to EJ communities that may exist within the 65 dB contour (where mitigation is often incomplete) if, due to the overall health and societal conditions that may exist in the EJ community, noise impacts would have, or likely would have, a substantive cumulative effect on such conditions.
Page 5-210 states that "[c]oordination with the cities of Greensboro, high Point, and Winston-Salem as well as Guilford County indicate that there are no other known major planned developments in the PTIA area that need to be considered on a cumulative basis." However, it seems unrealistic that no substantive projects are planned within the foreseeable future for the greater Greensboro area. The FEIS should revisit this and further discuss potential federal or non-federal projects and their specific impacts (particularly those impacts similar to the proposed action) within a 10-15 year horizon.
EPA rates this DEIS as an "EO-2," i.e., we have Environmental Objections to the Sponsor’s proposal and request some additional information in the FEIS. We base this rating primarily on the fact we do not believe that the DEIS fully describes the proposed air cargo operations and the associated potential noise impacts, nor fully address the mitigation of those impacts.
We appreciate the opportunity to review the DEIS. Should you have questions regarding our comments, feel free to contact Chris Hoberg of my staff at 404/562-9619.
Sincerely,
Heinz J. Mueller, Chief
Office of Environmental Assessment
Environmental Accountability Division
Enclosure
We offer the following detailed comments on the DEIS for FAA’s consideration and incorporation into the FEIS:
Alternatives
Sponsor’s Preferred Alternative - At this early stage of the NEPA process, the action being proposed is the Sponsor’s (PTAA’s) proposed alternative, which may or may not also be FAA’s federal preferred alternative. PTAA has proposed Alternative W2-A. FAA’s preferred alternative will need to be identified in the FEIS and the FAA selected alternative will need to be identified in the Record of Decision (ROD).
We suggest that the Sponsor’s proposed Alternative W2-A be so-designated (i.e., as the Sponsor’s proposal) in tables comparing the various alternatives and also be identified earlier in the document as the Sponsor’s selection. In the Executive Summary, it does not become clear that W2-A is the Sponsor’s proposal until page S-11, even though this proposal was depicted earlier (Fig. S-1: pg. S-3) and compared to other considered alternatives (Fig. S-2 and Table S-1).
Based on Tables S-1 and S-2 comparing alternatives, the Sponsor’s Alternative W2-A is predicted to impact a relatively large amount of wetlands (32.3 ac), a relatively moderate number of floodplains (36.6 ac), relocate a relatively low number of homes (9) and businesses (10), conflict with an equal number of hazardous waste sites (6), impact the least number of people (531) by a significant +1.5 dB DNL increase in noise, and is the least expensive ($221.3M).
The Sponsor’s airport selection criteria listed on page S-5, which were apparently best satisfied by PTIA, include a "no unexpected or unresolvable environmental problems" criterion. The FEIS should further discuss this concept since the overnight hub operations would result in significant noise during late-night and early-morning hours. How do the Sponsor and Airport Authority plan to resolve the noise elevations for residents living within the DNL ³65 dB contours (or even outside the DNL 65 contour where noise impacts also exist)?
EPA’s Preference - EPA has environmental objections with the proposed project; specifically, we do not believe the DEIS fully describes the proposed air cargo operations and the associated potential noise impacts as well as the mitigation of those impacts. Consequently, EPA has environmental objections with the all of the presented action alternatives for the FedEx hub, and therefore prefers the No-Action Alternative (which proposes some airport improvements but no cargo hub at PTIA). We believe that the proposed addition of an overnight cargo operation, which introduces a new overnight noise, is substantively different from a general expansion of an airport for capacity, safety or other reasons. EPA further believes that in order for an overnight air express operation to be reasonable environmentally, it would need to be removed from areas of public development -- particularly residential communities -- where the airport is surrounded by compatible land use with minimal sensitive noise receptors. This does not appear to be the case at PTIA where single family residences exist in the area, in both the southwest (scattered) and northeast (concentrated) sections.
Although EPA prefers the No-Action Alternative, we offer the following comments on the five action alternatives further evaluated in the DEIS:
We note that RPZs were discussed on page S-11 and elsewhere in the alternatives discussion. Alternative W2-C was in part rejected since the proposed FedEx sorting/distribution center would be located in the RPZ of proposed Runway 5L/23R. We agree with FAA’s Advisory Circular 150/5300-13 concerning RPZs to the extent that it recommends "...that it is desirable that the RPZ remain clear of all objects." In fact, EPA believes the required compatible land use in this area should be a cleared RPZ with no or little human interaction.
Noise - In addition to the noise documentation, effects and mitigation comments provided in the main letter, we offer the following specific noise concerns:
Noise Metrics - Due to the unique operational characteristics of air cargo hub facilities, we believe that disclosure of additional operational/noise information is required. While the existing information on DNL (the accepted descriptor for airports) and 9-hour Leq (Leq(9)) is useful, it does not provide a totally accurate view of the additional noise situation, i.e., noisy takeoff and landing events occurring during a relatively short late-night and early-morning timeframe. DNL data are based on average daily operations, which are obtained from total annual operations (total operations divided by 365 days), while Leq(9) data are averaged over 9 hours. As previously noted, FedEx operations will only occur on 260 nights not 365 nights, and it is also highly unlikely that FedEx operations will occur over a 9-hour period (ref: supplemental 9-hour Leq data in Appendix B), but more realistically will be compressed into a four-to-five-hour period.. While the current information/data is correct for the average daily situation, it understates the noise exposure for an actual operational day since quieter time periods (i.e., times/days without FedEx flights, holidays, etc.) are also part of the annual (DNL) and 9-hour (Leq) average. Consequently, the actual noise impact during FedEx take-offs and landings would be significantly greater than data for the averaged metrics (DNL and Leq(9)) would suggest. EPA therefore requests that additional supplemental exposure information/data be provided to more realistically represent the projected situations.
We also note that while the SEL supplemental data (Appendix B) is very useful, an explanation of the metric does not appear until Appendix C. This section should highlight the fact that the SEL is 5-to-10 dB above the Maximum A-weighted sound level. In addition, Appendix C refers to ALm for Maximum A-weighted sound level, while page 5-4 in Volume 1 refers to Lmax. The FEIS discussion should be more consistent.
Air Cargo Operations - Air Cargo operations as well as other aircraft operations need to be clarified. For example, on page 1-5 (third paragraph), it states that the goal is to have two widely-spaced parallel runways to support 48 daily FedEx air cargo operations (24 departures and 24 landings) by 2005. Table 5.1.2-4 shows only 17.1 FedEx departures projected for 2005, although there are 9.6 other cargo operations projected to occur. The same is true for data contained in Table 5.1.2-5.
Runway Use Percentages - A review of runway use percentages (Table 4.2.5-3) for 1998 indicates that Runway 23 is used approximately 75% of the time for both arrivals and departures. This is also true for the 2005 and 2009 No-Action Alternative. In Table 5.1.2-7, it indicates that FedEx will use 23L/23R and 5R/5L for departures and arrivals. We believe that the FEIS should provide wind information with a discussion to support that FedEx can operate in this manner 95% of the time.
The FEIS needs to provide a discussion that clearly states that 95% of the night FedEx operations will take place to the southwest of the airport. This population would live under both the approaches to runways 23L/23R and the departures on runways 5R/5L and would therefore be exposed to the majority of FedEx aircraft operational noise. In order to reduce the noise exposure to the population that lives to the northeast, departures from runway 5L and arrivals on runway 23R have been restricted. While this may be the preferred operation (based on averages), there should be some discussion that actual operations may change due to directions by Air Traffic Control in response to local weather and requests by pilots. We also believe that as both FedEx and other commercial aircraft operations increase, that there will be increasing pressure to use Runway 5L for departures and 23R for arrivals. We recommend that the FEIS discuss/develop a process that the PTAA and FAA air traffic control will use to include the public into the decision process when future runway use increases beyond those stated in the DEIS (2.5% to 5%).
* Airport Land Use - It is clear that land use near airports should be zoned compatible with noise and air quality impacts associated with airports. Since a northern parallel runway is now being proposed (and was apparently included in the Master Plan Update for some time), it is unclear as to why single family residences were allowed to be constructed in areas such as the above-referenced northeastern section of the PTIA site. While we agree that the NEPA process was not completed at the time nearby residences were sold and that the Master Plan is a living document that can be modified, we suggest that the City of Greensboro carefully consider zoning potential impact areas accordingly and make realtors aware of potential or planned airport expansions in order to advise home buyers of potential land use conflicts.
* Mitigation - EPA believes that an aggressive federal buyout program is needed to compensate for noise impacts within the DNL 65+ contours. However, we recognize that complete residential buyouts within these contours is expensive and that current Congressional allocations may not suffice. We also recognize that worst-case contours should be mitigated first (DNL 75 and DNL 70 contours) followed by the DNL 65. The previously suggested participation by the airport authority (PTAA) in the FAA 150 Program could perhaps supplement such federal funding limitations and allow for more complete compensation. Present and other FAA EISs should also provide full disclosure of noise impacts within the affected contours outside of the DNL 65 contour, so that noise impacts will be documented regardless of the current funding limitations in noise mitigation.
* Editorial - We note that in Appendix B of Volume 2, the supplemental metric data refers to the 2005 and 2019 cases. We presume that the "2019" horizon year was intended to be "2009". The FEIS should clarify this. Appendix I (air quality) also refers to 2019 and even 2025 (see specific comments below). The FEIS should discuss if this is accurate and if so, the reliability of such long-termed projections.
Air Quality - We offer the following comments:
* General Comments
Conformity - We understand that the FHWA North Carolina Division has determined that only general conformity and not transportation conformity would apply for the proposed PTIA project, which includes various transportation actions such as roadway relocations and runway bridges over roadways. We further understand that FHWA, as a cooperating agency to FAA for the present EIS, would likely adopt the FAA EIS for their NEPA roadway actions.
Since roadway projects are associated with the PTIA proposal and since FHWA is a cooperating agency to FAA for the DEIS, the document should substantiate the decision that transportation conformity does not apply for this proposed project. Transportation conformity would apply if: 1) FHWA/FTA (Title 23) funds are used for the roadway project(s) and/or FHWA/FTA approval is required, or 2) the project sponsor is a routine recipient or federal funds and the project is regionally significant. The transportation conformity requirements would be satisfied if the roadway project(s) is included in the currently conforming transportation plan/TIP and has not changed significantly in design or scope.
Ozone - In order to give a more accurate assessment of the current state of air quality in Guilford County, the FEIS should note that the county will likely be designated nonattainment under the eight-hour ozone standard (e.g., pg. 4-61).
Ground Transportation Emissions - The details of the analysis for ground transportation emissions (e.g., MOBILE input files, VMT, speeds) are not contained in the DEIS. These should be contained in Appendix I.
* Specific Comments
Pg. 4-61 (First Full Paragraph, Line 5) - The phrase "Nonattainment areas are further classified as extreme..." should read "Ozone nonattainment areas are further classified as extreme..."
Pg. 4-61 (Second Paragraph of Section 4.3.6-2) - CO2 should be added to the list of exhaust gas emissions from aircraft engines. It is a major aircraft exhaust gas and a greenhouse gas.
Pg. 4-62 - The term budget is used several times where it should read inventory.
Pg. 5-74 (Section 5.5.2.4, Line 4) - "Off the airport, the emissions inventory includes all motor vehicles traveling to, from and around the airport on..." The emissions impacts of off-airport motor vehicles should include the emissions over the entire trip to/from the airport from/to the trip origin/destination, not just in the vicinity of the airport. This can be estimated by using the Piedmont Triad Regional travel demand model. This requirement is satisfied if the proposed airport and runway improvements and the associated effects on trip-making in the region are included in the currently conforming transportation plan/TIP.
Pg. 5-77( Last Bullet of Section 5.5.4) - "The vast majority (74 percent) of emissions associated with PTIA continue to be in the form of CO, followed by NOx (18 percent) and VOCs (7 percent)." This comparison is not relevant.
Pg. 5-185 (First Paragraph of Section 5.19.3.1, Line 4 From Bottom) - Refer to the sentence "Turbidity is considered a short-term impact because the elevated suspended solids creating turbid conditions tend to dissipate soon after the land disturbance commences." The last word of this sentence should read "concludes" or "ends", not "commences." This also occurs in other areas of the text.
Pg. 6-10 - In addition to infrastructure that helps reduce emissions by reducing the probability of on-site congestion and idling, the possible mitigation measures should include strategies to reduce single-occupancy vehicle travel, increase high-occupancy vehicle travel, and encourage transit ridership to/from the airport (if transit is available).
Pg. 6-11 - During the construction phases, a possible mitigation measure would be to give special consideration to contractors that use equipment that produce lower emissions through diesel retrofit or other technologies.
Appendix I, pg. 2-2 - What is the basis for directing mixed use growth around various nodes throughout the Triad from years 2006 through 2025 for purposes of transportation modeling? Is this growth strategy enforceable or merely an aspiration?
Appendix I, pg. 2-2 - The FEIS should contain the updated traffic forecast for the No-Action Alternative, including the new interchanges at Bryan Blvd. and Old Oak Ridge Rd. and the relocation of Regional Rd. Furthermore, the report should make it clear that the No-Action ground transportation improvements have been included in the area's approved transportation plan (and TIP, if applicable). This is implied in Appendix I, p. 2-5, but does not appear to be explicitly stated.
Appendix I, pg. 2-3 - The discrepancies between build-out employment numbers among the alternatives should be resolved and a consistent set of numbers should be used for the FEIS analysis.
Appendix I, pg. 2-3 - The FEIS should explain how the 2019 traffic projections were adjusted upward using the 2025 projections with the projected air cargo facility employment.
Appendix I, pg. 2-3 - The FEIS should explain why it is expected that interpolating between the 2019 adjusted traffic projections and the 1994 base year traffic to project horizon year 2005 traffic would provide a more accurate prediction? More accurate than what?
Appendix I, pg. 5-13 (Section 5.5.7, Line 3) - It is not necessarily true that "any provisions for or enhancements to roadway or intersection projects that permit free-flow and high-speed travel would have corresponding benefits to air quality." The MOBILE5 emission factors for NOx and VOCs have minima in the intermediate speed ranges and increase at higher speeds. For example: Strategies that reduce vehicle-miles traveled, combine trip-making, encourage carpooling and encourage the use of alternative modes of transportation, do reduce emissions and should be considered as possible mitigation measures.
Wetlands and Water Quality - For the evaluated action alternatives, wetland losses are predicted to range from 27.3 to 36.8 acres. The No-Action Alternative preferred by EPA is predicted to impact approximately two-thirds less acreage (9.8 ac).
Wetland impacts and acreages are discussed in Table 5.11.2-1. Stream relocations are also quantified in linear feet and ponds in acres. However, total wetland acreages do not include stream relocation impacts (although pond acreages were included). Total wetland acreages should reflect all three categories (floodplain wetlands, streams and ponds), since waterways are also considered wetlands. The FEIS should show both dissected (individual) and lumped (total) values for these wetland categories and report totals (or individuals and totals) in summary tables such as Table S-2.
The quality of the wetlands directly and indirectly impacted should be better documented. For example, terms such as Floodplain Swamp used in Table 5.11.2-1 should be qualified (perhaps in a footnote or in the text or appendix) to better determine quality and vegetation type (forested, emergent, herbaceous, etc.). Based on the State’s (Division of Water Quality) assigned 90 rating for several of the wetlands discussed on the site, we assume that the wetland quality is generally good and that the wetlands are functional. The specific functions of the wetlands (water quality, habitat, ground-water recharge, etc.) should be provided in the FEIS.
Any unavoidable direct and secondary wetland impacts should be fully mitigated through coordination with the U.S. Army Corps of Engineers (COE) and other agencies.
Mitigative approaches for wetland restoration, enhancement, creation, banking and/or acquisition should be discussed. We note (pg. 5-141) that consultation with the COE and the State of North Carolina has been initiated. EPA and the U.S. Fish and Wildlife Service (FWS) should also be included in such consultation. Mitigative methods should result in the maintenance of existing wetland functions to the extent feasible.
Although possible mitigative measures for wetland, floodplain and other losses were discussed in the DEIS, no FAA commitment to ultimately mitigate was offered in the DEIS. Since coordination with the COE and State are ongoing, inclusion of final mitigation plans is presumably premature. If so, a commitment for FAA to provide all reasonable mitigation measures requested by the resource agencies should nevertheless have been included in the DEIS. If a final mitigation plan is not completed and included in the FEIS, a draft final plan should be included along with an FAA commitment to mitigate predicted wetland losses/impacts.
Hazardous Materials - Table S-1 relates that all action alternatives are predicted to conflict with six potentially hazardous material sites. However, review of Section 5.20 suggests that although old UST sites exist, other sites may only be suspected sites of contamination. Coordination with EPA Region 4 and/or the State should nevertheless be pursued to determine appropriate action. These sites should either be avoided, suitably cleaned up, or suitably capped to allow unrestricted or designated use of the area.
Environmental Justice (EJ) - Alternative screening Table S-2 indicates that no EJ impacts exist for any of the action alternatives or the No-Action Alternative. Because of this conclusion, Page 5-55 relates that no mitigation measures were offered. In addition to our comments in the main letter, we offer the following:
In regard to the EJ analysis in the DEIS, we appreciate that demographic data were provided in Chapter 4 on Table 4.2.2-9. From this table, we note that Guilford County has a slightly elevated but still comparable percentage of African-Americans (26.4%) compared to the State of North Carolina (22.0%). However, no site-specific demographic U.S. Census data were noticed, i.e., demographic percentages for the specific Census Block Group and its possible Sub-Group(s) containing the project site. The FEIS should provide such information for all minorities. This would help insure that no "pockets"of minority concentrations are located at the PTIA site that might be affected but were not obvious from the County average. Sub-Group percentages should then be compared to the minority percentages for Block Groups, Guilford County, and the State to determine if percentages are similar or if concentrations of minorities exist at PTIA and that there is potential for disproportionate impacts to minorities.
Consistent with Executive Order 12898, another component of EJ are low-income populations. As in the case for minorities, the percentage of low-income populations of the site should be compared to percentages of nearby areas using Census data for area designations such as Block Groups, etc. Table 4.2.2-11 provides low-income group data for populations in poverty and families in poverty for the U.S., State, Guilford County, and the study area. Based on the percentages provided, we note that the study area has less poverty than the State or the U.S., which suggests that there probably is no EJ impact for low-income populations. However, not all of the data are readily comparable since some are presented as percentages and others as actual numbers (i.e., the FEIS should provide a low-income percentage for Guilford County). In addition, the term study area is not defined in the table so that it is unclear if a conventional U.S. Census Block Group or Sub-Block Group was used or another area designation (e.g., a five-mile radius around the airport) was used. The FEIS should document and discuss, with an EJ impact reassessment being provided.
If the site area contains a significantly greater percentage for minorities and/or low-income populations than the surrounding area (Block Group and County) and the proposed project has significant impacts (e.g., noise), then a potential EJ impact may exist for affected populations. The FEIS should assess this. It should be noted that additional EJ assessment techniques are available through EPA.
In the event an EJ impact does exist, the FEIS should discuss for which alternatives it exists and prospective mitigation. Mitigation might include selection of the No-Action Alternative or another existing or new action alternative that would not have an EJ impact, federal buyouts of impacted residents or sound-proofing of residences in the impacted area, modification of airport operations such as flight patterns, etc. In addition, affected minorities and/or low-income populations should be informed of all public meetings/hearings, project impacts, and project modifications before and during proposed project construction and operation.
Cumulative Impacts - We appreciate that at least two projects were referenced regarding cumulative impacts (pg. 5-210). These were the completed FAA Categorical Exclusion (CE) regarding Runway 14 Safety Area and the Western Greensboro Urban Loop highway project. Although descriptive, these summaries did not provide environmental impact information that may be cumulative to the proposed action such as noise, water quality and wetland impacts. The FEIS should discuss. Page 5-210 also states that "[c]oordination with the cities of Greensboro, high Point, and Winston-Salem as well as Guilford County indicate that there are no other known major planned developments in the PTIA area that need to be considered on a cumulative basis." However, it seems unrealistic that no substantive projects are planned within the foreseeable future for the greater Greensboro area (why then is the airport being expanded?). The FEIS should revisit this and further discuss potential federal or non-federal projects and their specific impacts (particularly those impacts similar to the proposed action) within a 10-15 year horizon.