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<br />According to correspondence received from the Texas Natural Resource Conservation <br />Commission (TNRCC), Caldwell and Hayes Counties are in attainment for six criteria <br />air pollutants as designated by EPA pursuant to Section 107 of the Clean Air Act, <br />therefore "General Conformity does not apply". <br /> <br />Also, the proposed development plan would result in short -term air emissions <br />resulting from the actual construction activities, although these actions pose no <br />significant impact upon air quality standards. During construction of proposed <br />development items, steps should be taken to minimize the amount of particulate <br />matter (dust) generated, including incidental emissions caused by strong winds, as well <br />as tracking of dirt off the construction sites by machinery and trucks. Permits may be <br />required for ancillary construction facilities such as concrete or asphalt batch plants <br />involved in the improvement projects. <br /> <br />WATER QUALITY <br /> <br />Airport activities can have a major impact on water quality. The Clean Water Act <br />provides the authority to establish water quality standards, control discharges into <br />surface and subsurface waters, develop waste management treatment plans, and issue <br />permits for discharges and for dredged or fill materials. <br /> <br />Construction of the proposed improvements will result in an increase in impermeable <br />surfaces and a resulting increase in surface runoff from both landside and airside <br />facilities. The proposed development might result in short-term impacts on water <br />quality, particularly suspended sediments, during and shortly after precipitation <br />events during the construction phase. <br /> <br />Recommendations established in FAA Advisory Circular 150/5370-10 Standards for <br />Specifying Construction of Airports, Item P-156, Temporary Air and Water Pollution, <br />Soil Erosion and Siltation Control should be incorporated in project design <br />specifications to mitigate potential impacts. These standards include temporary <br />measures to control water pollution, soil erosion, and siltation through the use of fiber <br />mats, gravel, mulches, slope drains, and other erosion control methods. <br /> <br />In accordance with Section 402(p) of the Clean Water Act, a National Pollution <br />Discharge Elimination System (NPDES) General Permit is required from the <br />Environmental Protection Agency. NPDES requirements apply to industrial facilities, <br />including airports and all construction projects that disturb five or more acres ofland. <br /> <br />With regard to construction activities, the City of San Marcos and all applicable <br />contractors will need to comply with the requirements and procedures of the NPDES <br />General Permit, including the preparation of a Notice of Intent and a Stormwater <br />Pollution Prevention Plan, prior to the initiation of project construction activities. <br /> <br />A-7 <br />