Notice of Record of Decision on the Realignment of Naval Air Station (NAS) Miramar, San Diego, California

DEPARTMENT OF DEFENSE

Department of the Navy

Notice of Record of Decision on the Realignment of Naval Air

Station (NAS) Miramar, San Diego, California

SUMMARY: The Department of the Navy has decided to realign NAS Miramar

into Marine Corps Air Station (MCAS) Miramar. This decision is made

upon careful consideration of all comments on the Environmental Impact

Statement (EIS) prepared for the realignment action. After review of

the administrative record and information received during the

environmental review process, the Department of the Navy has determined

that no new significant environmental information or circumstances

exist. Consequently, the Department of the Navy has determined that a

supplemental EIS is not warranted. It has been decided to implement the

realignment action using the West-Ramp configuration (Alternative B),

which was both the preferred alternative and also the environmentally

preferred alternative.

DATES: This ROD becomes effective December 2, 1996.

FOR FURTHER INFORMATION CONTACT: Additional information regarding this

ROD or the Miramar realignment action may be obtained from Lieutenant

Colonel George Martin at (619) 537-6679.

SUPPLEMENTARY INFORMATION: The text of the entire ROD is provided as

follows:

Table of Contents

1. Introduction

2. Proposed Action

3. Purpose & Need

4. Background

5. Alternatives

6. Implementation

a. Aviation

b. Construction

c. Establishment of Landing Sites in East Miramar

7. Impacts & Mitigation

a. Residual Significant Impacts

i. Noise

ii. Biology

iii. Community Services and Utilities (Schools)

b. Mitigated Below A Level Of Significance

i. Geology and Soils

ii. Water Quality

iii. Biology

iv. Traffic

v. Community Services and Utilities (Potable Water)

c. Not Significant

i. Air Quality

ii. Hydrology

iii. Cultural

iv. Visual Resources

v. Land Use

vi. Public Health and Safety

vii. Hazardous Material and Wastes

viii. Aircraft Operations

ix. Socioeconomics

8. Conclusions

9. Further Information

1. Introduction

The Department of the Navy (DoN) has been studying a proposal to

realign Marine Corps Aviation assets from MCAS El Toro and MCAS Tustin

to other locations in Southern California. The realignment would

include Marine Corps aircraft, their dedicated personnel, equipment and

support. The realignment would be undertaken in accordance with the

Defense Base Closure and Realignment Act (BRAC) of 1990 (Pub. L. 101-

510). The DoN has conducted extensive analysis of the proposal under

Section 102(2) of the National Environmental Policy Act (NEPA) of 1969

and the Council on Environmental Quality (CEQ) regulations implementing

NEPA procedures (40 C.F.R. 1500-1508). The process used for the

analysis sought the views of the public and those Federal, State and

local agencies with special expertise. As a result of extensive

interest shown by the public, the process was extended to provide the

public with additional information and an additional opportunity to

comment. Their comments have been carefully considered and have helped

identify and resolve a number of issues and to sharpen the analysis. A

number of the most important issues, and the manner in which they have

been resolved, are set out in this Record of Decision. Having reviewed

the Final Environmental Impact Statement, the Supplemental Information

Report, and all the comments and the administrative record in this

matter, the Department of the Navy (DoN) announces its decision to

proceed with the realignment of NAS Miramar to MCAS Miramar.

2. Proposed Action

In compliance with the approved recommendations of the 1993 and

1995 Defense Base Closure Commissions, the proposed action is the

relocation of Marine Corps aircraft, along with their dedicated

personnel, equipment and support, from MCAS El Toro and MCAS Tustin to

NAS Miramar and the conversion of NAS Miramar to MCAS Miramar. The

relocation of aircraft and conversion from a Navy to Marine Corps Air

Station involves: Replacement of Navy fixed-wing aircraft (including

associated maintenance and support functions) designated for

realignment to other Naval Air Stations with U.S. Marine Corps fixed-

wing aircraft (including maintenance and support functions); the

addition of rotary-wing (helicopter) aviation squadrons (including

maintenance and support functions); construction of facilities to meet

the requirements of the Marine Corps; use and modification of existing

fixed-wing flight corridors; designation of new rotary-wing flight

corridors, an increase in fixed-wing missions that involve carrying

air-to-ground ordnance for use at training ranges; establishment of

Confined Area Landing (CAL)/ Mountainous Area Landing (MAL) sites; and

adoption of Marine Corps flight procedures. Upon full implementation of

the proposed action, MCAS Miramar will support approximately 256

aircraft (eight rotary-wing squadrons and nine fixed-wing squadrons),

and approximately 11,000 personnel.

3. Purpose and Need

The purpose and need of the proposed action is to comply with the

1993 and 1995 BRAC Commissions' recommendations for the closure of MCAS

El Toro and MCAS Tustin and relocation of MCAS El Toro and MCAS

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Tustin aircraft, along with their dedicated personnel, equipment, and

support, in a manner that supports the Marine Corps force structure.

4. Background

This action was initiated following Congress' approval of the 1993

recommendations of the Defense Base Closure and Realignment Commission

established under the Defense Base Closure and Realignment Act of 1990,

Public Law 101-510. Pursuant to that law, recommendations of the

Commission become final if the President sends them to Congress and

Congress does not reject them within 45 legislative days. Once

recommendations become final, 10 U.S.C. 2904 requires that the closures

and relocations must be implemented within six years. The 1993

recommendations included the closure of MCAS El Toro and direction to

``Relocate its aircraft along with their dedicated personnel, equipment

and support to other naval air stations, primarily, Naval Air Station

(NAS) Miramar, California, and MCAS Camp Pendleton, California.''

Included in the same Commission action was a change to the 1991 BRAC

Commission's recommendations for MCAS Tustin, which had named Marine

Corps Air Ground Combat Center (MCAGCC) Twentynine Palms as one of the

receiving sites for helicopter assets being realigned from MCAS Tustin.

The BRAC 93 Commission deleted MCAGCC as a receiving site and directed

relocation to ``NAS North Island, NAS Miramar, or MCAS Camp Pendleton,

California.'' In BRAC 95, the Commission again altered the receiving

site for assets realigned from MCAS Tustin by striking the three

potential sites listed in BRAC 93 and substituting ``other air stations

consistent with operational requirements.''

The proposed action is one of several steps to implement the BRAC

recommendations. In January 1994, the Marine Corps prepared an

Environmental Assessment (EA) for the temporary relocation of eight

MCAS El Toro tactical F/A-18 squadrons and certain support elements to

Miramar, replacing 12 squadrons of Navy F-14s. The EA concluded that

the temporary relocation of the F/A-18s, operating within existing NAS

Miramar flight procedures, would have no significant impact on the

environment. A Finding of No Significant Impact (FONSI) was made in

July 1994. The temporary relocation that was evaluated by the EA has

since been completed. In another interim move subsequent to the BRAC 95

decision, and unrelated to the selection of permanent relocation sites,

all of MCAS Tustin's CH-46Es (medium lift helicopters) were temporarily

relocated to MCAS El Toro in order to facilitate placing a significant

portion of MCAS Tustin in caretaker status. The relocation of four of

these medium lift helicopter squadrons to MCAS Camp Pendleton is the

subject of a separate EIS.

The analysis undertaken for relocation of assets and conversion of

NAS Miramar to MCAS Miramar in the Draft Environmental Impact Statement

(DEIS) and the Final Environmental Impact Statement (FEIS) assumed that

as many as eleven fixed-wing and ten rotary-wing squadrons would be

assigned to Miramar (The Supplemental Information Report (SIR),

discussed below, contained a typographical error that stated the DEIS

and FEIS evaluated the relocation of nine vice ten rotary-wing

squadrons to Miramar). The Marine Corps, through force structure

decisions, has decommissioned one fixed-wing (F/A-18) squadron

previously assigned to MCAS El Toro and transferred another fixed-wing

(F/A-18) squadron to MCAS Iwakuni, Japan. In separate actions to

implement the overall direction of BRAC and meet force structure

requirements, one MCAS Tustin rotary-wing squadron has been relocated

to MCAS New River, and another rotary-wing squadron has been relocated

to Marine Corps Base (MCB), Hawaii. Thus, realignment will actually

include only nine fixed-wing and eight rotary-wing squadrons.

Consequently, much of the EIS analysis overstates the projected impacts

for this action. Further clarification on the overstatement of impacts

was provided in a Supplemental Information Report (SIR).

Although neither addressed by NEPA, nor directed by CEQ

Regulations, the Department of the Navy determined that the use of a

Supplemental Information Report to address comments on the FEIS would

serve as a vehicle for a more thorough discussion of matters over which

there remained public concern. The SIR and the public comment it

generated would also provide the final decision maker with a more

detailed analysis for consideration in coming to a decision, thereby

furthering the purposes of NEPA. The SIR was published on September 6,

1996, with a 30 day public comment period.

The Department of the Navy received and has considered 277 letters

from the interested public during the comment period on the FEIS. It

also received and has considered 825 letters from the interested public

during the comment period on the SIR. While the SIR substantially

addressed comments received on the FEIS, some of the primary issues are

re-addressed in this Record of Decision.

5. Alternatives

NEPA and the CEQ regulations require the Department of the Navy to

study and evaluate a reasonable range of alternatives for accomplishing

the purpose and need underlying the proposed action. Because the

underlying purpose and need of the realignment of assets from MCAS El

Toro and MCAS Tustin is to satisfy BRAC mandates designed to reduce

infrastructure, costs, and personnel requirements, alternative sites

that did not contribute to such reductions did not fall within the

range of reasonable alternatives and did not warrant detailed,

comparative analysis. For alternatives that were initially identified

but subsequently eliminated from detailed study, regulations require

the Department of the Navy only to discuss briefly the reasons for

their having been eliminated.

Potential receiving sites for the assets to be realigned from MCAS

El Toro and MCAS Tustin were screened on the basis of several criteria:

(1) Realignment recommendations approved by the President and accepted

by Congress in BRAC 93 and 95; (2) operational requirements; (3)

infrastructure required to support the realigned assets; and, (4)

personnel requirements.

To achieve the economies that were basic to BRAC, Marine Corps

force structure relies on the location of installations to form

interdependent, mutually supporting regional complexes on the East

Coast, West Coast, and in the Pacific. In order to meet operational and

mission requirements, the selected receiving site(s) should be in close

proximity to the established regional complex. MCAS El Toro and MCAS

Tustin are located within the West Coast regional complex. Receiving

sites for the realigned assets therefore need to lie within the West

Coast region. The Marine Corps regional complex on the West Coast is

centered around MCB Camp Pendleton, CA.

Five possible locations were identified within the West Coast

region: MCAS Camp Pendleton, NAS North Island, NAS Miramar, Naval Air

Facility (NAF) El Centro, and March Air Reserve Base (March ARB). These

five sites were then evaluated based upon operational requirements

(including the ability to conduct aircraft carrier landing practice and

access to high performance air combat maneuvering airspace),

infrastructure (including identification of requirements for runways,

hangars, and maintenance and support facilities,

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as well as the cost of modernizing or building those facilities), and

personnel requirements (including Congressional limitations on end-

strength).

All locations except NAS Miramar were determined to be unreasonable

and were eliminated from the range of alternatives that would be

subjected to detailed study and analysis so that the analysis in the

EIS could be focused upon reasonable alternatives. The FEIS discussed

why the Department of the Navy determined that locations other than NAS

Miramar could not reasonably achieve the purpose and need for the

proposal. Further clarifying information on the criteria used to

evaluate feasibility and the basis for eliminating alternatives from

detailed discussion were provided in the SIR. An independent Department

of Defense review also confirmed that locations other than NAS Miramar

(specifically March ARB) could not reasonably achieve the purpose and

need for the proposal.

The FEIS identified Miramar as the preferred location for the

fixed-wing aircraft realigned from MCAS El Toro and most of the rotary-

wing aircraft realigned from MCAS Tustin. Three alternative site

configurations at MCAS Miramar (East Ramp (A), West Ramp (B), and East

Ramp II (C)) were analyzed in detail. A no-action alternative, which

would not realign aircraft from MCAS El Toro and MCAS Tustin and

thereby prohibit closure, was not evaluated in the EIS because BRAC

exempts from consideration under NEPA the need for closing a military

installation and the need for realigning functions from closing

installations to other receiving installations.

Some comments asserted that a no-action alternative should have

been used to establish baselines for the proposed action. The suggested

no-action alternative would consist of operating NAS Miramar at the

reduced levels it has operated while the Navy realigns assets

elsewhere. This no-action alternative would ignore the reasons for the

reduced Navy operations. The Department of the Navy did develop and use

a no-action alternative for NAS Miramar. Because the BRAC

recommendations relocated Navy aircraft from NAS Miramar to make way

for realigned Marine Corps aircraft, the no-action alternative

considered the environmental impacts associated with operating NAS

Miramar as if no Marine Corps aircraft were realigned there and it

continued to operate entirely with Navy aircraft, using Navy procedures

and operating at its historical usage levels. This no-action

alternative was used as the basis against which to measure the impacts

of the proposed action.

A number of comments addressed the Department of the Navy's

screening of potential sites other than NAS Miramar that might receive

assets relocating from MCAS Tustin and MCAS El Toro, asserting that

alternative locations should have been examined in depth. Most of these

comments focused on the relocation of Marine Corps rotary-wing aircraft

and recommended that the Department of the Navy relocate these aircraft

to March ARB. Some of these comments referred to a December 12, 1994

study from the Commander, Marine Corps Air Bases Western Area

(COMCABWEST). That study suggested that relocating the helicopters to

March ARB would be cheaper than jointly relocating fixed-wing and

rotary-wing aircraft to Miramar,

In response to these public comments, I carefully reviewed the

selection and screening of feasible sites for the relocation of Marine

Corps fixed-wing and especially rotary-wing aircraft. In particular, I

reviewed the 1994 COMCABWEST cost study that was cited in several of

the comments. I concluded that the 1994 COMCABWEST study was limited in

scope, failed to include costs in both dollars and personnel that would

be required to run an additional Marine Corps Air Station, and was

based on assumptions that are now invalid due to closure and

realignment decisions resulting from BRAC 95. The COMCABWEST study

assumed that the majority of facilities at March ARB would be available

to the Marine Corps. In fact, most facilities are not available to the

Marine Corps and significant new construction, in particular hangars

and pavement, would be required. It also assumed that the Navy would

remain at Miramar, however, in accordance with BRAC, most Navy units

have already relocated to various other sites. Finally, it assumed that

the Marine Corps would be operating at March ARB as a tenant unit, not

a host command. However, Air Force officials have stated that reserve

forces cannot host large numbers of active duty forces and the active

force would have to take control of the base with the reserve unit

becoming a tenant.

In response to the public concern expressed about the extent of the

alternatives analysis in the FEIS, the Deputy Secretary of Defense

undertook an independent review of the resource implications of

relocating Marine Corps helicopters. I have carefully studied that

independent review, which concluded that the proposed relocation of

fixed- and rotary-wing aircraft to Naval Air Station Miramar is

significantly more cost effective than relocating rotary-wing aircraft

to March ARB. This independent review established that the non-

recurring Department of Defense construction costs for relocating

Marine Corps rotary-wing assets to March ARB exceed the costs of the

proposed collocation at Miramar of the rotary-wing and fixed-wing by

approximately $250 million. After proponents of moving to March ARB

questioned some portions of the analysis, additional review determined

that the Marine Corps could avoid an estimated $3 million annually in

housing and subsistence allowances by moving the realigning rotary-wing

squadrons to March ARB. The findings of the original OSD review,

however, remain sound and the cost avoidance associated with housing

and subsistence allowances did not alter the conclusion that annual

recurring costs associated with the March ARB scenario are

significantly higher than the recurring costs of collocating the

rotary-wing squadrons with the fixed-wing squadrons at Miramar. As

demonstrated in the SIR, comparing the costs of constructing the

infrastructure and operating March ARB with Marine Corps rotary-wing

aircraft over 20 years shows that it would cost between approximately

$430 and $870 million more than if the rotary-wing assets are

collocated with the fixed-wing squadrons at Miramar. The SIR also

indicates that the relocation of rotary-wing aircraft to March ARB

would trigger a net increase in Marine Corps requirements for

approximately 780 military personnel as compared to the Miramar

alternative. Since Marine Corps end-strength levels are fixed, this

increase would have to come by drawing down other units, and would have

an adverse effect on Marine Corps operations and readiness.

Some comments state that because March ARB is closer to MCAGCC

Twentynine Palms than NAS Miramar, locating Marine Corps rotary-wing

aircraft to March ARB is more advantageous to the Marine Corps for

operational reasons. Predominately the rotary-wing aircraft that use

MCAGCC Twentynine Palms do so as a deployment exercise in support of

combined arms exercises, rather than as individual aircraft transiting

to the area for routine training. During such exercises, the aircraft

transit to MCAGCC, operate there for several days or weeks, then return

to their home base. As such, there are no substantial savings or

advantages to being closer to MCAGCC Twentynine Palms. Although March

ARB is closer to MCAGCC Twentynine Palms, it is farther than

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Miramar from the amphibious forces that the rotary-wing aircraft also

support.

Several comments also suggested that there is a continuing need to

conduct substantial training of Navy (as opposed to Marine Corps)

pilots at NAS Miramar in support of the aircraft carriers homeported in

San Diego. They state that this ongoing Navy training requirement would

operationally preclude realignment of all of the currently proposed

MCAS Tustin and MCAS El Toro assets to Miramar. These comments argue

that these operational requirements can only be met using NAS Miramar

and thus bar a realignment proposal that would use substantially all of

Miramar's capacity for Marine Corps operations, particularly rotary-

wing operations. As explained in the SIR, the Navy has determined that

it can train its fleet aviation assets without relying on MCAS Miramar.

Most of the individual squadron training, including practice carrier

landings, is conducted in the vicinity of the Navy home bases (such as

NAS Oceana and NAS Lemoore). To the extent that additional shore-side

training is required after units deploy to the carriers, it can be

accomplished using Navy air stations and air fields in California. Navy

use of MCAS Miramar will be minimal, and has been accounted for in the

analysis in the FEIS.

Very late in the process, the Department of the Navy received a

comment on the independent review performed by the Deputy Secretary of

Defense. The comment enclosed a report that purported to show that

moving the rotary-wing assets to March ARB would be less expensive than

realigning them to MCAS Miramar as proposed. Careful review of this

report showed it is generally based on incorrect data, inaccurate

assumptions, and inappropriate cost allocations and therefore results

in faulty conclusions. For example, the report relies heavily on

generalized ratios developed from personnel or aircraft loading and not

on specific requirements and thus incorrectly assumes that a high

percentage of new construction at MCAS Miramar can be attributed to the

inclusion of rotary-wing aircraft. The Department of the Navy's cost

estimates for MCAS Miramar, by way of contrast, are based on detailed

project plans.

In consideration of the public comments received on the FEIS, the

SIR and the independent review by the Deputy Secretary of Defense, I

took a hard look at sites other than Miramar as receiving sites for

realigning Marine Corps aircraft. I have concluded that no other site

is operationally preferable to Miramar and that detailed analysis of

other receiving sites clearly would have been inconsistent with BRAC

and Marine Corps force structure plans designed to reduce

infrastructure, costs and personnel requirements. The locations other

than Miramar could not reasonably achieve the purpose and need for the

realignment. Collocation of fixed-wing and rotary-wing aircraft at

Miramar best reduces excess infrastructure; reduces construction and

base operating costs; and makes use of common support assets, thereby

reducing personnel requirements.

6. Implementation

Implementation of the proposed action at Miramar would include the

conversion of aviation operations from Navy procedures to Marine Corps

procedures, construction of necessary facilities to support Marine

Corps operations, and establishment of remote landing sites in East

Miramar.

a. Changes to Aviation Operations and Practices Used by the Navy

Implementation of the proposed action will involve changes in

aviation operations at Miramar, beyond the simple addition of Marine

Corps fixed-wing and rotary-wing aircraft and the associated personnel

and maintenance and support facilities. The NW/SE runway (Runways 6L/

24R) will remain the principal runway for take-off and landing. The

proposed action will also allow for restricted use of the East/West

runway (Runway 10/28) by rotary-wing and some fixed-wing aircraft.

Although no departures for fixed-wing aircraft will be allowed on this

runway, it will still be available for rotary-wing operations as a

helicopter landing pad and for fixed-wing arrested gear landings only.

Changes to flight corridor parameters are also planned. Aircraft

departing to the north/northeast using the Julian corridor will

increase altitude after takeoff at a faster rate. The fixed-wing usage

rate for the Seawolf corridor will decrease from approximately 75% to

50% of total fixed-wing departures while the fixed-wing usage rate for

the Julian corridor will increase from approximately 25% to 50% of

total fixed-wing departures.

The following rotary-wing flight corridors will be added: Seawolf,

IFR Racetrack, Yuma, I-15, GCA Box, north touch and go, and south touch

and go. Based on the original proposal for realigning eleven fixed wing

squadrons and ten rotary wing squadrons, the average daily use of these

corridors (in operations per day) was projected to be approximately 26

for Seawolf, 3 for IFR Racetrack, 14 for Yuma, 23 for GCA Box, 14 for

I-15, 36 for north touch and go, and 87 for south touch and go. The

rotary-wing assets will be serviced at the West end of the airfield

facilities and the fixed-wing assets will be at the East end of the

airfield facilities.

b. Construction

Implementation of the proposed action will require a

reconfiguration and expansion of existing aircraft aprons and

pavements, flightline facilities, and associated support facilities to

meet mission requirements. Major flightline expansion will occur at the

west end of the hangar complex where the helicopter squadrons will be

located, while moderate flightline expansion will occur to the east

with the construction of a new hangar and apron for the single squadron

of KC-130 aircraft. The Marine Corps plans to use the existing ground

training areas, consistent with current NAS Miramar training area

guidelines and procedures. A Mountainous Area Landing (MAL) site and

Confined Area Landing (CAL) site will be located in East Miramar, in

disturbed areas currently supporting various training and maintenance

facilities. Under the proposed action, helicopter landing, takeoff and

hovering activities will occur at these locations and represent a new

land use.

Several construction projects have been proposed to accommodate

assets relocating to MCAS Miramar from MCAS Tustin and MCAS El Toro.

These projects include a new Air Traffic Control Tower, Airfield

Parking Pavement (Aprons), Bachelor Enlisted Quarters, Administration

and Training Facilities, Community Support and Dining Facilities,

Aircraft Maintenance Complex, Ordnance Storage Facilities, Operational

Support Complex, Utilities Improvements, Base Maintenance Facilities,

Storage Facilities, and Tactical Van Pad Facilities.

In addition to the facilities proposed at the Main Station, the

proposed action will also involve the construction of facilities

defined as remote facilities, located at both the Main Station and East

Miramar. Remote facilities that will be located at the Main Station

include the heavy lift pad, Crash Fire Rescue training (to be conducted

at the existing facility), Direct Support Stock Control, and the

Defense Reutilization Marketing Office. Remote facilities that will be

located in East Miramar include the ordnance facilities (ordnance

complex and Explosive Ordnance Disposal (EOD) training facilities),

Mountainous Area Landing site, Confined Area Landing site, and the

Nuclear, Biological, and Chemical training site. The Marine

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Corps plans to use the existing ground training areas in East Miramar

in a manner consistent with current NAS Miramar training area

guidelines and procedures.

7. Environmental Impacts and Mitigation Measures

The impacts analyzed in the EIS are grouped according to their

degree of significance: residual significant impacts (those that cannot

be mitigated below the threshold of significance); impacts mitigated

below the threshold of significance; and impacts that are not

significant. As discussed below, the Marine Corps will implement a

number of mitigative measures to avoid or minimize environmental harm

from the proposed action.

a. Residual Significant Impacts

i. Noise

I have taken a very close look at the issue of noise, recognizing

that many members of the public are concerned about the noise of

helicopter operations at a future MCAS Miramar. Although Miramar has

operated as a busy master jet base for decades and has successfully

managed the attendant noise, the introduction of substantial numbers of

helicopter operations has raised some additional concerns among some

members of the public. These concerns arise from the perceived

differences in the noise and the addition of new flight corridors. As

discussed below, the Department of the Navy has worked hard to assess

the impact of noise and to mitigate it as much as practical. Although

the mitigation measures should reduce noise impacts, the noise from

aircraft operations cannot be eliminated entirely.

Noise impacts were assessed using the State of California's

standard, the Community Noise Equivalent Level (CNEL), expressed in

units of decibel (dB). The State of California's Title 21, Subchapter

6, Section 5006 states: ``The level of noise acceptable to a reasonable

person residing in the vicinity of an airport is established as a

community noise equivalent level (CNEL) value of 65 dB for purposes of

these regulations. This criterion level has been chosen for reasonable

persons residing in urban residential areas where houses are of typical

California construction and may have windows partially open. It has

been selected with reference to speech, sleep and community reaction.''

Section 5014 describes the land uses that are incompatible within the

noise impact boundaries. It provides that noise exposure levels less

than 65 dB CNEL are generally compatible for noise sensitive land uses,

including residential areas and schools. Even after mitigation, the

proposed action will result in significant on-base and off-base noise

impacts related to fixed-wing aircraft operations. Noise contours

defining the areas of impact in 5 dB increments were developed using

the NOISEMAP model and projected operational tempo data.

The outer limits of the mapped noise contours are related to fixed-

wing aircraft. Rotary-wing (helicopter) aircraft noise contours fall

entirely within fixed-wing aircraft CNEL noise contours. Noise impacts

based upon the 65 dB CNEL standard are therefore associated with fixed-

wing aircraft. Noise contours that will result from the realignment

action for only rotary-wing aircraft are provided on page F-71 of

Appendix F, Volume I of the FEIS.

Further reductions in noise levels compared to the noise levels

that were calculated originally (and set out below) will result from

the disestablishment of one F/A-18 squadron and the transfer of another

to Japan. Elimination of the CH-53D operational squadron (realigned to

MCB Hawaii) and the CH-53 FRS squadron (realigned to MCAS New River, NC

and MCBH, HI) will also result in a substantial reduction in touch and

go operations, and consequently in the projected noise levels

attributable to those aircraft.

Specific areas of concern are:

(a) Noise Impacts to Housing. The total acreage within the 65 dB

Community Noise Equivalent Level (CNEL) contour will decrease by

approximately 305 acres; however, the majority of the 65 dB CNEL

acreage decreases will occur in East Miramar where no homes are

located. Approximately 43 homes currently located within the existing

65 dB CNEL contour will fall outside that contour after the realignment

action and will experience a decrease in noise. Conversely,

approximately 128 homes currently located outside of the existing 65 dB

CNEL contour will fall within that contour after the realignment action

and will experience an increase in noise. Overall, the realignment

action will result in a net increase of approximately 85 homes within

the 65 dB CNEL contour. Even though the California CNEL is not

exceeded, the Department of the Navy will continue to assess noise

impacts in affected housing areas to determine what future mitigation

measures may be necessary.

(b) Noise Impacts to Schools. The Department of the Navy has looked

carefully at potential noise impacts to schools. No public school will

fall within the 65 CNEL contour as a result of the realignment action.

However, various San Diego area school districts commented that the

increased noise from aviation operations could require sound

attenuation. The California requirement for sound attenuation is based

on the CNEL noise standard rather than proximity to a flight corridor.

I reviewed these comments, carefully considering the importance of

schools to our communities. As described above, the State of California

Code of Regulations, Title 21, provides that noise exposure levels less

than 65 CNEL are compatible for noise sensitive land uses, including

schools. Noise levels below 65 dB CNEL do not automatically trigger a

requirement for sound attenuation. Nonetheless, the Department of the

Navy is fully committed to continuing to work closely with the Miramar

Technical Advisory Committee. The Advisory Committee, consisting of

representatives of communities surrounding Miramar, works with the

Marine Corps to mitigate and/or reduce impacts from Marine Corps

aviation operations on areas surrounding Miramar. The Advisory

Committee is ideally suited to review Miramar's operational impacts on

schools. The Advisory Committee has been meeting regularly since May

1996, and has already successfully achieved noise mitigation measures

such as increasing the altitudes of Marine Corps rotary-wing air

routes.

(c) Noise Impacts to Sleep and Speech. A concern was raised in

public comments that the EIS section regarding sleep and speech

disturbance did not include mitigation measures. In addition to

analyzing noise impacts under the CNEL standard, the Department of the

Navy also measured noise impacts using Sound Exposure Level (SEL)

metrics. SEL can be used as an indicator of annoyance factors such as

sleep disturbance and speech interference, but cannot be used to

``predict long-term human health impacts.'' (``Federal Agency Review of

Selected Airport Noise Analysis Issues'', Federal Interagency Committee

on Noise, August, 1992). There are no established noise thresholds of

significance for sleep disturbance and speech interference. Unlike the

case with the CNEL standard, judging sleep disturbance and speech

interference is subjective. Nonetheless, the Department of the Navy

recognizes that sleep disturbance and speech interference may occur in

some residential areas outside the boundary of MCAS Miramar. In an

effort to more fully inform the public and ensure the impacts were

fully considered in the

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decision-making process, the Department of the Navy voluntarily

collected SEL data to provide additional analysis on sleep disturbance

and speech interference. Information on the impacts to the 17

representative test locations is presented in Table 4.11-9 of the FEIS.

The Marine Corps has continued to study the impacts of rotary-wing

operations and to meet with community representatives to understand

their concerns better. The Marine Corps has modified its procedures to

accommodate these concerns. For example, as discussed below, the

altitude of some flight corridors has been raised. The Marine Corps

will continue to meet with community leaders and elected officials to

seek ways in which noise impacts may be further reduced.

(d) Mitigation for Noise Impacts. A primary consideration for the

Department of the Navy was to configure operations to promote land use

compatibility, as defined under California CNEL standards, consistent

with the City of San Diego's Comprehensive Land Use Plan (CLUP) for

Miramar. In order to minimize noise exposure from aviation operations

to the surrounding communities, the Marine Corps will incorporate the

following noise mitigation measures into its aircraft operations

procedures: (1) Reduce aircraft power settings for Ground Control

Approach operations for F/A-18s (refer to Figure 4.10-4 in the FEIS);

(2) discontinue use of afterburners by departing aircraft upon reaching

the MCAS Miramar boundaries whenever possible; (3) limit repetitive

``pattern'' work to normal operating hours, except where necessary to

meet operational requirements; (4) increase the altitude at which the

aircraft are held in the Julian Standard Instrument Departure from

3,000 to 6,000 feet MSL; (5) divert some helicopter flights from

neighboring communities through a flight corridor (Yuma Corridor) south

of the runways to reduce the effects of helicopter noise; (6) eliminate

a departure route (SVFR Yuma departure route) from the I-15 corridor to

the east; (7) raise the outbound altitude on the Yuma departure from

2,600 feet to 3,000 feet and the inbound altitude from 2,100 feet to

3,500 feet; (8) raise the outbound altitude of the Interstate 15

corridor from 2,600 feet to 3,000 feet and the inbound altitude from

2,100 feet to 3,500 feet MSL; and (9) relocate the primary route

between MCAS Miramar and MCAS Camp Pendleton further offshore, at a

minimum distance of one mile from the coast.

These mitigation measures have already been approved by the FAA.

The Marine Corps will continue to attempt to mitigate noise impacts by

working with the FAA on further changes to the air routes, including a

request to raise the altitude of the Seawolf corridor.

(e) Additional Testing and Future Analysis. Several comments

requested that additional testing and future noise monitoring be

accomplished. The Marine Corps will continue to examine all operational

activities for ways to minimize noise impacts to the surrounding

communities, perform a new noise analysis in the year 2000, and

maintain a noise complaint hotline for the public. The noise analysis

in the year 2000 will come shortly after the realignment of MCAS

Miramar is completed.

I recognize that because noise perception is subjective and models

are imperfect, some households will perceive more noise as a result of

the proposed realignment regardless of what the models may indicate.

Some individuals may even perceive this noise as significant. But, as

explained above and discussed wtih the public in several meetings, the

Department of the Navy recognizes these concerns, has already taken

significant steps to mitigate the noise impacts, and will continue to

analyze noise impacts and work with the public to mitigate any future

problems.

ii. Biology (Vernal Pools--Habitat). Vernal pools consist of three

distinct resources: the habitat (watershed), which is addressed here,

the basins (wetlands), and the species associated with vernal pools.

Both the basins and the associated species are addressed in section

7.b.(iii), below. Vernal pool habitat is the only biological resource

that will be significantly impacted. The proposed action will result in

the loss of approximately 4.7 acres of vernal pool habitat, which

cannot be fully mitigated. Less than three percent of historical vernal

pool habitat remains in San Diego County. The proposed action will

result in further depletion of vernal pool habitat. The amount of

habitat being impacted is considered to be significant. Mitigation

measures are discussed in paragraph 7.b.(iii).

iii. Community Services and Utilities (Schools). Of the projected

net increase of 3,875 personnel associated with the proposed action,

approximately 197 will be civilians who will be housed off-base,

independent of military personnel. The resulting net increase will be

3,150 enlisted and 528 officers. It is estimated that a net increase of

1,698 school-aged dependents at MCAS Miramar will be introduced to the

schools of San Diego County upon implementation of the proposed action.

Insofar as these additional personnel choose to purchase or rent

existing homes or apartments in the local community, no impacts will

occur since developer impact fees, which are used to fund school

districts, were or will be paid at the time of construction.

The Department of the Navy Military Family Housing in the greater

San Diego region is managed under a shared-pool system, whereby the

Marine Corps will compete on an equal basis with Navy for available

units in that pool, regardless of actual location within the region. If

military personnel associated with the proposed action choose to live

in existing Military Family Housing, their school-aged dependents will

not impact the San Diego school system as these children have already

been factored into the capacity of the school district. A proposal is

being considered as part of the Fiscal Year 1998 budget to construct

approximately 166 units of Military Family Housing on or near MCAS

Miramar. This proposal is part of a regional housing plan and is not a

component of the conversion of NAS Miramar to MCAS Miramar. If these

166 units of Military Family Housing are constructed on-base, up to

approximately 80 school-aged dependents could be added to the schools

in San Diego County. Most of the schools in the vicinity of NAS Miramar

are operating either at or near enrollment capacity. Even adding only

80 children could be significant. To reduce potential cumulative

impacts to school capacity, the Marine Corps will apprise potentially

affected schools of any military family housing construction programs

approved in the vicinity of MCAS Miramar in an effort to assist the

schools in planning for an increase in student population. Any proposal

to construct military family housing at MCAS Miramar will be evaluated

in separate NEPA documentation.

b. Mitigated to Below the Threshold of Significance

(i) Geology and Soils

As discussed in the FEIS, the proposed action will include

incorporating appropriate erosion control measures and proper

excavation techniques to ensure protection of soil resources. The

proposed action will not affect geologic resources as the facilities

will be designed to reduce the potential for land slides and other

adverse geological activities. No significant impacts to soil will

occur as a result of implementing the proposed action.

[[Page 64717]]

(ii) Water Quality

As discussed in the FEIS, appropriate measures will be implemented

to ensure that potential releases of fuels are minimized. The

installation spill response plan will be updated to cover the new

facilities. No significant impacts to water quality will occur as a

result of implementing the proposed action.

(iii) Biology

The Department of the Navy has carefully studied the potential

impacts of the proposed action on endangered species and wetlands and

in consultation with the requisite agencies, has developed and will

implement appropriate measures to protect these sensitive resources. As

discussed in section 7.a.(ii), above, vernal pools consist of three

distinct resources: The habitat (watershed) discussed in section

7.a.(ii), the basins (wetlands), and the species associated with the

basins. This section discussed the basins and the associated species.

The proposed action will impact vernal pool wetlands and species

because of the loss of the basins. The Department of the Navy will take

a number of actions to mitigate these impacts below a level of

significance.

Based upon consultation with the U.S. Fish and Wildlife Service

(USFWS), three federally-listed endangered/threatened species and two

species proposed for listing as endangered/threatened were identified

as present on NAS Miramar. These endangered species that are included

are the California gnatcatcher (gnatcatcher), the endangered San Diego

button-celery (button-celery), and the endangered San Diego mesa mint

(mesa mint). The San Diego fairy shrimp (fairy shrimp) and the quino

checkerspot butterfly (butterfly), both of which are proposed for

listing as endangered, were also included in the consultation.

The Department of the Navy prepared a Biological Assessment on

these five species and other biological resources. Information provided

to USFWS in the Biological Assessment is summarized in the DEIS, FEIS,

and SIR. Specifically, the DEIS, FEIS, and SIR discussed the existing

condition of these threatened and endangered species as well as other

sensitive species and their habitat in considerable detail. The DEIS,

FEIS, and SIR identified the impacts associated with the proposed

action and discussed mitigation measures that would reduce the

potential for adverse impacts on the threatened and endangered species

and their habitat.

During consultation with USFWS, the Marine Corps provided a list of

20 species and habitat conservation measures that were incorporated

into the proposed action. Six measures dealt with general conservation

measures (e.g., hiring a qualified project biologist, marking sensitive

habitat areas, prohibiting entry into sensitive areas, conducting

surveys for other species). Nine measures dealt with protecting vernal

pools (e.g., seasonal restrictions on construction during the rainy

season, mitigation ratios, development of plans). Five protective

measures dealt with protection of the gnatcatcher and the coastal sage

scrub where it lives (e.g., seasonal restrictions on clearing

gnatcatcher habitat during the breeding season, mitigation ratios,

revegetation, a study of the potential impact of helicopter noise, and

an explicit commitment to re-initiate formal consultation if the

helicopter study finds significant impacts).

On April 11, 1996, the USFWS issued a Biological Opinion in which

it concluded that the proposed action is not likely to jeopardize the

continued existence of the gnatcatcher, button-celery, mesa mint, or

fairy shrimp. The USFWS also concluded that the quino checkerspot

butterfly is unlikely to occur on the Station and therefore any adverse

effect on the butterfly is unlikely. The USFWS Biological Opinion

describes the potential effects, direct and indirect, that the proposed

action would have on the species. In rendering the Biological Opinion,

the USFWS determined that the Marine Corps will undertake the

mitigation measures described in the FEIS and the Biological Opinion

and that the Marine Corps has committed to developing and implementing

a Multi-Species Habitat Management Plan (MHMP) for MCAS Miramar

consistent with the requirements of the Sikes Act. The MHMP, which the

Marine Corps will develop in conjunction with the USFWS, the U.S. Army

Corps of Engineers (ACOE), and the California Department of Fish and

Game (CDFG), will be designed to conserve natural resources onboard

MCAS Miramar on a day-to-day basis. The MHMP will deal with all natural

resources, but is especially concerned with threatened and endangered

species and their habitat. The MHMP is to be submitted to the USFWS,

ACOE and CDFG by October 1998. The MHMP is designed to enhance

biological diversity on the Station, while simultaneously supporting

the Marine Corps mission at MCAS Miramar.

The Biological Opinion also includes an Incidental Take statement

which describes taking that is incidental to and not intended as part

of the agency action. The Incidental Take statement includes three

Reasonable and Prudent Measures that the USFWS determined are necessary

and appropriate to minimize incidental take: (i) The Marine Corps shall

minimize destruction of gnatcatcher and fairy shrimp habitat and

provide compensation for unavoidable impacts; (ii) the Marine Corps

shall minimize impacts to occupied gnatcatcher territories during

construction activities; and (iii) the Marine Corps shall obtain a

permit from the ACOE, pursuant to section 404 of the Clean Water Act,

prior to any filling of vernal pools. The Marine Corps will comply with

all terms and conditions associated with this permit.

The Incidental Take statement also contains detailed terms and

conditions that implement the Reasonable and Prudent Measures. These

parallel and sometimes strengthen the mitigation measures described in

the FEIS. The terms and conditions will be incorporated into the final

Biological Mitigation and Monitoring Plan, which must be approved by

the USFWS and the ACOE. The list of terms and conditions is set out in

the Incidental Take statement, which is part of the Biological Opinion.

The Marine Corps will comply with all terms and conditions articulated

in the Biological Opinion.

Two comments addressed the reduction in the width of the wildlife

corridor in Rose Canyon as a result of sewer line installation as part

of the proposed action. After review of a number of factors, the

Department of the Navy determined that the impact will not be

significant. Corridors narrower than 400 feet are less likely to be

used by wildlife, as indicated by the Baldwin Otay Ranch Wildlife

Corridor Studies prepared by Ogden. The portion of Rose Canyon that may

be affected is toward the head of the canyon. Wildlife that utilize

this canyon must cross Kearny Villa Road and go underneath Interstate

15 (via a tunnel). The current corridor width of 250 feet provides

limited habitat opportunities to wildlife. Reduction of Rose Canyon is

not expected to adversely affect wildlife. In accordance with the

Biological Opinion, the Marine Corps is considering construction

methods to reduce impacts to Rose Canyon.

Some comments suggested the discussion of the potential effects of

the proposed action on endangered and threatened species was deficient

because the FEIS did not include the biological information in the

Biological Opinion and the MHMP. These comments expressed concern that

the decision maker should have the

[[Page 64718]]

information in the Biological Opinion and MHMP before reaching a final

decision. The Marine Corps received a draft Biological Opinion prior to

publishing the FEIS, and consequently the FEIS contained all of the

significant biological impacts and a majority of the mitigation and

monitoring requirements contained in the Final Biological Opinion

issued by the USFWS on April 11, 1996. The Biological Opinion was

discussed in the SIR and I have fully considered it in making the

decision on realigning Marine Corps aviation assets.

Some comments suggested that the study of effects of helicopter

noise on gnatcatchers should be completed before a decision to proceed

is made. Given the information already known, the USFWS no jeopardy

determination, and the mitigation agreed upon and set out in the USFWS

Biological Opinion, I have concluded that the proposed action can

safely proceed pending further study. As set out in the SIR, the Marine

Corps is committed to studying the effects of noise on gnatcatchers and

has already begun the research. The study is expected to last five

years and will cost approximately $600,000. Given the commitment of the

Marine Corps to immediately undertake formal consultation if

significant impacts are discovered, the incomplete information is not

essential to a reasoned choice among the alternatives at this time.

(iv) Traffic

One off-base intersection and five on-base intersections will

experience higher traffic volumes resulting in a significant impact as

a result of the proposed action. Increases in off-base traffic will

occur at the intersection of Miramar Road and Mitscher Way at the North

Gate, which will worsen the Level of Service (LOS) rating from D to E

in the evening peak hours.

The Department of the Navy will implement the traffic mitigation

measures discussed in the FEIS (4.12-9 & 10) and SIR to mitigate the

impacts to below the threshold level of significance. The Department of

the Navy has decided to install a traffic signal without the delay

associated with conducting further studies. Construction traffic

represents a temporary and nominal increase in traffic volumes;

therefore, impacts to the off-base and on-base circulation system will

not occur during construction.

The California Department of Transportation's comments to the FEIS

included a request for additional traffic studies. The technical

traffic study, as discussed in Section 4.12 of both the DEIS and FEIS,

was conducted using the most current traffic counts available, approved

trip generation and trip distribution assumptions, and the Highway

Capacity Manual methodology for intersection analysis. The study was

sufficient to determine the proposed action's off-base impacts.

Although one comment on the SIR suggested that another computerized

study of traffic is necessary, I have concluded that the methods the

Department of the Navy used, which were specifically tailored to the

Miramar area, were more accurate than the suggested study would be and

thus additional traffic studies are not warranted.

(v) Community Services and Utilities (Potable Water)

The demand on the potable water distribution system is expected to

increase as a result of the proposed action. The existing system is not

adequate to accommodate the demands of the proposed action. To provide

an adequate water supply, the Marine Corps will use the backup

connection from the San Diego water system as a full-time connection.

The City of San Diego has not stated a concern regarding the use of

this connection.

c. Impacts That Are Not Significant

i. Air Quality

The San Diego Air Basin is federally classified as a serious ozone

non-attainment area and a moderate carbon monoxide (CO) non-attainment

area. Pursuant to Section 176(c) of the Clean Air Act, US EPA

promulgated a final rule ``Determining Conformity of General Federal

Actions to State or Federal Implementation Plans'' (General Conformity

rule), 58 F.R. 63214 (Nov 30, 1993) (40 C.F.R. Parts 51 and 93). A

conformity applicability analysis of the air emissions associated with

the proposed action was conducted. As elaborated on in the SIR, the

conformity applicability analysis determined that air emissions

associated with the proposed action (reduced by the amount of emissions

associated with the departing U.S. Navy aircraft) are: (1) Below de

minimis levels (i.e., the net changes in emissions of criteria

pollutants do not exceed threshold levels established in the General

Conformity Rule); and, (2) not regionally significant (they do not

exceed 10% of the San Diego Air Basin's total emissions inventory for

any applicable criteria pollutant). Consequently, the proposed action

is not subject to the General Conformity Rule. (FEIS, Sec. 4.2 and FEIS

Appendix B)

Although the General Conformity rule does not require publication

of an applicability analysis that demonstrates emissions are de

minimis, the Department of the Navy published a summary of its

conformity applicability analysis in both the DEIS and FEIS to more

fully inform the public. (DEIS/FEIS, Sec. 4.2 and DEIS/FEIS Appendix

B).

Several comments expressed concerns regarding the Department of the

Navy's conformity applicability analysis and air quality impact

analysis under NEPA. Particular issues of concern included: (1) The

selection of 1990 for use in calculation of the net emissions for the

conformity applicability analysis; (2) why the emissions in the FEIS

differed from the emissions budget in the San Diego State

Implementation Plan (SIP); (3) why emission estimates in the DEIS and

the FEIS for helicopter emissions differed; (4) whether all appropriate

types of emission sources were included in the applicability analysis;

and (5) whether the methodologies used to calculate emissions were

proper. In its comments on the SIR and in response to a public inquiry,

EPA Region 9 requested additional information to resolve several issues

on how the total of the direct and indirect emissions for the proposal

were calculated.

Use of 1990 to determine net emissions. In conducting a conformity

applicability analysis for the proposed action, the Department of the

Navy selected 1990 as the most appropriate year to reflect Navy

aircraft operations and activities at Miramar as a fully operational

Naval Air Station in normal circumstances. As such, 1990 was used as a

basis to calculate emissions increases and decreases caused by the

proposed action; i.e., the ``net'' emissions considering all incoming

and outgoing direct and indirect emissions. The ``netting'' of

emissions in this manner appropriately accounts for the total direct

and indirect emissions associated with the proposed action and is in

accordance with provisions of the General Conformity Rule. The

Department of the Navy's use of 1990 to analyze net emissions is also

consistent with the San Diego Air Pollution Control District's (APCD)

use of 1990 for determining emissions inventories.

Difference between the FEIS and the SIP--use of best available data

instead of SIP estimates. In conducting its conformity applicability

analysis, the Department of the Navy did not use emission estimates

found in the San Diego SIP air emissions budget. With San Diego APCD's

concurrence, the Department of the Navy calculated the emissions for

1990 that more accurately estimated emissions at NAS Miramar than those

found in the San Diego SIP. Table B-1 in the FEIS, ``1990 Annual Air

Quality Emissions at NAS

[[Page 64719]]

Miramar,'' identified the specific Navy and EPA technical sources

(which did not include the SIP) that the Department of the Navy used to

calculate emissions. The section of that table entitled ``Aircraft

Emissions'', explains how the Department of the Navy calculated

aircraft emissions for the year 1990. Operational data were based on

definitive studies, specific aircraft types, and defined aircraft

operating characteristics. The proposed realignment does not violate

any emission reduction targets for military aircraft, since no

reduction targets exist in the SIP.

Differences in emissions figures for helicopters between the DEIS

and FEIS. Some comments questioned why estimates for emissions from

helicopters varied between the DEIS and the FEIS. The San Diego APCD

responded during the public review period of the Draft EIS with

questions regarding rotary-wing emissions and the inversion layer

height, which is at 2,000 feet for six months and 3,000 feet for six

months of the year. The FEIS addressed these concerns by calculating

rotary-wing aircraft emissions up to 3,000 feet year-round and no

further comments were received from the SDAPCD on this issue. This

change in altitude of the inversion layer accounts for the difference

in rotary-wing aircraft emission estimates found in the DEIS and FEIS.

Inclusion of direct and indirect emissions in conformity

applicability analysis. In performing either a conformity determination

or an analysis to determine the applicability of the requirement for a

conformity determination, an agency does not have to include every

indirect emission that could be associated with a project. Implementing

regulations reasonably limit the reasonably foreseeable indirect

emissions that must be considered to those that practicably are subject

to control by the agency in the normal course of its mission. The

Department of the Navy calculated the direct and indirect emissions

associated with the proposed realignment that were both reasonably

foreseeable and practicably controlled under the Department of the

Navy's use of Miramar as a military airfield. The Department of the

Navy has no ``continuing program responsibility'' for most offbase

indirect emissions within the meaning of the regulations governing

conformity determinations.

Appropriate methodologies. I carefully reviewed the public comments

on the air analysis and conformity applicability analysis in the DEIS,

FEIS and SIR. In view of these comments, I reviewed and took a hard

look at the Department of the Navy's method for estimating air

emissions and the supporting data and calculations. The Department of

the Navy's method for calculating aircraft emissions applies the

following elements: number of aircraft operations; type or mode of

operation (power setting); number and type of aircraft engines per

aircraft; time in mode; and, corresponding emission factors. The

emission factors were obtained from studies conducted by the Navy

Aircraft Environmental Support Office (AESO) that are referenced in the

EPA ``Compilation of Air Pollutant Emission Factors (AP-42).''

After receipt of comments on the SIR, the Department of the Navy

reviewed the applicability analysis and found that the original

analysis assumed that the E-2/C-2 Navy aircraft currently stationed at

NAS Miramar would leave the air basin. No final decision has been made,

however, on relocation of the E-2/C-2 aircraft and they potentially

could remain in the air basin. To determine the impact if the E-2/C-2

aircraft remain, the emissions were recalculated including the E-2/C-2

emissions. Even with these emissions included, the analysis showed that

emissions would still be below de minimis thresholds established by the

General Conformity Rule. This analysis was very conservative, because

it did not reduce projected emissions to account for four Marine

squadrons that were moved outside the air basin. The original analysis

included eleven fixed-wing and ten rotary-wing squadrons. Subsequently,

two fixed-wing and two rotary-wing squadrons were decommissioned or

relocated to other sites outside the air basin. Thus emissions can

reasonably be expected to be lower still.

In response to its comments on the SIR, the Department of the Navy

provided EPA Region 9 with a letter providing additional explanation,

summarized above, clarifying the way it conducted the applicability

analysis, addressing the issues that EPA felt it was unable to resolve,

and offering to provide the underlying data for the analysis. On

November 14, 1996, EPA Region 9 responded that although the

applicability determination is the responsibility of the action

proponent, it had reviewed the information provided by the Department

of the Navy's letter and determined that the methods used by the

Department of the Navy to determine the ``total of direct and indirect

emissions'' from the proposed action was appropriate. The San Diego Air

Pollution Control District had indicated its concurrence in the methods

used by the Department of the Navy in earlier correspondence.

A further comment on the air quality analysis was received on

November 22, 1996. It continued to challenge the accuracy of the

Department of the Navy's estimates of air emissions. The comment argues

that the realignment will result in significant impacts to San Diego's

air quality, that the action violates the Clean Air Act and EPA rules

and regulations, and that the action will result in pollution in excess

of SIP milestone goals, thereby potentially limiting commercial

expansion in the area. The comment revealed no new significant

environmental information or changed circumstances but relied on

incorrect assumptions and methods to reach a much different, and

faulty, result. A thorough review of the Department of the Navy's

applicability analysis confirmed that it is accurate.

In summary, the Department of the Navy has conducted a thorough

review of the data and methods used to analyze whether the requirement

for a conformity determination applies to this proposed action. My

review of the record indicates that the proposed realignment of Miramar

represents a net decrease in air pollution and will contribute to San

Diego's reasonable further progress toward attainment.

ii. Hydrology

As discussed in the FEIS, the proposed action will not have any

significant impacts on the local or regional hydrology. (FEIS,

Sec. 4.3)

iii. Cultural

In accordance with 36 CFR Part 800, regulations implementing

Section 106 of the National Historic Preservation Act, it was

determined that three cultural sites are eligible for inclusion in the

National Register of Historic Places (NRHP). The State Historic

Preservation Officer (SHPO) agrees with this determination. Similarly,

the SHPO has concurred with the determination that the proposed action

will not affect historic properties FEIS, Sec. 4.5). The proposed

realignment of NAS Miramar will not significantly impact cultural

resources listed or determined eligible for listing on the NRHP.

iv. Visual Resources

As discussed in the FEIS, the proposed action will not have any

significant impacts on the visual resources (FEIS, Sec. 4.6).

v. Land Use

As discussed in the FEIS, the proposed action will not have any

significant impacts on land use as

[[Page 64720]]

designated in San Diego's CLUP for Miramar (FEIS, Sec. 4.7). Land use

compatibility in the context of aircraft and airfield operations is

evaluated on the basis of Accident Potential Zones (APZ) and noise

contours. Both the APZ analysis and the noise analysis using California

CNEL standards indicate that current land uses surrounding MCAS Miramar

are compatible with the proposed aircraft and airfield operations.

Some comments raised concerns that the proposed project will have

significant impacts on existing and planned land uses in the

surrounding communities. The analysis of land use impacts were based on

the San Diego Association of Governments (SANDAG) Series VIII forecast

data, which were updated by the Department of the Navy to reflect 1994

conditions. The State of California has adopted the CNEL as the state-

wide standard for land use planning around airports within the state.

This standard is consistent with the adopted CLUP for NAS Miramar and

Lindbergh Field, and is endorsed by the County of San Diego. SANDAG

develops and maintains regional land use databases as part of its

charter to track land use trends and forecast population growth. The

most recent (1990) existing land use GIS database available from SANDAG

was obtained to analyze land use compatibility in the FEIS. SANDAG

updates the database every five years, and is currently working on the

1995 update. In order to update the database to 1994 (the baseline or

existing conditions year for the FEIS), the Marine Corps, in

cooperation with SANDAG, reviewed aerial photographs from the 1994

Thomas Brothers Aerial Photo Map Book. The photos were reviewed

primarily to identify new housing development within the 65 dB CNEL

noise contour surrounding NAS Miramar. In addition, SANDAG maintains a

database of proposed site specific projects which was used as a guide

for the 1994 update process. The Department of the Navy used this

updated data in evaluating noise impacts.

vi. Public Health and Safety

A number of comments were received dealing with safety. Some of

these comments discussed concerns about the safety of operating rotary-

and fixed-wing aircraft at the same airfield. Some of these focused on

the perceived risks during repetitive training operations at the field,

especially Field Carrier Landing Practice (FCLP) approaches. Others

discussed potential risks of operating military aircraft in an area

characterized as the second busiest in the country. The Department of

the Navy takes aviation safety very seriously and recognizes that the

public has legitimate concerns that those who use the nation's airspace

must do so in a safe manner. After carefully looking at the issues and

as discussed in the FEIS and the SIR, I have determined that the

proposed action will not have any significant impacts on the local or

regional public health and safety.

Measures to ensure safety of flight. Some comments raised the issue

of mixing rotary-wing and fixed-wing aircraft, especially combining

close-in patterned FCLPs by fixed-wing aircraft and rotary-wing take-

offs and landings. The Marine Corps will be one of numerous users of

the airspace above and adjacent to MCAS Miramar. Consequently, the

Marine Corps has a vested interest in maintaining safe operations and

will make maximum use of appropriate control measures and operating

procedures to ensure proper time, distance, and altitude separation

between aircraft. The Marine Corps has operated rotary- and fixed-wing

aircraft at a number of other air stations, relying on a combination of

redundant measures to ensure safety of flight at its air stations and

the air corridors nearby. These measures include extensive pilot

training and briefing, established traffic separation schemes, and

watchful air traffic controllers in constant communication with

aircraft. These measures have allowed the Marine Corps to operate

safely in the past in circumstances at least as severe as those its

pilots will face operating from MCAS Miramar.

At MCAS Miramar, traffic patterns have been designed to provide the

necessary separation between aircraft. Fixed-wing and rotary-wing

aircraft will be based at opposite ends of the airfield. This

separation will occur on the parking apron, fuel pits, aircraft

movement areas and the landing/departure surfaces. Most rotary-wing

aircraft arrivals and departures and all pattern work will be done on

the north pads while fixed-wing FCLP's are in progress on the 24L

runway located to the south side of the air station. Consequently, to

improve safety, fixed- and rotary-wing aircraft will be laterally

separated and deconflicted while FCLP operations are in progress. Entry

into the patterns is carefully controlled by air traffic controllers.

The air traffic controllers maintain visual and/or radar surveillance

of all aircraft in the vicinity of the field, have communications with

all aircraft in the patterns, and can warn them of dangerous

situations.

MCAS Miramar will use the rules set forth in FAA Handbook 7110.65

to operate rotary- and fixed-wing aircraft while they are within

controlled airspace and under the control of air traffic controllers.

These rules contain separation and sequencing requirements for

operating all types of aircraft and will be applied to all operations

at MCAS Miramar as required. All air traffic controllers are trained

and qualified to provide safe and expeditious handling of all aircraft

under their control. Also, unique operating procedures are developed at

each air station to accommodate the unique mix of aircraft at that air

station and are published in the Air Field Operations Manual. A revised

Air Field Operations Manual will be published for MCAS Miramar to

address the planned mix of aircraft. Most of the aircraft stationed at

MCAS Miramar will also provide some advantages over typical commercial

aircraft and many general aviation aircraft. The helicopters are dual

seat aircraft, allowing one of the pilots to help maintain a visual

scan of the area. The helicopters also have broad windscreens and

better cockpit visibility than many commercial aircraft. The F/A-18s

have clear canopies and are designed to provide excellent all around

visibility. Although nothing can guarantee absolute safety, these

measures provide a substantial margin of safety. Finally, the Marine

Corps is committed to sacrificing efficiency if necessary to ensure

that safety is maintained.

Marine Corps success in operating safely in congested uncontrolled

airspace. Several comments raised the issue of safety and the operation

of rotary-wing aircraft in ``uncontrolled airspace.'' The Department of

the Navy has safely integrated rotary wing aircraft with general

aviation aircraft for many years in the existing San Diego airspace

structure. The comments received have not offered any evidence to the

contrary that would lead me to conclude that the proposed operations in

San Diego can not be conducted safely. The Marine Corps has worked

closely with the Federal Aviation Administration (FAA), the Southern

California Terminal Radar Approach Control Facility (SC TRACON), and

the San Diego Airspace Users Group (SAUG) to ensure that the proposed

action will be compatible with the existing airspace structure. Rotary

wing aircraft operate at approximately the same speeds as small general

aviation aircraft and this contributes to these two types of aircraft

operating safely in a VFR environment. Currently, Marine Corps rotary-

wing aircraft

[[Page 64721]]

operate safely in ``uncontrolled airspace'' in other areas, including

equally congested airspace, without incident. For example, over 90% of

the USMC rotary-wing operations in the vicinity of MCAS Tustin in 1995

were VFR operations (95,525 of 104,171), and of those, nearly 20% were

in uncontrolled VFR airspace. This demonstrates the ability of the

Marine Corps to operate rotary-wing aircraft in congested uncontrolled

airspace safely.

Compared with the airspace around NAS Miramar, the airspace around

MCAS Tustin and John Wayne/Orange County Airport is far more congested

with approximately 21,971 operations per square mile (three mile

radius) in 1994, compared to nearly 4,927 operations per square mile

(five mile radius) in 1994 between NAS Miramar and Montgomery Field. If

the area under consideration at Orange County is expanded to include

the operations of MCAS El Toro (a radius of seven miles), the

congestion (approximately 4,675 operations per square mile) is nearly

equal to that experienced near Miramar in 1994. The SC TRACON, as well

as the Marine Corps, is equipped to handle the air traffic volume in

these areas. Thus, the history of operating rotary-wing aircraft at

MCAS Tustin and fixed-wing aircraft at MCAS El Toro in congested

airspace, both controlled and uncontrolled, demonstrates that the

impacts of these operations on general aviation can be managed safely.

Coordination with the Federal Aviation Administration and local

groups. Some comments also raised an issue regarding the operation of

fixed-wing and rotary-wing aircraft in the same airspace. The

realignment of NAS Miramar to MCAS Miramar necessarily involves a

change in the aviation operations at Miramar. The change in aviation

operations was fully considered in studies associated with the EIS. The

Marine Corps and the Department of the Navy have worked closely

throughout the planning process with the FAA, SC TRACON, and the SAUG

to deal with the change in aviation operations. Of note, the FAA is

charged with overall responsibility for the safe and expeditious

handling of all aircraft in the National Airspace System. As such, the

FAA is responsible for determining whether airspace should be

uncontrolled or controlled (unregulated or regulated). The Department

of the Navy has worked with these agencies to plan for the realignment,

and none of these agencies has submitted an objection to the proposed

action.

Interface with Class B airspace. An issue was raised regarding the

impacts of flight operations for the proposed realignment on Class B

airspace. A comment also argued that the proposed mitigation measures

are insufficient. The point was made that San Diego TRACON is the

second busiest facility in the United States and is predicted to grow

in complexity and congestion. For clarification, the San Diego TRACON

was consolidated into SC TRACON in September, and is now referred to as

the San Diego Sector of the SC TRACON. As described above, the San

Diego Sector of SC TRACON is appropriately equipped for the workload.

The Marine Corps has been working with SC TRACON to ensure

compatibility. The introduction of rotary-wing aircraft will not have a

significant impact on Class B airspace because most helicopter

operations will not be required to operate in Class B airspace. The SIR

explains that 60% of the rotary-wing operations will take place within

the confines of MCAS Miramar, thus these operations will have no impact

except at MCAS Miramar. Further, the impact on Class B airspace will be

reduced as the USMC will conduct fewer total operations in Class B

airspace than the Navy because it will have fewer fixed-wing aircraft

at Miramar than the historic Navy levels. The Marine Corps will

continue to work with the FAA and the Miramar Technical Advisory

Committee, providing an ongoing dialogue to promote regional airspace

safety.

vii. Hazardous Material and Wastes

As discussed in the FEIS, the proposed action will not have any

significant impacts related to hazardous materials or wastes (FEIS,

Sec. 4.9).

viii. Aircraft Operations

As discussed above and in the FEIS, the proposed action will not

have any significant impacts on commercial or private aircraft

operations within the San Diego region. The Airfield and Airspace

Operational Study for MCAS Miramar was prepared by ATAC Corporation in

1995, and is incorporated in the FEIS by reference. The study

encompassed current and projected future operations and considered

impacts upon both military and civilian users of the airspace in the

greater San Diego area. This study, through the use of the Naval

Aviation Simulation Model (NASMOD), demonstrated that the proposed

quantity of fixed-wing and rotary-wing aircraft can be safely

collocated while operating effectively and efficiently at Miramar.

ix. Socio-Economics

As discussed in the FEIS, the proposed action will not have any

significant local or regional socio-economics impacts (FEIS,

Sec. 4.13). In compliance with Executive Order 12898, an analysis was

conducted to determine if minority or low-income populations would

suffer disproportionately high and adverse environmental impacts as a

result of the proposed action (FEIS, p. 4.13-3). It was determined that

these populations would not suffer disproportional impacts. Two

community planning groups raised questions regarding compliance with

Environmental Justice guidelines with respect to Mira Mesa. The impacts

on Mira Mesa were reexamined and it was confirmed that residents of

Mira Mesa are not being disproportionately affected.

8. Conclusion

On behalf of the Department of the Navy, I have decided to realign

NAS Miramar into MCAS Miramar. I have carefully considered all of the

comments, including those urging further analysis. After reviewing the

administrative record and information received during the environmental

review process, I have determined that no new significant environmental

information or circumstances exist. Consequently, I have determined

that a supplemental EIS is not warranted. I have decided to implement

this action using the West-Ramp configuration (Alternative B), which

was both the Preferred Alternative and also the Environmentally

Preferred Alternative.

9. Where To Obtain Further Information

For further information, contact Lieutenant Colonel George Martin

at (619) 537-6679.

Duncan Holaday,

Deputy Assistant Secretary, Installations and Facilities.

Dated: December 2, 1996.

M.A. Waters,

LCDR, JAGC, USN, Federal Register Liaison Officer.

[FR Doc. 96-31024 Filed 12-5-96; 8:45 am]

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