Redevelopment Agency of the City of Warner Robins, Georgia Georgia Robins Aerospace Maintenance Partnership (G-RAMP) Draft Final Environmental Assessment September 4, 2012 TIHS PAGE INTENTIONALLY LEFT BLANK Prepared for the Redevelopment Agency of the City of Warner Robins, Georgia by AMEC Environment & Infrastructure, Inc. Kennesaw, Georgia TIHS PAGE INTENTIONALLY LEFT BLANK G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 EXECUTIVE SUMMARY The City of Warner Robins (the City) conducted this Environmental Assessment (EA) to identify and assess potential effects of the Proposed Action, which would consist of the construction and operation of the Georgia Robins Aerospace Maintenance Partnership (G-RAMP) project. This EA evaluated the environmental consequences of implementing the Proposed Action and No Action Alternative. As described below, no reasonable alternatives to the Proposed Action were identified. The City proposes to construct the G-RAMP project, which would be a multifaceted partnership between Robins Air Force Base (RAFB) and the community for construction of a new aerospace industrial complex. G-RAMP would be a collaborative effort that would include the City, the Middle Georgia community, private industry, and the Warner Robins Air Logistics Complex (AFSC) to integrate U.S. Air Force (USAF) and private sector sustainment capabilities. The City and AFSC entered into a Strategic Partnership Agreement in 2008 to integrate public and private maintenance and repair operations and to jointly manage and execute aircraft sustainment and shared sustainment capabilities, including education, training, technology, and infrastructure opportunities. The purpose of the Proposed Action is to improve support to the war fighter by pursuing opportunities to enhance the capability and capacity at AFSC. This would be accomplished by fostering cooperation between the City and AFSC, identifying/developing technology for use by involved parties, facilitating innovation and transformation by identifying potential projects and target areas for improvement and opportunities, and leveraging the synergy created by developing public and private capabilities and collaboration. The need for the Proposed Action is to meet contracting and workload constraints. More specifically, the project is needed to provide opportunities for meeting the workload capacity/capability requirements of AFSC, to overcome facilities constraints at AFSC, to reduce costs of facilities ownership for involved parties, and to reduce costs of products produced or maintained at such facilities. As stated in Title 10 U.S. Code Section 2466, Subsection (c), "Not more than 50 percent of the funds made available in a fiscal year to a military department or a Defense Agency for depot-level maintenance and repair workload may be used to contract for the performance by non-Federal Government personnel of such workload for the military department or the Defense Agency. Any such funds that are not used for such a contract shall be used for the performance of depot-level maintenance and repair workload by employees of the Department of Defense." As a result, USAF is responsible for the organic/core workload and the work that cannot be completed through contract. The remaining workload would be taken by private industry groups. Other constraints include the lack of facilities on RAFB to perform aircraft maintenance, repair, and overhaul work and the inability of private industry to use the existing RAFB back shops and support capabilities. Creating Public-private Partnerships (PPPs) would allow RAFB to gain significant improvements while maintaining the strength of the September 4, 2012 ES-1 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 existing industry operations. However, RAFB must overcome facility constraints to achieve the efficiencies afforded by shared sustainment capability. Building the proposed G-RAMP facilities on City-owned land next to RAFB would allow RAFB to create the co-located PPP and to benefit from the sharing of sustainment capabilities. The G-RAMP site (herein referred to as "the Project Site") is located on ?24.5 acres next to the northeast end of RAFB, and is owned by the City. The Project Site is vacant. Historically, since the late 1950s, the City-owned area immediately east of the Project Site has been used for soil borrowing for construction of RAFB projects. Disturbance to surface soils and vegetation occurred on the Project Site as a result of this activity. In addition, an approximate 1-acre cemetery tract is located next to the Project Site near the southern boundary. The City owns the cemetery property and will place a 50-foot buffer around the cemetery's perimeter so that it will remain undisturbed during project implementation. Next to the cemetery is a small concentration of bricks and stones that may be remnants of a farmhouse and approximately 5 acres of overgrown pecan orchard. The City's Ocmulgee River Water Pollution Control Facility No. 1 is located next to the northwest corner of the Project Site. A small portion of the Project Site is located within the 100-year floodplain of the Ocmulgee River. The Proposed Action would involve construction of an aerospace industrial complex, including hangar facilities, ramp space, public infrastructure, and office/professional space for program management. The Proposed Action would use certain RAFB assets to reduce the overall project cost, including the airfield operations, a taxiway connection, and a secured entrance to the base and North Perimeter Road. Improvements would consist of site preparation and grading, infrastructure improvements such as water and sanitary sewer systems to serve the facility, development of a taxiway extension/connection to RAFB, aircraft parking areas, a vehicular access road, and construction of hangar facilities to support RAFB and private contractors. Because the exact footprint of the Proposed Action is not fully known at this time, it is assumed that the 24.5-acre Project Site would be developed. Approximately 450,000 cubic yards of earthwork is anticipated to be moved during site development (mass grading). The site will be graded to allow a finished floor elevation of approximately 266 feet above mean sea level (AMSL), as recommended in the Preliminary Engineering Report (Carter & Sloope 2009). Under the No Action Alternative, construction of the G-RAMP facilities would not occur. There would be no shared assets or shared sustainment and operational capabilities between AFSC and private industry. Therefore, there would be no reduction of costs or increase in aircraft availability. Under the No Action Alternative, aerospace-related jobs would not be created and the Middle Georgia community would not receive economic benefit. The No Action Alternative would not result in significant adverse direct or indirect effects on environmental resource components (Tables ES-1 and 2-1). No reasonable alternatives to the Proposed Action that would be implementable and meet the purpose, need, and objectives for the action were identified. No other City-owned properties that September 4, 2012 ES-2 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 would allow immediate access to the taxiways on RAFB are located along RAFB. This immediate access is needed to allow shared sustainment capabilities between RAFB and the proposed G-RAMP facilities. The Proposed Action represents the minimum area of impact to meet the purpose and need for the action. Therefore, the Proposed Action is the Preferred Alternative, and no other action alternatives are evaluated in detail in this EA. Implementation of the Proposed Action would result in insignificant adverse effects on topography due to grading, with minor effects on stormwater, floodplains, air quality, hazardous/toxic material generation, noise, the biological environment, and transportation. These effects would be largely managed through avoidance or adherence to appropriate local, state, or federal laws and regulations. Impacts to wetlands are not anticipated; however, in the unlikely event that impacts to adjacent wetlands would be deemed necessary during construction activities, the activities would be reduced and would require coordination with the U.S. Army Corps of Engineers (USACE) for permitting and mitigation before ground disturbing within such wetlands. The access route owned by the City into the G-RAMP area follows the present City route of a dirt road to the City water treatment facility. The road crossed the base to the north of the runway, and extends along a route outside the base along the eastern perimeter. The dirt road is above the wetlands/floodplains that are adjacent to the G-RAMP site. Activities related to construction of improvements and vehicular traffic on the road may be expected to expand along the edges of the road into the adjacent wetlands/floodplains. The impacts would be limited to this extent, and would present substantially fewer impacts than might be expected from building a new road through the wetlands/floodplains. Archeological resource surveys (Garrow 1996; CRA 2011) of the Project Site determined that there are no sites potentially eligible for listing on the National Register of Historic Places (NRHP). Should human remains be identified at locations within the area of potential effects (APE) during construction/excavation activities, such activities would cease. As part of 36CFR800.13 (b), construction personnel would be directed to avoid the site of discovery and immediately contact the City. Work in the discovery area would stop until the Project Site could be investigated. The City would coordinate with RAFB to send a qualified representative to visit the discovery site, the resource would be recorded and evaluated, and the effects would be managed as necessary. The Proposed Action would not generate disproportionate adverse human or environmental health impacts on minority or low income populations. No adverse socioeconomic impacts on military or regional populations, the economy, employment, income, housing, community services, or education would result from implementation of the Proposed Action. However, project implementation would result in positive socioeconomic impacts by providing additional economic stimulus to the Middle Georgia region. September 4, 2012 ES-3 G-RAMP Environmental Assessment 1 2 3 4 5 6 Table ES-1 summarizes the project's potential impacts, management actions or Best Management Practices (BMPs), and proposed mitigation measures to be implemented where appropriate. Cumulative impacts on the environment from the incremental impact of the Proposed Action, when added to other past, present, and reasonably foreseeable future actions, also were evaluated and found to be insignificant. September 4, 2012 ES-4 G-RAMP Environmental Assessment Table ES-1 Summary of Potential Impacts, Management Actions or BMPs, and Mitigation Measures No Action Alternative No change to existing conditions. Management Actions or Best Management Practices To Be Implemented The construction fill and topsoil would be obtained from either the Project Site or an existing commercial source fully permitted under applicable laws protecting the environment. Mitigation Measures To Be Implemented None needed. Resource Area Topography Proposed Action The Project Site would be graded. Approximately 450,000 cubic yards of earthwork (cut/fill) is anticipated. Excavation would be required in the area of Joint Stars Road for the taxiway connection and for the proposed access road. Minor ground disturbance would be required for the replacement of the 6-inch water supply main. A Land Disturbing Activity Permit would be obtained from Houston County. The permit would include a Notice of Intent for permit coverage under National Pollutant Discharge Elimination System (NPDES) Permit GAR100001 (approval to discharge stormwater associated with construction activity). As required by the NPDES permit, an Erosion, Sediment, and Pollution Control Plan (ESPCP) would be developed and implemented. Implementation of the Proposed Action would not result in either significant adverse or positive effects on surface waters because construction activities would not occur in or next to natural surface water bodies. Surface Waters No change to existing conditions. BMPs such as silt fencing, hay bales, and erosion control blankets would be used during construction to control land disturbance and stormwater runoff. None needed. September 4, 2012 ES-5 G-RAMP Environmental Assessment Resource Area Floodplains and Wetlands No Action Alternative No change to existing conditions. Proposed Action The Proposed Action could fill a small portion of the floodplain within the Project Site. Filling the floodplain would not significantly alter flood elevations. No other construction activities (e.g. access route, water supply main route) occur within the floodplain. The Proposed Action is not anticipated to impact wetland features. Wetlands would be avoided to the extent possible. Land disturbance permits would be required, as described in Section 4.1.1. Management Actions or Best Management Practices To Be Implemented Before activity, the City must evaluate and approve this action, while USAF must investigate the potential alternatives that would avoid working within the floodplain. Although not anticipated, impacts to adjacent jurisdictional wetland areas would require a Preconstruction Notification (PCN) to be prepared/submitted before ground disturbing activities. Impacts to the floodplain would require a Letter of Map Revision from the City to the Federal Emergency Management Agency. BMPs for protecting surface water from sedimentation effects would be in place during construction. Construction design of the proposed stormwater treatment pond would require consideration of 11 minimum standards outlined in the Georgia Stormwater Management Manual (Appendix C). The Proposed Action would comply with Section 438 of the 2007 Energy Independence and Security Act requiring use of low-impact development techniques during construction. Mitigation Measures To Be Implemented If necessary as part of PCN submittal, mitigation for impacts on wetlands would be documented. Proposed wetland mitigation would likely consist of the purchase of mitigation credits from a USACE-approved wetland mitigation bank. Stormwater No change to existing conditions. Implementation of the Proposed Action would result in an increase in the volume of stormwater runoff because construction activities would increase the impervious surface within the Project Site. NPDES Permit GAR100001 (approval to discharge stormwater associated with construction activity) would be obtained. As a part of the NPDES permit, an ESPCP would be prepared and submitted. A storm drainage collection system is proposed to collect surface drainage from the Project Site. The storm sewer system would include drop inlet structures, trench drains, and connecting storm sewer piping. The piping system would discharge the stormwater into a proposed stormwater treatment pond. None needed. September 4, 2012 ES-6 G-RAMP Environmental Assessment Resource Area Geology and Soils No Action Alternative No change to soils or the existing geologic environment. Proposed Action Implementation of the Proposed Action would not result in significant adverse or positive effects on geologic features because construction activities would occur at or near the ground surface. Management Actions or Best Management Practices To Be Implemented BMPs applied during construction activities, such as silt fencing, hay bales, and erosion blankets, would control soil erosion and avoid significant adverse effects on the quality of stormwater runoff. Not applicable. Mitigation Measures To Be Implemented None needed. Groundwater No change to existing conditions. Project implementation is not anticipated to adversely affect groundwater resources because subsurface water levels were determined to be below current elevations and would not be disturbed. Implementation of the Proposed Action would not adversely affect the existing local water supply because the supply would not experience significant impacts. None needed. Water Supply and Drinking Water No changes to existing resources. Not applicable. None needed. September 4, 2012 ES-7 G-RAMP Environmental Assessment Resource Area Air Quality No Action Alternative No change to existing conditions. Proposed Action Construction activities would temporarily increase emissions of carbon monoxide, hydrocarbons, and nitrogen dioxide. Implementation of the Proposed Action would increase air emissions because there would be increased emissions from employee personal vehicles and potentially from painting and depainting operations, solvent cleaning, and chromium plating and anodizing. Other potential sources would include fuel storage tanks, peaking power generators, boilers, and various sources of fugitive volatile organic compounds. Project implementation (maintenance, repair, and operations work on up to two C-17 or C-5 aircraft) is not expected to significantly impact air quality in the region. Management Actions or Best Management Practices To Be Implemented Air quality BMPs would be implemented during construction and would include emissions standards for construction equipment and procedures for wetting disturbed portions of the project areas to control dust emissions. It is anticipated that the amount of emissions would not result in violations of National Ambient Air Quality Standards. If PTE emissions of PM2.5, PM10, SO2, CO, NOx, or VOC exceed 100 tons per year or if total HAPs exceed 25 tons per year, or an individual HAP PTE exceeds 10 tons per year, a major source Title V operating permit must be obtained. Generated industrial wastewater would comply with the City's Wastewater Pretreatment Program for industrial discharges. Should industrial wastewater be generated at the Proposed Project, such wastewater would be in compliance with the City's Wastewater Pretreatment Program for industrial dischargers. Mitigation Measures To Be Implemented None needed. Wastewater No change to existing conditions. Based on assumption of 150 new employees at the Project Site, no significant impacts on the City's Ocmulgee River Wastewater Treatment Plant No. 1 are anticipated based on the plant's capacity of 3 million gallons per day (MGD) and the current operating average of approximately 1.2 to 1.5 MGD. It is not anticipated that industrial wastewater would be generated at the proposed facilities. None needed. September 4, 2012 ES-8 G-RAMP Environmental Assessment Resource Area Solid Waste No Action Alternative No change to existing conditions. Proposed Action Generated solid waste would be similar in amount and type to that generated by similar operations at RAFB, and would be insignificant considering the population in the Warner Robins Metropolitan Statistical Area and the number of personnel at RAFB. The Proposed Action may result in the generation of hazardous wastes including petroleum products, such as hydraulic fluid mixed with used oil and hydraulic fluid mixed with solvent. Hazardous waste generation is anticipated to be comparable to that of existing hangar facilities at RAFB. Management Actions or Best Management Practices To Be Implemented Solid wastes would be recycled to the extent possible, and waste materials containing polychlorinated biphenyls (PCBs), asbestos, or lead would be handled in accordance with applicable regulations. Generated hazardous waste would be managed and disposed of pursuant to the Resource Conservation and Recovery Act (RCRA) (Title 40 Code of Federal Regulations [CFR] Part 262) and Georgia Rule 391-311, and stored and handled in accordance with Occupational Safety and Health Administration (OSHA) regulations, 29 CFR 1910.1200(e)-(h). Under RCRA, hazardous waste generators are required to notify the Georgia Environmental Protection Division of regulated waste activities. The hazardous waste generator would be required to obtain a U.S. Environmental Protection Agency (USEPA) Identification Number by completing and submitting USEPA Form 870012 for initial notifications. A storage permit is not required for storage of hazardous waste under 90 days. Mitigation Measures To Be Implemented None needed. Hazardous Materials and Waste No change in current generation of wastes. None needed. September 4, 2012 ES-9 G-RAMP Environmental Assessment Resource Area Toxic Materials No Action Alternative Asbestoscontaining material (ACM) or lead-based paint (LBP) is unlikely to be present within the location of an old abandoned home site on the Project Site. PCBcontaining materials are not present on the Project Site. No change to existing conditions. Proposed Action Implementation of the Proposed Action would have no significant adverse or positive effects on toxic materials or toxic waste, or the environment as it relates to these materials. Operation of the hangar facilities would not involve the use of equipment containing PCBs, ACM, or LBP. Management Actions or Best Management Practices To Be Implemented ACM or LBP within remnants of the abandoned home would be assessed by pre-demolition inspections/surveys. If susceptible materials are encountered, these materials would be tested and characterized, and if identified as ACM or LBP the toxic materials or waste would be removed, managed, and disposed of in accordance with applicable regulations. Mitigation Measures To Be Implemented None needed. Noise Environment Construction would occur in and near the elevated noise environment of the flight line area (Taxiway E) or along existing roadways (access route and water supply main route). Noise from future operations at the new hangar facilities would be generally consistent with noise from existing and surrounding operations. Personnel at the new facilities would be exposed to noise from the aircraft at the Project Site, from surrounding streets, and from the nearby airfield at RAFB. Construction near receptors within City limits would abide the City's noise ordinance. Construction personnel would wear ear protection in accordance with U.S. Department of Defense (DoD) and OSHA health and safety requirements. Personnel would expect elevated noise levels and would be protected in accordance with DoD and OSHA health and safety requirements. None needed. September 4, 2012 ES-10 G-RAMP Environmental Assessment Resource Area Biological Environment No Action Alternative No change to existing conditions. Proposed Action Implementation of the Proposed Action would not result in adverse effects on endangered, threatened, or sensitive species because these species are not expected to occur. Habitats supporting these species are not present within the Project Site or along the access route/water supply main route; however, potential habitat for some species is located next to the Project Site. The alligator snapping turtle has not been observed on the Project Site and the likelihood for occurrence is highly unlikely as it has not been recorded in Houston County. Bald eagles and wood storks have been previously observed at RAFB or on/near the Project Site, but do not nest or roost on the Project Site. Impacts on common wildlife species would include an increase in noise and traffic, and loss of habitat. The Project Site is highly disturbed from historical soil borrowing, logging, and clearing activities that occurred either on site or next to the site. Therefore, high-quality habitat and significant vegetation and wildlife resources are not present throughout most of the Project Site. Management Actions or Best Management Practices To Be Implemented If protected species are observed during construction, construction activities in the immediate vicinity would cease, and the construction manager would immediately contact the City. The City would coordinate with RAFB and send a qualified representative to visit the discovery site, the resource would be recorded and evaluated, and appropriate avoidance measures would be implemented as necessary. Mitigation Measures To Be Implemented None needed. September 4, 2012 ES-11 G-RAMP Environmental Assessment Resource Area Cultural Resources No Action Alternative No change to existing conditions. Proposed Action No sites potentially eligible for listing on the NRHP have been identified on the Project Site. Therefore, implementation of the Proposed Action would not result in significant adverse or positive effects on cultural resources within the Project Site. The Proposed Action has been fully coordinated under provisions of the National Historic Preservation Act, Section 106. Management Actions or Best Management Practices To Be Implemented Should human remains be identified during construction, excavation activities would cease and plans would be developed to address the discovery. While not an eligible NRHP site, the Wellston cemetery would be protected from disturbance with a 50-foot undisturbed buffer and a new permanent fence that would be installed before construction. Not applicable. Mitigation Measures To Be Implemented None needed. Socioeconomic Environment No change to existing conditions. The Proposed Action would provide additional economic stimulus to the Middle Georgia region, resulting in positive impacts on the socioeconomic environment, including creation of up to 150 new jobs at the new facility. No adverse disproportionate effects on minority or low-income populations would occur. There would be a temporary, insignificant increase in traffic from construction vehicles, including trucks hauling clean fill material to be placed on the Project Site. Traffic may be a temporary, insignificant impact during replacement of the water supply main. The number of additional personnel (up to 150 new jobs) is anticipated to be insignificant considering the existing traffic from the approximately 25,584 people who access RAFB daily. None needed. Transportation No change to existing conditions. The City would jointly develop and coordinate a Construction Vehicle Traffic Plan with airport users, air traffic control, and the appropriate construction engineers and contractors. None needed. September 4, 2012 ES-12 G-RAMP Environmental Assessment Resource Area Safety No Action Alternative No change to existing conditions. Proposed Action The Proposed Action would have no significant adverse or positive effect on safety. Management Actions or Best Management Practices To Be Implemented USAF personnel working at the Project Site are protected by observing OSHA, Air Force Occupational Safety and Health (AFOSH) standards, and RCRA. Non-military personnel would also be protected by observing OSHA regulations. Aircraft flight operations and patterns associated with RAFB would be conducted in accordance with RAFB's flight operation and safety procedures. Mitigation Measures To Be Implemented None needed. September 4, 2012 ES-13 G-RAMP Environmental Assessment TABLE OF CONTENTS Page EXECUTIVE SUMMARY............................................................................................................. 1 1.0 INTRODUCTION, PURPOSE AND NEED FOR ACTION.................................................... 1 1.1 1.2 1.3 1.4 1.5 2.1 2.2 2.3 2.4 2.5 3.1 INTRODUCTION .............................................................................................................................. 1 PURPOSE AND NEED FOR THE ACTION .......................................................................................... 3 OBJECTIVES ................................................................................................................................... 4 PROJECT REQUIREMENTS .............................................................................................................. 4 EARLY COORDINATION ................................................................................................................. 5 PROJECT LOCATION ...................................................................................................................... 5 2.1.1 Current Access .................................................................................................................. 8 2.1.2 Land Use ........................................................................................................................... 8 PROPOSED ACTION ........................................................................................................................ 8 NO ACTION ALTERNATIVE.......................................................................................................... 13 ALTERNATIVES CONSIDERED AND ELIMINATED FROM FURTHER CONSIDERATION .................. 14 COMPARISON OF POTENTIAL EFFECTS ........................................................................................ 14 PHYSICAL ENVIRONMENT ........................................................................................................... 15 3.1.1 Topography ..................................................................................................................... 15 3.1.2 Surface Waters ................................................................................................................ 16 3.1.3 Floodplains and Wetlands ............................................................................................... 16 3.1.4 Stormwater ...................................................................................................................... 17 3.1.5 Geology and Soils ........................................................................................................... 19 3.1.6 Groundwater ................................................................................................................... 19 3.1.7 Water Supply and Drinking Water.................................................................................. 20 AIR QUALITY............................................................................................................................... 21 3.2.1 Regional Air Quality ....................................................................................................... 22 3.2.2 Air Emission Sources ...................................................................................................... 22 WASTE MANAGEMENT AND TOXIC MATERIALS ........................................................................ 23 3.3.1 Wastewater ...................................................................................................................... 23 3.3.2 Solid Waste ..................................................................................................................... 23 3.3.3 Hazardous Materials and Waste ...................................................................................... 24 3.3.4 Toxic Materials ............................................................................................................... 24 NOISE ENVIRONMENT ................................................................................................................. 25 BIOLOGICAL ENVIRONMENT ....................................................................................................... 25 CULTURAL RESOURCES .............................................................................................................. 31 SOCIOECONOMIC ENVIRONMENT ................................................................................................ 33 3.7.1 Economic Activity and Population ................................................................................. 34 3.7.2 Environmental Justice ..................................................................................................... 35 TRANSPORTATION ....................................................................................................................... 35 SAFETY ........................................................................................................................................ 37 PHYSICAL ENVIRONMENT ........................................................................................................... 37 4.1.1 Topography ..................................................................................................................... 37 4.1.2 Surface Waters ................................................................................................................ 38 4.1.3 Floodplains and Wetlands ............................................................................................... 39 4.1.4 Stormwater ...................................................................................................................... 40 4.1.5 Geology and Soils ........................................................................................................... 42 2.0 DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES ..................................... 5 3.0 AFFECTED ENVIRONMENT .............................................................................................. 15 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 4.1 4.0 ENVIRONMENTAL EFFECTS ............................................................................................ 37 September 4, 2012 G-RAMP Environmental Assessment 4.1.6 Groundwater ................................................................................................................... 43 4.1.7 Water Supply and Drinking Water.................................................................................. 43 4.2 AIR QUALITY............................................................................................................................... 44 4.2.1 No Action Alternative ..................................................................................................... 44 4.2.2 Proposed Action .............................................................................................................. 44 4.3 WASTE MANAGEMENT AND TOXIC MATERIALS ........................................................................ 45 4.3.1 Wastewater ...................................................................................................................... 45 4.3.2 Solid Waste ..................................................................................................................... 46 4.3.3 Hazardous Materials and Waste ...................................................................................... 47 4.3.4 Toxic Materials ............................................................................................................... 48 4.4 NOISE ENVIRONMENT ................................................................................................................. 48 4.4.1 No Action Alternative ..................................................................................................... 48 4.4.2 Proposed Action .............................................................................................................. 48 4.5 BIOLOGICAL ENVIRONMENT ....................................................................................................... 49 4.5.1 No Action Alternative ..................................................................................................... 49 4.5.2 Proposed Action .............................................................................................................. 49 4.6 CULTURAL RESOURCES .............................................................................................................. 50 4.6.1 No Action Alternative ..................................................................................................... 50 4.6.2 Proposed Action .............................................................................................................. 50 4.7 SOCIOECONOMIC ENVIRONMENT ................................................................................................ 51 4.7.1 No Action Alternative ..................................................................................................... 52 4.7.2 Proposed Action .............................................................................................................. 52 4.8 TRANSPORTATION ....................................................................................................................... 54 4.8.1 No Action Alternative ..................................................................................................... 54 4.8.2 Proposed Action .............................................................................................................. 54 4.9 SAFETY ........................................................................................................................................ 55 4.9.1 No Action Alternative ..................................................................................................... 55 4.9.2 Proposed Action .............................................................................................................. 55 4.10 CUMULATIVE IMPACTS ........................................................................................................... 55 5.0 CONCLUSIONS..................................................................................................................... 60 6.0 LIST OF PREPARERS ........................................................................................................... 62 7.0 PERSONS CONTACTED ...................................................................................................... 63 8.0 REFERENCES ....................................................................................................................... 64 LIST OF TABLES TABLE ES-1 TABLE 2-1 TABLE 3-1 TABLE 3-2 SUMMARY OF POTENTIAL IMPACTS, BMPS, AND MITIGATION MEASURES ... ES-5 COMPARISON OF ALTERNATIVES RECEIVING DETAILED EVALUATION ............. 14 NATIONAL AMBIENT AIR QUALITY STANDARDS .............................................. 21 FEDERALLY AND STATE-PROTECTED ANIMAL AND PLANT SPECIES OCCURRING WITHIN HOUSTON COUNTY AND THE SURROUNDING COUNTIES OF BIBB, BLECKLEY, DOOLY, MACON, PEACH, PULASKI, AND TWIGGS, GEORGIA ............................................................................................ 28 LIST OF FIGURES FIGURE 1 FIGURE 2 FIGURE 3 SITE LOCATION MAP ............................................................................................... 6 ACCESS ROUTE ........................................................................................................ 7 PROPOSED ACTION - CONCEPTUAL SITE PLAN ...................................................... 10 September 4, 2012 G-RAMP Environmental Assessment FIGURE 4 FIGURE 5 FIGURE 6 LOCATION OF WATER SUPPLY MAIN ..................................................................... 12 DELINEATED WETLANDS ....................................................................................... 18 PROPERTY OWNERSHIP ALONG ACCESS ROUTE ..................................................... 36 LIST OF APPENDICES APPENDIX A FACILITIES REQUIREMENTS FOR MILITARY AIRCRAFT APPENDIX B APPENDIX C AGENCY AND TRIBAL COORDINATION AND RESPONSES MINIMUM STANDARDS FROM GEORGIA STORMWATER MANAGEMENT MANUAL APPENDIX D DOD POLICY MEMORANDUM OUTLINING REQUIREMENTS UNDER EISA APPENDIX E APPENDIX F NOTICE OF DECISION, NO FURTHER ACTION, GA EPD EXECUTIVE SUMMARY OF PHASE II ARCHEOLOGICAL SURVEY REPORT APPENDIX G MINSHEW-THOMAS-SULLIVAN (WELLSTON) CEMETERY DELINEATION REPORT September 4, 2012 G-RAMP Environmental Assessment ACRONYMS ACM ACW AFSC AFOSH AICUZ AMSL APE BEA BMPs BTEX CAA CEQ CFR CO CRA CWA CZ dB DNL DoD EA EIS EISA EO ESA ESPCP FEMA FIRM FONSI FONPA GA EPD GCZ GDNR GHG G-RAMP GSWCC HAP HPD HUC Asbestos-containing Material Air Control Wing Warner Robins Air Logistics Complex Air Force Occupational Safety and Health Air Installation Compatible Use Zone Mean Sea Level Area of Potential Effects Bureau of Economic Analysis, U.S. Best Management Practices Benzene, Toluene, Ethylbenzene, Xylene Clean Air Act Council on Environmental Quality Code of Federal Regulations Carbon Monoxide Cultural Resources Analysts, Inc. Clean Water Act Clear Zone Decibels Day-Night Average Noise Level Department of Defense Environmental Assessment Environmental Impact Statement Energy Independence and Security Act Executive Order Environmental Site Assessment Erosion, Sediment, and Pollution Control Plan Federal Emergency Management Agency Flood Insurance Rate Map Finding of No Significant Impact Finding of No Practicable Alternative Georgia Environmental Protection Division Graded Clear Zone Georgia Department of Natural Resources Greenhouse Gas Georgia Robins Aerospace Maintenance Partnership Georgia Soil and Water Conservation Commission Hazardous Air Pollutant Historic Preservation Division Hydrologic Unit Code September 4, 2012 G-RAMP Environmental Assessment ACRONYMS (Continued) ILCM INRMP IP ISWM JD LBP LEED LID LiDAR LOMR MEK MGD MIBK MRO MSA MSG NAAQS NEPA NFA NHPA NO2 NOD NOI NPDES NRCS NRHP NWP O3 OSHA Pb PCBs PCN PM PM2.5 PM10 PPP PSD PTE RAFB Integrated Life Cycle Management Integrated Natural Resources Management Plan Individual Permit Integrated Solid Waste Management Jurisdiction Determination Lead-based Paint Leadership in Energy and Environmental Design Low Impact Development Light Detection and Ranging Letter of Map Revision Methyl Ethyl Ketone Million Gallons per Day Methyl Isobutyl Ketone Maintenance Repair and Overhaul Metropolitan Statistical Area Mission Support Group National Ambient Air Quality Standard National Environmental Policy Act No Further Action National Historic Preservation Act Nitrogen Dioxide Notice of Decision Notice of Intent National Pollutant Discharge Elimination System Natural Resources Conservation Service National Register of Historic Places Nationwide Permit Ozone Occupational Safety and Health Administration Lead Polychlorinated Biphenyls Pre-Construction Notification Particulate Matter Particles with Diameters of 2.5 Micrometers or Less Particles with Diameters of 10 Micrometers or less Public-Private Partnerships Prevention of Significant Deterioration Potential to Emit Robins Air Force Base September 4, 2012 G-RAMP Environmental Assessment ACRONYMS (Continued) RCRA RFI ROW SIP SO2 TCE the City the Project Site USACE USAF USC USCB USEPA USFWS USGS VOCs WTE Resource Conservation and Recovery Act RCRA Facility Investigation Right-of-Way State Implementation Plan Sulfur Dioxide Trichloroethylene City of Warner Robins the G-RAMP site U.S. Army Corps of Engineers U.S. Air Force U.S. Code U.S. Census Bureau U.S. Environmental Protection Agency U.S. Fish and Wildlife Service U.S. Geological Survey Volatile organic compounds Waste-to-Energy September 4, 2012 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 1.0 INTRODUCTION, PURPOSE AND NEED FOR ACTION 1.1 Introduction This Environmental Assessment (EA) was prepared to assess the predicted environmental impacts associated with the proposed Georgia Robins Aerospace Maintenance Partnership (GRAMP) project (Proposed Action). G-RAMP is a multifaceted partnership between Robins Air Force Base (RAFB) and the community for construction of a new aerospace industrial complex. This is a collaborative effort that includes the City of Warner Robins (the City), the U.S. Department of Defense (DoD), the Middle Georgia Regional Development Center, the Houston County Board of Commissioners, 21st Century Partnership, the Houston County Development Authority, and private sector partners. The City acquired ?544 acres next to the north end of RAFB through a land swap with the State of Georgia. On a preliminary basis, the City determined that ?24.5 acres closest to RAFB would be the most suitable for development. The Proposed Action would involve construction of an aerospace industrial complex, including hangar facilities, ramp space, public infrastructure, and office/professional space for program management. The City and the Warner Robins Air Logistics Complex (AFSC) entered into a Strategic Partnership Agreement on July 22, 2008, to integrate public and private maintenance and repair operations and to jointly manage and execute aircraft sustainment and shared sustainment capabilities, including education, training, technology, and infrastructure opportunities. The GRAMP complex would facilitate the Public-private Partnership (PPP) between AFSC and private industry to share weapons system sustainment capabilities, thereby improving aircraft availability and reducing costs. The complex would be used for aircraft maintenance, repair, and overhaul (MRO) activities. G-RAMP offers the opportunity for partnership between the State of Georgia, the Middle Georgia community, private industry, and AFSC to integrate USAF and private sector sustainment capabilities by providing more efficient and economical support of the war fighter. It is based on the premise that there is a better way to perform integrated life cycle management (ILCM) based on shared capacity and capability. Candidate G-RAMP workload includes, but is not limited to, on-aircraft maintenance for USAF, Army, Navy, and Marines; aircraft modification design and installation; overflow aircraft depot-level maintenance; and other related aircraft maintenance from Foreign Military Sales and Special Operations Command Requirements. G-RAMP may include organic (military, non-private sector resources) and nonorganic workload on various aircraft, including, but not limited to, C-130, C-17, and C-5 aircraft. The following chart developed by AFSC summarizes the G-RAMP concept: September 4, 2012 1 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 As stated in Title 10 U.S. Code (USC) Section 2466, Subsection (c), "Not more than 50 percent of the funds made available in a fiscal year to a military department or a Defense Agency for depot-level maintenance and repair workload may be used to contract for the performance by non-Federal Government personnel of such workload for the military department or the Defense Agency. Any such funds that are not used for such a contract shall be used for the performance of depot-level maintenance and repair workload by employees of the Department of Defense." As such, USAF is responsible for the organic/core workload and the work that cannot be completed through contract. Workload exceeding the capacity/capability of AFSC is typically contracted to private sector industry. Other constraints include the lack of facilities at RAFB to perform MRO work and the inability of private industry to use the existing RAFB back shops and support capabilities. Creating PPPs would allow RAFB to gain significant improvements while maintaining the strength of the existing industry operations. However, RAFB must overcome facility constraints to achieve the efficiencies afforded by shared sustainment capability. Building the proposed G-RAMP facilities on City-owned land next to RAFB would allow RAFB to create the co-located PPP and to benefit from the sharing of sustainment capabilities. The Proposed Action would be consistent with the State of Georgia's strategic industries and the development of the "aerospace corridor" in Georgia. Today, there are more than 84,500 Georgians employed in the aerospace industry, with an annual aerospace payroll of $5.2 billion (2009). Georgia's diverse aerospace industry features more than 500 organizations that specialize in the facets of aerospace: research and development, original equipment manufacturers, MRO companies, and global aircraft fleet operations. AFSC is the largest industrial complex in Georgia, with an estimated economic impact of $4.1 billion annually. In summary, benefits from the Proposed Action would include the following: September 4, 2012 2 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 o o o o o o o o o Enable compliance with DoD and Air Force Materiel Command guidance on PPPs Increase aircraft availability Reduce operational and sustainment costs Create capacity for new workloads at AFSC Improve depot maintenance productivity Enable improved ILCM Maintain DoD and commercial industrial base viability Create jobs Foster regional economic growth and stability This EA was prepared pursuant to the National Environmental Policy Act (NEPA) of 1969, as amended, which requires federal agencies to consider environmental impacts in their decisionmaking process. This EA evaluates the potential for environmental consequences of the Proposed Action associated with the development of the G-RAMP facilities next to RAFB, in accordance with the President's Council on Environmental Quality (CEQ) regulations for implementing NEPA (Title 40 Code of Federal Regulations [CFR] 1500-1508) and U.S. Air Force (USAF) regulations for the Environmental Impact Analysis Process (32 CFR 989). These federal regulations establish the administrative process and substantive scope of the environmental impact evaluation, designed so that deciding authorities have a proper understanding of the potential environmental consequences of a contemplated course of action. The purpose of this EA is to determine whether the Proposed Action would constitute a major federal/state action that could significantly affect the environment, requiring the preparation and distribution of an Environmental Impact Statement (EIS) for public review. If it is determined that this action would not significantly affect the environment after incorporation of management actions and mitigation measures, a Finding of No Significant Impact (FONSI) and Finding of No Practicable Alternative (FONPA) would be prepared and issued. A FONPA is required for impacts to wetlands and floodplain pursuant to Executive Orders 11988, Floodplain Management, and 11990, Protection of Wetlands, and the authority delegated by Secretary of the Air Force, Order 791.1. This EA is based on a combination of preliminary design reports, technical studies, engineering analysis, and existing environmental documents. People contacted for collection of needed information are listed in Section 7.0. References for this document are listed in Section 8.0. 1.2 Purpose and Need for the Action The purpose of the Proposed Action is to improve support to the war fighter by pursuing opportunities to enhance the capability and capacity at AFSC. The need of the Proposed Action is to provide opportunities for meeting the workload capacity/capability requirements of AFSC, to overcome facilities constraints at AFSC, to reduce costs of facilities ownership for involved parties, and to reduce costs of products produced or maintained at such facilities. September 4, 2012 3 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 1.3 Objectives NEPA requires that a decision made with respect to the Proposed Action be based on analysis of a reasonable range of alternatives that are likely to meet project objectives. Objectives are specific statements of purpose that describe what must be accomplished for a project to be considered a success. Alternatives selected for detailed analysis must meet these objectives to a large degree, and fulfill the project purpose and need for action. The following objectives were developed to guide preparation of the EA: o o o Create a partnership between AFSC and private industry to enhance AFSC capability to increase aircraft availability and reduce sustainment costs Enhance State of Georgia aerospace workforce development and aerospace technology development capabilities Create aerospace facilities in Georgia suitable for aerospace MRO work To meet these objectives, the Proposed Action would: o o o o Support AFSC sustainment requirements Be enduring and applicable to typical system sustainment requirements Comply with/enhance USC Title 10 requirements Be cost-advantageous 1.4 Project Requirements In addition to federal and state environmental requirements, the Proposed Action would be required to comply with federal and USAF requirements pertaining to flight line, ramp, and taxiways, and several USAF requirements regarding security, safety, processes, and space and equipment specifications that would be the responsibility of the facilities owner. A general list of facility requirements required to conduct military aircraft work is in Appendix A. Several requirements identified for the evaluation of alternatives were based on fulfilling the purpose of developing the proposed G-RAMP facilities. The proposed alternatives that merit detailed evaluation would meet the following criteria, which support the purpose and need for the Proposed Action: o o o Ability to provide adequate space to accommodate an aerospace industrial complex, including hangar facilities, public infrastructure, and office/professional space. Right of entry into RAFB, allowing access for due diligence and construction. An ROW agreement from RAFB would be required for access to the finished G-RAMP facilities. Compliance with DoD minimum force protection construction standards as outlined in DoD Minimum Antiterrorism Standards for Buildings (DoD 2003): September 4, 2012 4 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 - A building greater than 150 feet from the controlled perimeter, and a site large enough for a 33-foot standoff distance from the structure. - Fencing and construction materials shall not penetrate any part of Taxiway E. Further, in accordance with the USAF Sustainable Design and Development policy dated July 31, 2007, USAF construction projects, regardless of scope or funding source, shall endeavor to use the U.S. Green Building Council's Leadership in Energy and Environmental Design (LEED) Green Building Rating Systems as their self-assessment metric. This is consistent with the Energy Policy Act of 2005 and Executive Order (EO) 13423. Beginning in Fiscal Year 2009, 100 percent of each Major Command's Military Construction vertical construction projects, with climate control, shall be designed so that they can achieve LEED Silver certification. 1.5 Early Coordination The City notified federal and state agencies and Indian tribes of the intent to perform an EA for the proposed construction of G-RAMP. Copies of notification letters and responses are included in Appendix B. 2.0 DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES This section describes the Proposed Action and No Action Alternative, presents the considerations used for selecting alternatives, and summarizes the environmental consequences of implementing the Proposed Action and No Action Alternative. 2.1 Project Location RAFB is in Houston County in central Georgia, approximately 100 miles southeast of Atlanta, 18 miles south of Macon, and immediately east of the City of Warner Robins. The location of the proposed Project Site is next to the northeast end of RAFB, approximately 400 feet east of Taxiway E and north of an existing parking lot (the Project Site) (Figure 1). The Project Site, approximately 24.5 acres, is part of 544 acres owned by the City. The Project Site is generally bounded by RAFB to the west and south and by the Oaky Woods Wildlife Management Area to the north and east. The City's Ocmulgee River Water Pollution Control Facility No. 1 is located next to the northwest corner of the Project Site. Further, a City- owned sewage force main extends along the northern Project Site boundary next to an existing dirt road that follows the tree line. A portion of the Project Site is located within the 100-year floodplain of the Ocmulgee River. The west bank of the river is located ?3,000 feet from the northeast boundary of the Project Site. North Perimeter Road and Joint Stars Road travel just outside the west and south boundaries of the Project Site, respectively. A City-owned gravel access road, inclusive of a 50foot right-of-way (ROW), extends around the north end of RAFB from the City's Ocmulgee River Water Pollution Control Facility No. 1 to North Davis Drive west of RAFB. This gravel road is located outside RAFB and parallels North Perimeter Road, which is located within RAFB (Figure 2). September 4, 2012 5 G--RAMP Environmental Assessment Gravel Access Road Rivet Ocmulgee River -, it- `ii1>>'fi2:Legend .i6i t'S FEMA ?i=ir30 years of age, preferably >10 inches dbh. Primarily feed in fresh and brackish wetlands and nest in cypress or other wooded swamps. Roosting locations typically include cypress "heads" or swamps, mangrove islands, expansive willow thickets or small, isolated willow "islands" in broad marshes. No Nesting, Roosting, Foraging No Nesting, Foraging E E Wood stork (Mycteria americana) Bi, Bl E E Yes Resting Only REPTILES Alligator snapping turtle (Macroclemys temminckii) Do, Ma NFS T Rivers, lakes, and large ponds near stream swamps. Restricted to the Apalachicola River and larger tributaries including the Chipola, Chattahoochee, and Flint Rivers in east Alabama, west Georgia, and west Florida. Well-drained, sandy soils in forest and grassy areas; associated with pine overstory, open understory with grass and forb groundcover, and sunny areas for nesting. No Barbour's map turtle (Graptemys barbouri) Do, Ma NFS T No Gopher tortoise (Gopherus polyphemus) Bi, Bl, Do, Ho, Ma, Pu NFS T No September 4, 2012 28 G-RAMP Environmental Assessment Species Name (Scientific Name) INVERTEBRATES County1 Federal Status2 State Status3 Preferred Habitat Habitat Available in Project Area? Fat three-ridge mussel (Amblema neislerii) Ma E E Main channels of small to large rivers with slow to moderate currents, in substrates ranging from gravel to a rocky rubble mixture of sand and sandy mud to a mixture of sand, sandy/clay substrates. Medium streams to large rivers with slight to moderate current over sand and gravel substrates; may be associated with muddy sand substrates around tree roots. River tributaries and main channels in slow to moderate currents over silty sand, muddy sand, sand, and gravel substrates. Main channels of ACF basin rivers in moderate currents over sand, sand mixed with mud, or gravel substrates. Medium creeks to the mainstreams of rivers with slow to moderate currents over sandy substrates and associated with rock or clay. No Gulf moccasinshell mussel (Medionidus pencillatus) Oval pigtoe mussel (Pleurobema pyriforme) Purple bankclimber mussel (Elliptoideus sloatianus) Shiny-rayed pocketbook mussel (Hamiota subangulata) FISHES Bluestripe shiner (Cyprinella callitaenia) PLANTS Do E E No Do, Ma E E No Do, Ma T T No Do, Ma E E No Do, Ma NFS T Found in brownwater streams. No Buckthorn (Sideroxylon thornei) Pu NFS E Oak flatwoods where soil normally is saturated for long periods after floods/heavy rain (i.e., calcareous swamps; woods bordering cypress ponds). Peaty muck of shallow cypress ponds, wet pine savannahs, and adjacent sloughs and drainage ditches. No Canby's dropwort (Oxypolis canbyi) Do E E No September 4, 2012 29 G-RAMP Environmental Assessment Species Name (Scientific Name) County1 Federal Status2 State Status3 Dwarf witch-alder (Fothergilla gardenia) Ma NFS T Preferred Habitat Low, flat, swampy areas, especially shrub-dominated margins of upland swamps (pocosins), Carolina bays, pitcher-plant bogs, wet savannahs, and Atlantic whitecedar swamps. In low woods, rocky and gravelly shores, and along stream beds. Mature hardwood or hardwoodpine forests on river bluffs, small stream terraces, moist slopes and well-shaded ridge crests. Open seepy meadows, along sandy flushed banks of streams, and in partially shaded red mapleblackgum low woods or poorly drained oak-pine flatwoods. Seeps on granite outcrops in the Piedmont; wet savannahs, ditches, and peaty fringes of pineland pools and cypress ponds in the Coastal Plain. Dry open upland forests of mixed hardwood and pine. Forested terraces, hardwood slopes and riverbanks of tributaries to the Ocmulgee, Oconee, and Savannah Rivers. Rocky acidic woods along streams with mountain laurel; rarely in drier upland oakhickory-pine woods. Hardwood forests; in the Piedmont, found in either rich ravines or adjacent alluvial terraces with other springflowering herbs. Acid soils of open bogs, sandhill seeps, Atlantic white-cedar swamps, wet savannahs, low areas in pine flatwoods, and along sloughs and ditches. Habitat Available in Project Area? No Florida willow (Salix floridana) Fringed campion (Silene polypetala) Pu Bi, Ho, Tw NFS E No E E No Green pitcher-plant (Sarracenia oreophila) Bi E E No Harperella (Ptilimnium nodosum) Indian olive (Nestronia umbellula) Ocmulgee skullcap (Scutellaria ocmulgee) Piedmont barren strawberry (Waldsteinia lobata) Do E E No Ma, Pe Bi, Bl, Ho NFS T No NFS T No Bi, Tw NFS T No Relict trillium (Trillium reliquum) Bi, Bl, Ho, Ma E E No Sweet pitcher-plant (Sarracenia rubra) Bi, Ma, Pe NFS E No September 4, 2012 30 G-RAMP Environmental Assessment Species Name (Scientific Name) County Bi - Bibb Bl - Bleckley Do - Dooly Ho - Houston Ma - Macon Pe - Peach Pu - Pulaski Tw - Twiggs Source: USFWS 2010. 1 County1 2 Federal Status2 State Status3 Preferred Habitat 3 Habitat Available in Project Area? Federal Status E = Endangered T = Threatened CS = Candidate Species NFS = No Federal Status BGEPA = Bald and Golden Protection Act State Status E = Endangered T = Threatened U = Unusual R = Rare NSS = No State Status 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 "Harass" is defined under 50 C.F.R. ? 17.3 as acts or omissions, whether intentional or negligent, that annoy wildlife so as to "significantly disrupt behavioral patterns which include, but are not limited to, breeding, feeding, or sheltering." "Harm" is defined as "an act which actually kills or injures wildlife. Such act may include significant habitat modification or degradation where it actually kills or injures wildlife by significantly impairing essential behavioral patterns, including breeding, feeding or sheltering." Thus, potential impacts (in terms of "take") can be evaluated by identifying the life history events of the listed species with potential to be present on or near the Project Site. 3.6 Cultural Resources The APE includes areas to be affected by new construction, including demolition debris hauled off the site and potential material brought on the 24.5-acre Project Site. The archeological and cultural resources of RAFB are summarized in the Integrated Cultural Resources Management Plan (Ellis Environmental Group 2005). RAFB has been surveyed for archeological sites and historic structures, and the survey work has been reviewed and accepted by the HPD. An archeological survey of the Project Site was conducted by Garrow & Associates, Inc. (Garrow) in November 1996. The survey included upland portions of a 600-acre tract originally considered for purchase by RAFB. This tract fully encompassed the Project Site. The survey focused on 23 acres of uplands and suspected uplands to determine whether archeological resources were present and considered the existing haul/access roads. The survey used screened shovel tests at 30-meter intervals to locate sites, and then screened tests at 10-meter intervals to determine site boundaries. Four sites were discovered or noted from previous investigations: 9HT10 (lithic scatter), 9HT126 (lithic scatter), 9HT127 (lithic scatter), and 9HT128 (known as the "Wellston Cemetery" or the "Minshew-Thomas-Sullivan Cemetery"). Site 9HT10 was recommended by Garrow (1996) as being potentially eligible for the National Register of Historic Places (NRHP), based on artifact density and diversity. The Garrow (1996) report September 4, 2012 31 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 recommended cultural resources clearance for the remainder of the upland portions of the Project Site. According to a letter from the Georgia HPD dated July 24, 2009, HPD indicated that no archeological resources that are listed or eligible for listing on the NRHP would be affected by the G-RAMP project. However, on review of an upland survey area map from the Garrow (1996) report, it appeared that an additional upland area between Sites 9HT126 and 9HT10 warranted investigation, in addition to a re-examination of Site 9HT10, before ground-disturbing activities. As a result, these sites were reinvestigated as part of a Phase II archeological survey by Cultural Resources Analysts, Inc. (CRA) between February 9 and 15, 2011. The executive summary of this report is in Appendix F. Based on the results of the fieldwork, CRA indicated that Site 9HT10 was not considered eligible for inclusion on the NRHP and that no further research was recommended before project construction. CRA indicated that the Archaic occupation level appears intact across much of the Project Site, but concluded that the Project Site lacks potential to provide significant data regarding Archaic period culture and technology because of the lack of vertical integrity, low number of diagnostic artifacts, lack of cultural features, and relative low density of artifacts in general. In a letter from the Georgia HPD dated June 1, 2011, (Appendix B) HPD indicated that Site 9HT10 is not eligible for listing on the NRHP. Therefore, no archeological resources, including Site 9HT10, would be affected by the Proposed Action. RAFB sent letters to 12 potentially affected tribes in April 2012 to communicate the finding on 9HT10 and inquire regarding potential concerns; however, no responses were received (Appendix B). Site 9HT128 consists of two fenced plots, marked graves outside the plots, and unmarked graves. The use of the cemetery is from 1846 to 1979, based on the markers. According to the Garrow (1996) report, the cemetery does not offer outstanding historical significance or archeological potential, and was recommended as ineligible for the NRHP. Additional cemetery delineation performed by RAFB refined information regarding location of unmarked graves and supported establishment of a 50-foot buffer on the east side of the cemetery plot to be protected from ground-disturbing activities (Appendix G). The cemetery would continue to be preserved in place and protected from future ground-disturbing activities as recommended by Garrow (1996) and advised by Georgia HPD (Appendix B). Next to the cemetery is a small concentration of bricks and stones that may be remnants of a farmhouse and approximately 5 acres of overgrown pecan orchard noted by Garrow (1996). However, during the Phase I archaeological investigation, these areas within the APE were determined not to possess archaeological integrity for recommendation for inclusion in the NRHP. A delineation of the Wellston Cemetery (Site 9HT128), conducted in 2012 (URS, 2012, see Appendix G), revealed that the Wellston Cemetery has been in use by multiple families over a long period. While it cannot be discounted that unmarked graves could be the remains of persons that lived at structures formerly in the APE, historical records do not indicate that the September 4, 2012 32 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Wellston Cemetery functioned as a family cemetery for the inhabitants that may have lived next to the cemetery. 3.7 Socioeconomic Environment Socioeconomic resources include the basic attributes and resources associated with the human environment, particularly population and economic activity. Economic activity typically encompasses employment, personal income, and industrial growth. In addition, populations of special concern, as addressed by EO 12898, Federal Action to Address Environmental Justice in Minority and Low Income Populations, are identified and analyzed for environmental justice impacts. EO 12898 requires a federal agency to "make achieving environmental justice a part of its mission by identifying and addressing, as appropriate, disproportionately high human health or environmental effects of its programs, policies, and activities on minority populations and low income populations." A message from President Clinton concerning EO 12898 stated that federal agencies should collect and analyze information concerning a project's effects on minorities or low income groups, when required by NEPA. If such investigations find that minority or low income groups experience a disproportionate adverse effect, then avoidance or other management actions are to be implemented. Under NEPA, if disproportionate impacts on minority or low income populations are identified, this determination does not prevent a proposed action from going forward, nor does it compel a conclusion that the action is environmentally unsatisfactory. Rather, identification of such effects should heighten agency attention to alternatives, management actions or mitigation measures, monitoring needs, and preferences expressed by the affected communities or populations (CEQ 1997). Race and ethnicity are two separate categories of minority populations. A minority population can be defined by race, by ethnicity, or by a combination of the two distinct classifications. According to CEQ (1997), a minority population can be described as the following groups: American Indian or Alaskan Native, Asian or Pacific Islander, Black, not of Hispanic origin, or Hispanic. The population of an area is considered to be a minority population if it exceeds 50 percent of the population or the minority population percentage is meaningfully greater than the minority population percentage in the general population. Race, as defined by the U.S. Census Bureau (USCB 2001) includes: o White - A person having origins in any of the original peoples of Europe, the Middle East, or North Africa Black or African American - A person having origins in any of the Black racial groups or Africa American Indian or Alaskan Native - A person having origins in any of the original peoples of North and South America (including Central America) and who maintain tribal affiliation or community attachment o o September 4, 2012 33 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 o Asian - A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent, including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, or the Philippine Islands Native Hawaiian and Other Pacific Islanders - A person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands o USCB (2001) defines ethnicity as either being of Hispanic origin or not being of Hispanic origin. Hispanic origin is defined as "a person of Cuban, Mexican, Puerto Rican, south or Central American, or other Spanish culture or origin regardless of race." A minority population can be defined in multiple ways. For example, a population under consideration may be demographically composed of 45 percent Black, 6 percent Asian, 40 percent White, and 9 percent all other races or combination of races. In addition, a minority population can also be defined through ethnicity, where the population under consideration is demographically composed of 80 percent White, 10 percent Black, and 10 percent all other races or combination of races, but has an ethnic composition of 98 percent Hispanic origin and 2 percent of the population not of Hispanic origin. Race and ethnicity individually total a population of 100 percent. Each year USCB defines the national poverty thresholds, which are measured in terms of household income dependent on the number of persons within the household. Individuals falling below the poverty threshold ($17,603 for a household of four in 2000, and $21,954 for a household of four in 2009) are considered low income individuals. USCB (1995) tracts where at least 20 percent of the residents are considered poor are known as "poverty areas." When the percentage of residents considered poor is greater than 40 percent, the census tract becomes an "extreme poverty area." 3.7.1 Economic Activity and Population The Project Site is located within an area that is undeveloped next to RAFB and the Ocmulgee River floodplain. No residential or commercial development is near the Project Site. Because the Project Site currently has no facilities or operations, no employees or expenditures are associated with it. The Proposed Action would create jobs and foster economic growth and stability in the Middle Georgia region. Middle Georgia is home to RAFB, the state's largest industrial complex covering nearly 7,000 acres and employing more than 21,000 civilian and military personnel. RAFB has an annual economic impact of $3.9 billion, draws employees from 22 counties in Middle Georgia, and has contracts for services with firms in 18 Georgia counties. The Middle Georgia region includes the Warner Robins Metropolitan Statistical Area (MSA), which includes the cities of Macon, Warner Robins, and Fort Valley. According to the U.S. Bureau of Economic Analysis (BEA) website (BEA 2010), the Warner Robins MSA had a total population of 391,241 in 2008, with a total of 226,403 persons employed. September 4, 2012 34 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 3.7.2 Environmental Justice Based on a review of USCB (2010) data from the 2000 Census, the City has a population of 58,672 (based on 2009 estimates using census data from 2000). Further, the census tract containing the Project Site has a population of 2,591 (based on 2009 estimates) (USCB 2010). The census tract is approximately 17.7 square miles, encompasses RAFB, and is generally bound by Echeconnee Creek to the north, Sandy Run Creek to the south, Highway 247 to the west, and the Houston County boundary to the east. In addition to RAFB, this census track includes two small neighborhoods west and north of the base. Specific evaluation of potential impacts to low income neighborhoods is limited to the census tract level because USCB (2010) does not release income data at the smaller census block level, which contains a portion of the access route to the Project Site (Figure 6). According to the USCB (2010), forty-five people and 13 household units (13 owned, nine rented) are in this census block. Of the 2,591 people in the census tract, 109 people, or approximately 4 percent, are below the poverty level (USCB 2010). It is assumed in this document that this 4 percent is represented by the two small communities just west and north of the base. According to USCB (2010), the census block in which the proposed access route travels has a minority population of approximately 56% (five out of nine people are minorities). Further, the census tract containing the Project Site has a minority population of approximately 42 percent. The City has a minority population of approximately 38 percent, and approximately 13 percent of the population is below poverty level (USCB 2010). Houston County has a minority population of approximately 33 percent, and approximately 11 percent of Houston County is below poverty level (USCB 2010). In contrast to USCB data (2010), according to parcel data collected from Houston County (2011), the neighborhood in which the access route travels contains three occupied residential households Figure 6. The remaining properties along North Davis Drive and Perimeter Road consist of residences that are vacant, commercial properties, or undeveloped or vacant lots. Also shown on Figure 6, the USAF owns properties along Perimeter Road. 3.8 Transportation No adverse transportation issues are currently associated with the Project Site or the immediately surrounding roads. Access to the Project Site is and would be from a secured entrance from North Davis Drive on the west side of RAFB (Figure 2). The current access road is a dedicated City ROW gravel road that is used by staff working at the Ocmulgee River Water Pollution Control Facility No. 1. The gravel access road extends north from North Davis Drive, located east of State Highway 247, along the north end of RAFB to the City's Ocmulgee River Water Pollution Control Facility No. 1. Current traffic volume on the gravel access road is minor. Up to five employees work at and access the Ocmulgee River Water Pollution Control Facility No. September 4, 2012 35 G--RAMP Environmental Assessment '?oo J: I dg a' Noqh . - - Dawg .Legend a . Proposed Access Road .4 . Boundary i . 2 US Air Force Parcel Boundary 1 - - - Approxlmate Parcel Boundary yy Ge0rg|a-R0b|nS Aerospace Us? ILE I ri Maintenance Partnershi CI Active Business Residential - Vacant gygaqigogth (D - - on _k us; undeveloped, Vacantlot, Wooded Datalsourcel Houston Gounty, $0;0&11 6 *6 . Project Num bert . . Image Source. US Arr Force >>2009 Gaymms G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 1. Current trip counts for personnel accessing this area are approximated to be one to two roundtrips per day per individual, depending on whether personnel depart during lunch or for other routine trips. In addition, two to three trucks access the facility up to twice a week. Other periodic traffic on this access road may include families accessing the cemetery on the Project Site or hunters accessing the Oaky Woods Wildlife Management Area. 3.9 Safety Safety issues at RAFB are those that directly affect the protection of human life and property, and principally involve aviation, munitions, and fire prevention. USAF personnel are protected by observing OSHA, Air Force Occupational Safety and Health (AFOSH) standards, and RCRA. Aircraft flight operations and patterns associated with RAFB are conducted in accordance with RAFB's flight operation and safety procedures. No collisions have been recorded at RAFB (URS 2009a). Non-military personnel at the G-RAMP facilities would also be protected by observing OSHA and RCRA regulations. With respect to construction vehicle traffic, aircraft safety at Taxiway E during construction may be endangered by four principal causes: increased traffic volume, non-standard traffic patterns, vehicles without radio communication and marking, and operators untrained in airfield procedures. RAFB and the City would jointly develop and coordinate a Construction Vehicle Traffic Plan with airport users, air traffic control, and the appropriate construction engineers and contractors. The plan, when signed by participants, should become a part of the contract. Airfield Management and Safety are responsible for coordinating and enforcing the plan. No adverse safety issues are currently associated with the Project Site. 4.0 Environmental Effects This section describes the potential environmental effects of implementing the Proposed Action and the No Action Alternative. Potential effects of actions are based on the description of the actions as presented in Section 2.0 and existing environmental conditions at the Project Site as presented in Section 3.0. Environmental effects from the No Action Alternative address effects as they currently occur or could occur in the future without construction of the new G-RAMP facilities. 4.1 Physical Environment 4.1.1 Topography 4.1.1.1 No Action Alternative Implementation of the No Action Alternative would have no significant adverse or positive effects on the topography at or near the Project Site. Under the No Action Alternative, the topography of the Project Site would remain unchanged because construction would not occur. September 4, 2012 37 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 While the topography of the Project Site was altered significantly in the past, it is not currently being altered because the Project Site experiences no uses at this time. 4.1.1.2 Proposed Action While grading of the Project Site would be required to reduce or increase elevation levels, implementation of the Proposed Action would have no significant adverse or positive effects on the Project Site topography. The Proposed Action would require clearing, grubbing, and mass grading to prepare the Project Site for the new infrastructure improvements and the hangar facilities. Excavation would also be required in the area of Joint Stars Road to facilitate the proposed access road and taxiway connection. No additional clearing, grubbing, or grading would be required for access to the Project Site as existing roadways would be used. Topography would not be affected by the installment of the new 12-inch water supply main because it would be placed in the same location as the existing 6-inch main (Figure 4). Approximately 450,000 cubic yards of earthwork is anticipated to be moved during mass grading to bring the grade of the Project Site to 260 feet AMSL. According to the Preliminary Engineering Report (Carter & Sloope 2009), this is the recommended grade for the Project Site. The necessary construction fill and topsoil would be obtained from either the Project Site or an existing commercial source fully permitted under applicable laws protecting the environment. Because of the historical disturbance to the Project Site, primarily due to borrow pit excavations next to the Project Site, the net result of these improvements would have a beneficial effect on topography because the topography would be returned to near-historical levels. 4.1.2 Surface Waters 4.1.2.1 No Action Alternative Implementation of the No Action Alternative would not cause significant adverse or positive impacts on surface waters because no natural surface water bodies, such as lakes or streams, are located on or next to the Project Site, and construction would not occur. 4.1.2.2 Proposed Action There are no surface waters, such as lakes or streams, within or next to the Project Site, access route, or location of the water supply main. Therefore, implementation of the Proposed Action would not result in either significant adverse or positive effects on surface waters because construction activities would not occur in or next to natural surface water bodies. Further, Best Management Practices (BMPs) would be used during implementation of the Proposed Action to protect nearby surface waters during construction operations, including surface runoff that drains to storm sewer systems at RAFB. BMPs such as silt fencing, hay bales, and erosion control blankets would be used, as applicable, during construction to control land disturbance and stormwater runoff, avoiding significant adverse impacts on surface waters. Section 4.1.4 includes September 4, 2012 38 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 discussion of potential impacts on surface waters from soil erosion and stormwater runoff during construction activities. 4.1.3 Floodplains and Wetlands 4.1.3.1 No Action Alternative Under the No Action Alternative, floodplain characteristics and wetland features would remain unchanged; therefore, implementation of the No Action Alternative would not result in significant adverse or positive effects on these resources within the Project Site. 4.1.3.2 Floodplain Proposed Action Implementation of the Proposed Action would result in filling floodplain within portions of the Project Site. The floodplain characteristics within portions of the Project Site would potentially be changed by directly impacting approximately 1.36 acres of the 100-year floodplain (designated as "Zone A" by FEMA). This equates to approximately 3,015 cubic yards of fill material to be placed within the floodplain. Construction of the taxiway ramp/apron to RAFB and the access road to the Project Site would not impact the floodplain (Figure 2). Further, the location of the water supply main is not within the floodplain. Filling the floodplain would not significantly alter flood elevations because the filled area would lie within the extensive Ocmulgee River flood zone (Figures 1-3). The floodplain storage loss of 1.36 acres would be insignificant compared to the extensive flood storage capacity of the Ocmulgee River floodplain, which has 5,975 acres for that portion of sub-basin west of the Ocmulgee River (URS 2009a). The watershed floodplain would accommodate the loss in storage capacity. Further, loss in storage capacity would not alter the delineation of flood hazard zones outside the Project Site. Before ground-disturbing activity within the floodplain, the City must evaluate and approve this action. Further, before performing construction projects within a floodplain, USAF must investigate and exhaust potential alternatives that would avoid working within floodplain resources. This requirement is consistent with EO 11988, Floodplain Management, and USAF's wetlands/floodplains compliance responsibilities per Air Force Instruction 32-7064. EO 11988 addresses floodplain management and requires that the functions of floodplains be considered in the decision-making process. Adverse impacts on floodplains may be acceptable only if there is no practicable alternative. No practicable alternative that would meet the project requirements was identified for the Proposed Action. Therefore, the Proposed Action must be located within a small portion of the floodplain. Implementation of the Proposed Action would require a Letter of Map Revision (LOMR) from the City to FEMA. September 4, 2012 39 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Wetlands The Proposed Action would avoid impacts to wetland features. Further, construction of the taxiway ramp/apron to RAFB, improvements to the access road, and replacement of the water supply main would not impact wetlands. Wetlands next to construction activities would be identified and protected with fencing and other erosion control measures, as described further under Section 4.1.4 (Stormwater). During project implementation, should it be determined that adjacent wetland areas would be encroached and impacted by the Proposed Action, a Pre-Construction Notification (PCN) (for impacts 0.5 acre or less) would be submitted to USACE for approval before impacts. The PCN is commonly submitted simultaneously with the JD package. The Proposed Action could be authorized under Nationwide Permit (NWP) 39 (Commercial and Institutional Developments). If the project would impact less than 0.1 acre of jurisdictional wetlands, then no compensatory mitigation would be required as a part of the PCN. For wetland impacts greater than 0.1 acre, compensatory mitigation would be required and would likely consist of the purchase of wetland mitigation credits from a USACE-approved wetland mitigation bank. If compensatory mitigation is required, the City would be responsible for purchasing the credits from the approved mitigation bank after the USACE has approved the permit and before construction. Additional mitigation measures might include preservation/conservation of wetlands in the project vicinity, or purchase of in-lieu fees from USACE. The access route owned by the City into the G-RAMP area follows the present City route of a dirt road to the City water treatment facility. The road crossed the base to the north of the runway, and extends along a route outside the base along the eastern perimeter. The dirt road is above the wetlands/floodplains that are adjacent to the G-RAMP site. Activities related to construction of improvements and vehicular traffic on the road may be expected to expand along the edges of the road into the adjacent wetlands/floodplains. The impacts would be limited to this extent, and would present substantially fewer impacts than might be expected from building a new road through the wetlands/floodplains. 4.1.4 Stormwater 4.1.4.1 No Action Alternative Implementation of the No Action Alternative would not cause significant adverse or positive effects on stormwater quality because construction and implementation would not occur and there would be no changes to stormwater runoff on the Project Site. 4.1.4.2 Proposed Action Implementation of the Proposed Action would result in an increase in the volume of stormwater runoff because construction activities would result in an increase of impervious surface within September 4, 2012 40 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 the Project Site. It is anticipated that the Proposed Action would not cause significant adverse or positive effects on stormwater because permitting and environmental requirements would be met and appropriate BMPs for protecting surface water from sedimentation effects would be in place during construction, as described below. According to the Preliminary Engineering Report (Carter & Sloope 2009), stormwater runoff from the Project Site would be collected and conveyed to a stormwater treatment pond, which would provide sediment storage during construction and provide water quality treatment, flow, and velocity control for the developed Project Site. The design would conform to, and the work would be performed in accordance with, the Georgia Stormwater Management Manual (Appendix C), the project specifications, and the project details to protect downstream waterways and existing stormwater conveyance systems during and after construction. Application for a Land Disturbing Activity Permit from Houston County would be submitted before construction. The permit process also includes submission of a Notice of Intent (NOI) for permit coverage under National Pollutant Discharge Elimination System (NPDES) Permit GAR100001 (approval to discharge stormwater associated with construction activity), which would be obtained through GA EPD. As required by the NPDES permit, an Erosion, Sediment, and Pollution Control Plan (ESPCP) would be developed and implemented during the project. Approval by GA EPD would be required if more than 50 acres of area is disturbed. The ESPCP would be written in accordance with the Georgia Soil and Water Conservation Commission's (GSWCC's) Manual for Sediment and Erosion Control in Georgia, 5th Edition (GSWCC 2000). The Proposed Action would also comply with applicable county water protection ordinances because a Houston County Sediment and Erosion Control Permit would be obtained, land disturbance fees would be submitted to GA EPD and Houston County, BMPs would be implemented, and Notice of Termination would be submitted to GA EPD following conclusion of work when Project Site conditions meet the definition of "final stabilization." Erosion and sediment control measures would be implemented as required for land disturbing activity permits. Use of BMPs such as silt fencing, hay bales, and erosion control blankets, as applicable, would be implemented during construction activities to control stormwater runoff. These construction activities include improvements to the access road and replacement of the water supply main. These sediment barriers, consisting of approved materials, would be installed along the perimeter of the construction site, downslope of construction activities and at drainage inlets. Additional erosion and sediment control measures would be installed if deemed necessary by on-site inspection as construction activities progress. Sediment control barriers would be monitored, and the excess sediment would be removed and spread on-site. Sediment and erosion control measures would remain in place and be maintained until the disturbed areas are stabilized with permanent vegetation. Grading and excavation would be scheduled to reduce the exposure of bare soils to erosive elements. September 4, 2012 41 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Further, the Proposed Action would comply with the EISA, Section 438, requiring use of LID techniques during construction, which is consistent with USEPA's Technical Guidance on Implementing the Stormwater Runoff Requirements for Federal Projects Under Section 438 of the Energy Independence and Security Act (USEPA 2009) (Appendix C). LID techniques would be determined as appropriate during the design review process. The EISA, Section 438, requires that the overall design objective for each project is to maintain predevelopment hydrology and avoid net increase in stormwater runoff. DoD defines "predevelopment hydrology" as the preproject hydrologic conditions of temperature, rate, volume, and duration of stormwater flow from the Project Site. The analysis of the predevelopment hydrology must include site-specific factors (such as soil type, ground cover, and ground slope) and use modeling or other recognized tools to establish the design objective for the water volume to be managed from the Project Site. EISA, Section 438, also requires that Project Site design options be evaluated to achieve the design objective to the maximum extent technically feasible. The "maximum extent technically feasible" criterion requires full employment of accepted and reasonable stormwater retention and reuse technologies (e.g., bio-retention areas, permeable pavements, cisterns/recycling, and green roofs), subject to Project Site and applicable regulatory constraints (e.g., Project Site size, soil types, vegetation, demand for recycled water, existing structural limitations, and state or local prohibitions on water collection). 4.1.5 Geology and Soils 4.1.5.1 No Action Alternative Under the No Action Alternative, geology and soil characteristics would remain unchanged; therefore, implementation of the No Action Alternative would not result in significant adverse or positive effects on geology and soil characteristics within the Project Site. 4.1.5.2 Proposed Action Implementation of the Proposed Action would not result in significant adverse or positive effects on geologic features because construction activities would occur at or near the ground surface. Fill material would be required to bring portions of the Project Site to grade. The potential for soil erosion to adversely affect surface water quality would be reduced through the application of appropriate BMPs during construction, and adherence to NPDES permit requirements, as discussed in Section 4.1.4.2. BMPs applied during construction activities, such as silt fencing, hay bales, and erosion blankets, would control soil erosion and avoid significant adverse effects on the quality of stormwater runoff. September 4, 2012 42 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 4.1.6 Groundwater 4.1.6.1 No Action Alternative Implementation of the No Action Alternative would not result in either significant adverse or positive effects on groundwater because there would be no changes to groundwater resources. 4.1.6.2 Proposed Action Implementation of the Proposed Action would result in near-ground-surface activities and would not significantly affect groundwater. As a result of the RFI (Earth Tech/Rust E&I 1999), the downgradient boundaries of the chlorinated solvent plumes were determined to be discharging into the wetlands east of RAFB, just north of the Project Site. (The BTEX plume was also further defined in the RFI and was described as moving along the same flow path as that of the chlorinated solvent plume.) Consequently, because of the direction of the plume, it is not anticipated that this plume would be encountered within the Project Site. According to the RFI (Earth Tech/Rust E&I 1999), exposure to the chlorinated solvent plume is limited because there are no potential human exposure points except casual contact by recreationists (i.e., hunters, fishers, and hikers) within the wetland areas hydraulically downgradient of RAFB. In addition, there are no drinking water wells impacted by the chlorinated solvent plume. Although not likely, future exposure to groundwater may occur using a water well that could be installed in the Providence Formation in the future. However, the Proposed Action would result in use of the City's water supply via a water supply main extension that would connect to an existing 12-inch main at North Davis Drive and Tabor Drive. Analytical results of the existing well located on the Project Site indicated that no contamination was detected (Appendix A of Earth Tech/Rust E&I 1999). Therefore, the Proposed Action is not anticipated to result in adverse effects from exposure to the groundwater plume within the Project Site. In addition, GA EPD has indicated that NFA was required of RAFB with respect to the groundwater contamination. An NOD indicating NFA was issued by GA EPD on September 12, 2002, and is in Appendix E. 4.1.7 Water Supply and Drinking Water 4.1.7.1 No Action Alternative Implementation of the No Action Alternative would not cause significant adverse or positive effects on water supply or drinking water because construction and implementation would not occur and there would be no changes to these resources on the Project Site. September 4, 2012 43 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 4.1.7.2 Proposed Action Implementation of the Proposed Action would not adversely affect the existing water supply because the local water supply would not be significantly affected by the proposed improvements. Water from the existing well on the Project Site would not be used. The flow and pressure required by the Proposed Action would be provided by the water system improvements proposed for the project area. 4.2 Air Quality 4.2.1 No Action Alternative There would be no changes to air emissions under the No Action Alternative because construction and operation of the Proposed Action would not occur. Implementation of the No Action Alternative would not result in either significant adverse or positive effects on air quality. 4.2.2 Proposed Action The primary means by which the protection and enhancement to air quality is accomplished is through maintaining the NAAQS. To accomplish this, construction of new air emission sources must go through the Georgia Environmental Protection Division (EPD) - Air Protection Branch State Implementation Plan (SIP) construction permit program. Depending on the potential to emit (PTE) of the Proposed Action, a construction permit may need to be issued before construction can begin. If PTE emissions of PM2.5, PM10, SO2, CO, NOx, or VOC exceed 100 tons per year or if total HAPs exceed 25 tons per year, or an individual HAP PTE exceeds 10 tons per year, a major source Title V operating permit must be obtained. Construction activities associated with the Proposed Action would involve operation of heavy equipment during construction, transport of fill material, and an increase in vehicular traffic trips from construction crews. These activities would temporarily increase emissions of carbon monoxide, hydrocarbons, particulate matter, and nitrogen dioxide. However, because these emissions would be temporary and relatively limited in quantity and duration, they would be considered insignificant. Further, construction of the Proposed Action would not cause significant adverse impacts on air quality from fugitive dust emissions because BMPs would be implemented daily during construction activities. BMPs would include procedures for wetting disturbed portions of the project areas to control dust emissions during periods of excessive dryness, thereby avoiding significant adverse impacts. Implementation of the Proposed Action would increase air emissions because there would be an increase in emissions from employee personal vehicles. However, these mobile emission sources would not significantly change air emissions in the vicinity compared to the current total emissions associated with RAFB operations, and would not increase ambient air pollution concentrations above NAAQS. Air emissions would also increase because of aircraft repair and September 4, 2012 44 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 maintenance operations, and movement of aircraft along taxiways. Maintenance and repair of aircraft would be the primary sources of air emissions and would be similar to operations already conducted at RAFB. Sources of air emissions could include paint stripping, painting, electroplating, degreasing, and engine testing. Activities contributing to the primary sources of air emissions could include painting and de-painting operations, solvent cleaning, and chromium plating and anodizing. Other sources could include fuel storage tanks, peaking power generators, boilers, and various sources of fugitive VOCs. The amount of air emissions cannot be calculated because the level of future operations at the Project Site cannot be determined at this time. However, based on the future maintenance, repair, and operations of two C-17 or C-5 aircraft at the Project Site, it is anticipated that the amount of particulate matter, carbon monoxide, nitrogen dioxide, sulfur dioxide, HAP, and VOC emissions would be significantly less than the emissions coming from operations at RAFB, and that these emissions would not result in violations of the NAAQS. Air quality in Houston County, which includes RAFB and the Project Site, is classified as an "attainment" area (i.e., pollutant levels are below the NAAQS), and as such, conformity is not applicable. USEPA is currently considering lowering the NAAQS for certain air pollutants. If NAAQS were to be lowered, Houston County would go into nonattainment status. GA EPD would be required to revise the SIP and to promulgate the new regulations. However, this would be a lengthy process that is not anticipated to affect the air quality analysis in this document. In 2010, CEQ provided a draft guidance memorandum for federal agencies to consider whether analysis of greenhouse gas (GHG) emissions from proposed actions may provide meaningful information to decision makers and the public as a part of the NEPA process. Specifically, if a proposed action would be reasonably anticipated to cause direct emissions of 25,000 metric tons or more of carbon-dioxide-equivalent GHG emissions annually, or if long-term GHG emissions could be significant, agencies should consider the potential for impacts. Because the Proposed Action is not expected to produce significant quantities of GHG emissions, no additional consideration of GHG emissions is included in this EA. Based on the above-described assessment, implementation of the Proposed Action would not significantly increase air emissions at or near the project area and would not be expected to cause violations of the NAAQS. 4.3 Waste Management and Toxic Materials 4.3.1 Wastewater 4.3.1.1 No Action Alternative There would be no changes to sanitary or industrial wastewater generation under the No Action Alternative because construction and operation of the Proposed Action would not occur. September 4, 2012 45 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Implementation of the No Action Alternative would not result in either significant adverse or positive effects on wastewater. 4.3.1.2 Proposed Action Sanitary wastewater would be generated at the new facilities associated with the Proposed Action. Based on the creation of 150 new jobs at the G-RAMP facilities, it is anticipated that the impact on the City's Ocmulgee River Wastewater Treatment Plant No. 1 would not be significant based on the plant's capacity of 3 million gallons per day (MGD) and the current operating average of approximately 1.2 to 1.5 MGD. The plant provides domestic sewage treatment for City customers and would also treat sewage from the Proposed Action. Because it is anticipated that the additional sanitary wastewater generated by the Proposed Action would be insignificant compared to the number of current customers and wastewater volume currently generated, the new facility operations would not cause significant adverse impacts on the sanitary wastewater system. It is not anticipated that industrial wastewater would be generated at the proposed facilities; however, should industrial wastewater be generated at the Proposed Project, such wastewater would be in compliance with the City's Wastewater Pretreatment Program for industrial dischargers. Operations at the proposed facilities would not produce significant adverse or positive effects on sanitary and industrial wastewater generation. 4.3.2 Solid Waste 4.3.2.1 No Action Alternative No significant adverse or positive impacts on solid waste would occur under the No Action Alternative because solid waste would not be generated. 4.3.2.2 Proposed Action Implementation of the Proposed Action would not result in significant adverse or positive impacts on solid waste or the physical environment as it relates to solid waste. Solid waste would be sent to the Houston County landfill, which would provide solid waste disposal services. This landfill is a permitted municipal solid waste landfill with 8 years of useful life remaining, and a permitted construction and demolition landfill with 35 years of useful life remaining (GA EPD 2009). The landfill could acquire approximately 50 years of additional capacity through expansion if needed (URS 2009b). Therefore, adequate space is available in the Houston County landfill for the solid waste that would be generated from the Proposed Action. Waste materials containing asbestos or lead would be handled in accordance with applicable regulations (Section 4.3.4.2). Solid waste (e.g., office-type and shop-related waste) generated from implementation of the Proposed Action would be similar in amount and type to that currently generated by similar operations at RAFB. Based on the creation of 150 new jobs at the G-RAMP facilities, the amount of solid waste that would be generated would be insignificant compared to the September 4, 2012 46 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 population in the Warner Robins MSA and the number of personnel at RAFB. Solid wastes would be recycled to the extent possible and would not cause significant adverse environmental effects. 4.3.3 Hazardous Materials and Waste 4.3.3.1 No Action Alternative Under the No Action Alternative, use of hazardous materials and generation of hazardous waste would not occur. The No Action Alternative would not cause significant adverse or positive environmental effects related to hazardous materials and hazardous waste. 4.3.3.2 Proposed Action Implementation of the Proposed Action would not result in significant adverse or positive environmental effects related to hazardous materials or hazardous waste. Implementation of the Proposed Action may result in the generation of hazardous wastes including petroleum products, such as hydraulic fluid mixed with used oil and hydraulic fluid mixed with solvent. Waste streams at the new hangar facilities could include rags, adhesives, dried paint, and paint thinner. The exact amount of this waste that would be generated annually from the Proposed Action cannot be determined at this time. However, based on the future maintenance, repair, and operations of two C-17 or C-5 aircraft at the Project Site, it is anticipated that hazardous waste generation be would comparable to that at existing hangar facilities at RAFB. RCRA requires anyone who owns or operates a facility where hazardous waste is treated, stored outside the limits of 40 CFR 262.34, or disposed of to have a permit. A storage permit is not required for storage of hazardous waste under 90 days. RCRA establishes a procedure for obtaining interim status, which allows existing facilities to continue operating until a final hazardous waste permit is issued. Hazardous waste generators are required to notify GA EPD of regulated waste activities. The hazardous waste generator/property owner is required to obtain a USEPA Identification Number by completing and submitting USEPA Form 8700-12 for initial notifications. GA EPD would be consulted for specific guidance on this issue. Hazardous waste generated by the Proposed Action would be managed and disposed of pursuant to the RCRA Standards Applicable to Generators of Hazardous Waste (40 CFR 262) and Georgia Rule 391-3-11, Hazardous Waste Management. Further, hazardous materials would be stored and handled in accordance with OSHA regulations, 29 CFR 1910.1200(e)-(h), Hazard Communication. Construction of facilities for the Proposed Action (e.g., hangars and parking areas) is not anticipated to generate hazardous waste. September 4, 2012 47 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 4.3.4 Toxic Materials 4.3.4.1 No Action Alternative Implementation of the No Action Alternative would not cause significant adverse or positive environmental effects related to toxic materials and toxic waste because these materials would not be generated. The Phase 1 ESA (Preston 2006b) conducted for the Project Site did not address radon, ACM, LBP, or lead in drinking water. ACM or LBP is unlikely to be present within the location of the old abandoned home site at the south end of the Project Site. If potential toxic materials are present on the Project Site, these materials would not be affected and it is highly unlikely that they would affect the environment given the small size of the abandoned home. 4.3.4.2 Proposed Action No PCB-containing equipment is located within the boundaries of the Project Site (Preston 2006b). Implementation of the Proposed Action would have no significant adverse or positive effects on toxic materials or toxic waste, or the environment as it relates to these materials. Remnants of the abandoned home that could be disturbed at the Proposed Site would be assessed by pre-demolition inspections/surveys before demolition activities. If susceptible materials are encountered, these materials would be tested and characterized, and if identified as ACM or LBP, the toxic materials or waste would be removed, managed, and disposed of in accordance with applicable regulations. Operation of the hangar facilities would not involve use of equipment containing PCBs, ACM, or LBP. The use of these materials in new construction would be prohibited. Therefore, operation of the proposed hangar facilities would not result in significant adverse impacts on the environment related to toxic materials. 4.4 Noise Environment 4.4.1 No Action Alternative Implementation of the No Action Alternative would not result in significant adverse or positive effects on the noise environment, which would not change from its current condition. 4.4.2 Proposed Action Construction activities would not result in significant adverse impacts on the noise environment because these activities would be short-term, localized, and sufficiently distanced from the nearest sensitive noise receptors. Construction at the Project Site would occur in and near the elevated noise environment of the flight line area (Taxiway E). The nearest noise receptors would be the buildings south of the existing Joint Stars Road. Replacement of the 6-inch water supply main would occur along existing roads that experience traffic noise. Sensitive noise receptors (buildings and homes west of RAFB) would be protected by the City's noise ordinance. According to Section 13-67 of Article IV, Chapter 13, of the City's Municipal Code, September 4, 2012 48 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 construction activities are to occur between the hours of 7:00 a.m. and 6:00 p.m. weekdays, except in cases of urgent necessity, for which the City engineer may grant a permit for a period not to exceed 60 days. Further, if the City engineer determines that public health and safety would not be impaired by the construction activity between the hours of 6:00 p.m. and 7:00 a.m., and that loss or inconvenience would result to the party of interest, the City engineer may grant permission for this work during these hours. An application for a permit for such work must be made at the time the permit for work is awarded, or during the progress of work. Construction personnel would wear ear protection in accordance with DoD and OSHA health and safety requirements, where applicable, for construction activities requiring this level of protection. Implementation of the Proposed Action would also not result in significant adverse impacts on the noise environment. No increase in flight operations is anticipated. Noise from future operations at the new hangar facilities would be generally consistent with that from existing and surrounding operations. Personnel at the new facilities would be exposed to noise from the aircraft at the Project Site, from surrounding streets, and from the nearby airfield at RAFB. According to the AICUZ study (USAF 1998), the Project Site is subject to noise levels between 70 and 80 dB. It is anticipated that non-aircraft-related sound levels generated at the Project Site would typically be below the AFOSH-established exposure limit of 85 dB (by 8-hour time weighted average) (URS 2009b). Aircraft operations at the Project Site may generate noise that exceeds 80 dB; however, personnel would expect these elevated noise levels and would be protected in accordance with DoD and OSHA health and safety requirements, where applicable. Noise levels exceeding 85 dB would require use of personal protective equipment to protect hearing (URS 2009b). 4.5 Biological Environment 4.5.1 No Action Alternative Implementation of the No Action Alternative would not result in significant adverse or positive effects on the biological environment because no natural resources would be disturbed. 4.5.2 Proposed Action Implementation of the Proposed Action, including construction of the taxiway ramp/apron and access road to RAFB, would not result in adverse effects on endangered, threatened, or sensitive species because these species are not expected to occur on the Project Site. These species are not known to occur on the Project Site, and/or habitats supporting most of these species are not present within the Project Site, or along the access route or water supply main route. On rare occasions, bald eagles and wood storks have been observed on or near in the Project Site, but neither of these species has been observed nesting or roosting on the Project Site (Sargent 2011), as described in Section 3.2. Because vegetation would be removed during construction, in the September 4, 2012 49 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 unlikely event that roosting or resting bald eagles or wood storks were to be observed, construction activities in the immediate vicinity would cease, and the construction manager would immediately contact the City. The City would send a qualified representative to visit the discovery site, the resource would be recorded and evaluated, and appropriate avoidance measures (e.g., temporary buffer) would be determined as necessary. Potential habitat for the alligator snapping turtle is located next to the Project Site. This species has not been observed and is not anticipated to be present on the Project Site (Sargent 2011). The alligator snapping turtle is large and conspicuous and, if present, would be readily observable. In the unlikely event that a snapping turtle is observed on the Project Site during project implementation, construction activities in the immediate vicinity would cease, and the construction manager would immediately contact the City. The City would send a qualified representative to visit the discovery site, the resource would be recorded and evaluated, and appropriate avoidance measures would be determined as necessary. The Proposed Action would not result in significant adverse impacts on common wildlife and vegetation resources. Impacts on common wildlife species would include an increase in noise and traffic, and loss of habitat. The Project Site is highly disturbed from historical soil borrowing, logging, and clearing activities that either occurred on-site or immediately next to the site. Therefore, high-quality habitat and significant vegetation and wildlife resources are not present throughout most of the Project Site. However, the Proposed Action would involve clearing of trees and other vegetation, which would decrease the amount of forested habitat available to common wildlife species and would displace wildlife to surrounding areas. It is unlikely that clearing vegetation within the Project Site would have a negative impact on the current common wildlife species, which would likely be displaced to surrounding habitats of greater quality. The mixed bottomland hardwood forest and bottomland hardwood swamp communities that surround the Project Site are of much higher quality than the Project Site (RAFB 2007). Potential impacts on wetlands and floodplains are discussed in Section 4.1.3. 4.6 Cultural Resources 4.6.1 No Action Alternative The No Action Alternative would not result in significant adverse or positive effects on cultural resources because construction activities would not occur. Cultural resources are not being impacted at the Project Site, and these resources would continue to be protected as required by federal and state agencies. 4.6.2 Proposed Action The Proposed Action has been coordinated under provisions of the National Historic Preservation Act (NHPA), Section 106 (as amended). As part of the Section 106 process, the APE was investigated to identify if historic properties were present. Four archaeological sites September 4, 2012 50 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 have been identified within the APE. The sites, located within the APE, are not eligible for inclusion in the NRHP. The result is that no historic properties are present within the APE. Archeological investigations of the Project Site in 1996 (Garrow), in 2011 (CRA), and by RAFB in 2012 determined that there are no sites potentially eligible for listing on the NRHP (Appendix F). The Garrow (1996) report recommended cultural resources clearance for the remainder of the upland portions of the Project Site. Further, the Garrow (1996) report recommended a formal delineation of the cemetery to ensure proper preservation. The CRA (2011) report provided results of the recommended clearance and indicated that no further research before construction is recommended. While Site 9HT128 is not an NRHP eligible site, it will be protected from disturbance with a 50foot undisturbed buffer and a new permanent fence, which would be installed before construction. In 2012, the boundaries of Site 9HT128 were delineated using information from local informants, a pedestrian survey, and archaeological probing (URS, 2012; Appendix G). While the cemetery boundaries were established during this investigation, the Georgia HPD has advised, in a letter dated August 1, 2012, (Appendix B) that a 50-foot buffer be placed on the east side of the cemetery plot. This buffer zone is not part of the cemetery boundary but will serve as a precautionary measure to protect potential unmarked graves. During construction activities, should human remains be identified, excavation activities would cease and plans would be developed to address the discovery. Construction personnel would be directed to avoid the site of discovery and immediately contact the City. Work in the area of discovery would stop until the Project Site could be investigated. The City, with RAFB, would send a qualified representative to visit the discovery site, the resource would be recorded and evaluated, and the effects would be managed in consultation with RAFB as necessary. 4.7 o o Socioeconomic Environment Substantial gains or losses in population and/or employment; Disequilibrium in the housing market, such as severe housing shortages or surpluses, resulting in substantial property value changes; and/or Disequilibrium in the quality of life, such as severe shortages of hospitals, emergency response services, and schools Potential socioeconomic impacts are considered major if the Proposed Action would cause: o Potential environmental justice impacts are considered major if the Proposed Action would cause disproportionate effects on low income and/or minority populations. September 4, 2012 51 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 4.7.1 No Action Alternative Under the No Action Alternative, no additional jobs would be created and there would be no input of economic growth. Based on the City's economic impact analysis, the Proposed Action has the potential to create up to 1,650 jobs with an estimated impact of $36.5 million per year from 2011 to 2040 (Carbon 2008). The immediate need of approximately 150 new jobs would create revenues of more than $3.8 million per year from project commencement to 2038 (Carbon 2008). The No Action Alternative would not meet the purpose and need for the Proposed Action, which is intended to improve aircraft availability and reduce operational and sustainment costs. Further, under the No Action Alternative, additional jobs would not be created and there would be no input to economic growth and stability in the Middle Georgia region. Therefore, the No Action Alternative would result in an adverse, although insignificant, impact on the socioeconomic environment. Compared to the economy associated with RAFB and the Warner Robins area, the socioeconomic environment would not change significantly under the No Action Alternative because RAFB would continue to exert a significant positive impact on the economy of the Middle Georgia region of influence. Minority and low income populations would not be significantly, adversely, or positively impacted under the No Action Alternative. Further, there would be no significant environmental health or safety risks to children. Therefore, implementation of the No Action Alternative would result in neither significant positive nor significant negative effects on the local socioeconomic environment. 4.7.2 Proposed Action 4.7.2.1 Economic Development and Demographics Construction and operation of the Proposed Action, including activities on the access road, would provide additional economic stimulus to the Middle Georgia region, resulting in positive impacts on the socioeconomic environment, including 150 new jobs at the new facility. Mercer University partnered with the Middle Georgia Regional Commission to develop an employment multiplier model for a study area consisting of the Macon - Warner Robins - Fort Valley, GA, Combined MSA. A minimum requirements technique was used for the analysis. This technique uses industry-level data for a group of comparable MSAs in building an employment multiplier. The multiplier model was developed using data available through BEA (2010). BEA uses the North American Industry Classification System for regional economic data comparisons. This analysis used BEA data from 2008. According to the BEA (2010) website, the Warner Robins MSA had a population of 391,241 in 2008, with 226,403 people employed. According to the analysis, the economic impact multiplier for the combined MSA in 2008 was 2.5. This means that for each job created/lost at RAFB, an additional 1.5 jobs will be created/lost in the local economy. The Proposed Action would also provide a short-term beneficial economic effect on September 4, 2012 52 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 the regional economy from new construction expenditures. As a result of construction activities, potential short-term employment opportunities may be expected through contractor jobs. These jobs would likely use the local labor force and not require relocation of labor force from outside the Warner Robins MSA. 4.7.2.2 Environmental Justice Disproportionate environmental impact occurs when the risk or rate for a minority population or low income population from exposure to an environmental hazard exceeds the risk or rate of the general population and, where available, to another appropriate comparison group (EO 12898). Although potential impacts, such as traffic and noise, may occur within the general setting of the Proposed Action and along the access route/water supply main route, the census tract of the area (RAFB and neighborhoods west and north of RAFB) has a low percentage of minority and low income populations and is not expected to be disproportionately affected. According to USCB (2010), the census block in which the proposed access route travels has a minority population of approximately 56 percent (five of nine people are minorities). Comparatively, the larger census tract containing the Project Site has a minority population of approximately 42 percent, the City has a minority population of approximately 38 percent, and Houston County has a minority population of approximately 33 percent (USCB 2010). If using the USCB (2010) data, the percentage of minority populations along the access route would be comparable to surrounding areas. If comparing minority populations using the Houston County parcel data (2011), the percentage of minorities along the access route may be smaller because these data indicate that there are three occupied residential households along the access route, with the remaining properties along North Davis Drive and Perimeter Road consisting of vacant residences, commercial properties, or undeveloped or vacant lots (Figure 6). Of the 2,591 people in the census tract containing the Project Site, 109 people, or approximately 4 percent, are below the poverty level (USCB 2010). As stated under Section 3.7, it is assumed that a high proportion of residents in the two small communities just west and north of the base, including the community along the access route, are below the poverty level. However, the poverty level of the neighborhoods next to the Project Site is low when compared to 13 percent of the population below the poverty level in the City and 11 percent of the population below poverty level in Houston County (USCB, 2010). Furthermore, using the Houston County parcel data (2011), the estimates of population below the poverty level along the access route may be smaller. The potential effects of the Preferred Alternative have been evaluated in accordance with the requirements of EO 12898. No adverse disproportionate effects on minority or low income populations would occur. Overall, the Proposed Action would not result in significant adverse socioeconomic impacts. Impacts associated with access to the Project Site during both construction and implementation September 4, 2012 53 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 would be considered insignificant. Potential economic impacts from the Preferred Alternative are considered long-term beneficial. 4.8 Transportation 4.8.1 No Action Alternative Under the No Action Alternative, there would be no significant adverse or positive effects on transportation because local traffic patterns and volume near the Project Site would remain unchanged. 4.8.2 Proposed Action The Proposed Action would have no significant adverse or positive effect on transportation. During construction, there would be a temporary, insignificant increase in traffic from construction vehicles, including trucks hauling clean fill material to be placed on the Project Site. Replacement of the water supply main may also temporarily impact traffic (e.g., temporary lane closures or road detours) but not to a significant degree. The anticipated period of construction of the G-RAMP facilities and associated infrastructure improvements would be four to five years. Access to the Project Site during construction is anticipated to be from the gravel access road located outside the RAFB security fence (Figure 2). Access would be primarily for construction vehicles and equipment. Contractors and heavy equipment operators would adhere to applicable safety regulations and guidelines. As stated in Section 3.8, construction personnel may be required to park at off-site parking facilities and to access the Project Site using a City-provided shuttle service. This would assist in reducing dust impacts to residential/commercial buildings along the access route and to RAFB. For construction personnel accessing the Project Site, traffic counts during construction activities would depend on the use of the shuttle service, but are anticipated to be minimal. Determination of access and security would depend on lease ownership of the G-RAMP facilities. Regarding construction traffic near Taxiway E, RAFB and the City would jointly develop and coordinate a Construction Vehicle Traffic Plan with airport users, air traffic control, and the appropriate construction engineers and contractors. The plan, when signed by the participants, would become part of the contract. Airfield Management and Safety are responsible for coordinating and enforcing the plan. During operation of the Proposed Action, traffic flow from State Highway 247 and North Davis Drive is expected to increase near the Project Site. The exact number of future employees working at the G-RAMP facilities is not known at this time; however, it is assumed for this analysis that up to 150 new jobs would be created at the new facility. As such, it is anticipated that the number of additional personnel would be insignificant considering the existing traffic from the approximately 25,584 people who access the base daily (URS 2009b). The overall September 4, 2012 54 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 traffic at or surrounding RAFB is not expected to increase significantly as a result of the Proposed Action. Ample parking space would be available at the new facilities. 4.9 Safety 4.9.1 No Action Alternative Under the No Action Alternative, there would be no significant adverse or positive effects on safety because conditions at the Project Site would remain unchanged. 4.9.2 Proposed Action The Proposed Action would have no significant adverse or positive effect on safety. Personnel driving the access route to and from the Project Site (during construction and implementation of the Proposed Action) would be expected to adhere to local traffic laws, including adherence to the posted speed limit. As stated in Section 3.9, military and non-military personnel working at the Project Site would be protected by observing OSHA and RCRA regulations. Military personnel at the G-RAMP facilities would also be protected by observing AFOSH standards. Aircraft flight operations and patterns associated with RAFB would be conducted in accordance with RAFB's flight operation and safety procedures. 4.10 Cumulative Impacts CEQ regulations stipulate that potential environmental impacts resulting from cumulative impacts should be considered in the EA. A cumulative impact is the impact on the environment that results from the incremental impact of an action when added to other past, present, and reasonably foreseeable future actions. In accordance with NEPA, a discussion of cumulative impacts resulting from projects that are proposed, currently under construction, recently completed, or anticipated to be implemented in the near future is presented below. These projects are located on RAFB. No other projects outside the immediate vicinity of RAFB have been considered in this analysis because the Project Site is located on the east side of RAFB, where there are no current or anticipated land uses such as residential or commercial development. o 116 Air Control Wing (ACW) Mission Support Group (MSG) Facility (past): The recently completed 116 ACW MSG facility was constructed to consolidate 116 ACW assets within the East Ramp Campus in accordance with the 116 ACW Area Development Plan to consolidate ACW's components. Support functions that were located on the West Ramp were relocated to a new facility on the East Ramp. The 36,500-square-foot, one-story facility and associated parking lot were constructed on undeveloped land north of East Drive. Support personnel relocated to the new facility from their former West Ramp and work locations. The development of the site increased the area of impermeable land surface on the East Ramp and resulted in a temporary increase in air emissions, noise, and volume of solid waste generated by demolition/construction activities. Analysis of potential environmental effects from this 55 September 4, 2012 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 action resulted in a FONSI on the natural or human environment from construction and operation of the MSG facility. o Relocation of Marine Corps Units from Naval Air Station Atlanta (past): This project involved the relocation of Marine Corps Units (MAG-42, HMLA-773, and MALS-42) from Naval Air Station Atlanta to the RAFB East Ramp Campus. As part of the relocation, existing buildings were renovated, one building was demolished, and a new helicopter maintenance hangar and parking areas were constructed on the east side of the East Ramp Campus area. Beale Drive was realigned to accommodate the new facilities. Operations are conducted by approximately 200 to 300 Marine Corps personnel at RAFB 5 days per week, and focus on maintenance of 18 H-1 helicopters (12 AH-1 and 6 UH-1 aircraft) and related training and logistics activities. The construction and associated realignment of Beale Drive, in addition to the relocation of an atmospheric sensor, occurred within the 100-year floodplain and directly next to, but not within, wetlands. The area of new construction for the hangar (40,375 square feet) and parking areas (83 spaces) was approximately 4 acres. Construction of the new hangar facility and associated parking was determined to result in neither significant positive nor significant negative effects on floodplains, floodplain characteristics, or wetlands. The facility renovation, construction, and operation of the Marine Corps units and facilities were determined to result in insignificant direct impacts and cumulative impacts on the environment. Based on the evaluation, construction would produce temporary, insignificant adverse impacts on the physical environment, air quality, solid waste and toxic materials, and transportation, and a beneficial effect on the economy. Operations of the Marine Corps units were found to have insignificant adverse effects on water supply, air quality, waste management, noise, and transportation, with beneficial effects on safety and the economy. Analysis of potential environmental effects from this action resulted in a FONSI on the natural or human environment. Clear Zone (CZ) Improvements (current): This project involves improvements to the CZ and Graded Clear Zone (GCZ) on the south end of the runway at RAFB. These improvements are currently underway. The GCZ measures approximately 1,000 feet long by 2,000 feet wide and encompasses a designated wetland area (Wetland 25), drainages for stormwater runoff from the RAFB industrial area, and portions of a groundwater treatment system within former Landfill 02. The wetland and former landfill areas provide habitat for birds and other wildlife species. The CZ, measuring 3,000 feet long by 3,000 feet wide, encompasses wooded areas and wetlands that also provide wildlife habitat. The improvements within the CZ and GCZ have resulted in filling approximately 19.5 acres of wetlands, including approximately 2 acres within the 100-year floodplain, to provide level topography that can be maintained in turf grass next to the runway, and rerouting existing stormwater drainage through the area. The project location is determined by the proximity of the runway and the dimensions of the CZ and GCZ, and o September 4, 2012 56 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 there is no practicable alternative to construction within the 100-year floodplain and filling adjacent wetlands. Construction will permanently alter topography to meet Unified Facilities Criterion 3-260-01 (Airport and Heliport Planning and Design) for the CZ, and cause temporary and insignificant impacts on surface water, floodplain, wetlands, stormwater, geology and soils, air quality, the noise environment, the biological environment, safety, and transportation. Operation after the proposed action will cause only insignificant adverse effects on air quality from minor vehicle emissions during airfield turf maintenance, and the wildlife displaced by the small area of wildlife habitat lost from filling the wetlands will be easily accommodated by the extensive natural areas next to the proposed Project Site. Wetland credits purchased from a wetland mitigation bank will compensate for the unavoidable loss of wetlands. There will be no addition of impermeable land surface or personnel associated with the improvements. The Proposed Action will have short-term beneficial impacts on the socioeconomic environment from construction expenditures, and improve airfield safety by reducing the potential adverse effects from an aircraft mishap during departure or landing and the risk of bird/wildlife strikes on the airfield. Analysis of potential environmental effects from this Proposed Action resulted in a FONSI/FONPA on the natural or human environment. o Construction and Operation of Waste-to-Energy (WTE) Plant (current/future): This Proposed Action involves the construction and operation of a plasma gasification WTE plant on RAFB that would employ plasma arc furnace technology and would process much of the non-recyclable, non-hazardous waste at RAFB. The operation of this facility would greatly reduce the amount of waste from RAFB that is entering landfills. Temporary, insignificant adverse affects from construction, and insignificant effects from operations, would be minor due to employment of BMPs. The Proposed Action would not contribute to air emissions to a significant degree. Process cooling water would be recycled wastewater. The quantity and quality of wastewater from this Proposed Action would not significantly impact wastewater treatment operations. Noise generated from the Proposed Action would be typical of that already begin generated in the central industrial portion of RAFB. The Proposed Action would produce a short-term positive effect on the regional economy from the purchase of goods and services. There would be long-term benefits from the additional of personnel and the reduction/elimination of costs associated with current waste disposal practices. Analysis of potential environmental effects from the Proposed Action resulted in a FONSI on the natural or human environment. Clear Zone (CZ) and Accident Potential Zone (APZ) Selective Tree Removal (future): This project would occur within the CZ and APZs north and south of the runway at RAFB. The overall area is undeveloped wetland and floodplain areas associated with Echeconnee Creek, Horse Creek, and the Ocmulgee River floodplain complex. The Proposed Action consists of selective tree cuts on RAFB property and o September 4, 2012 57 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 removal of timber by a timber contractor. As a conservative measure, trees that penetrate the imaginary glide slope or extend closer than 15 feet below the elevation of the imaginary surface would be cut. This represents an area approximately 20 acres in the northern CZ, 52 acres in the southern CZ, and 148 acres in the southern APZ. Implementation of the Proposed Action would have no adverse effects on topography, stormwater, groundwater, water supply, or waste or toxic materials. There would be insignificant adverse effects on surface waters, floodplains, wetlands and associated soils, air quality, biological resources, cultural resources, and noise. There would be short-term, minor beneficial effects on socioeconomics, a potential long-term beneficial effect from the change in forest composition and structure that would benefit wildlife that depend on forest openings, and a beneficial effect on airfield safety. The Proposed Action is located mainly within the 100-year floodplain, and the area contains wetlands. Floodplain and flood zone characteristics would not change, and there would be no effect on the function of surface water conveyance or flood storage capacity. No debris would be left in the floodplain. Soil disturbance would be reduced by leaving stumps in place. Wildlife would be temporality affected by construction noise; however, wildlife are accustomed to the significant aircraft noise that dominates the Proposed Action area. Displaced wildlife would relocate to unaffected areas of the adjacent bottomland hardwood swamp. Analysis of potential environmental effects from the Proposed Action resulted in a FONSI/FONPA on the natural or human environment. The following is a discussion of the potential cumulative impacts that may result from past, current, and future actions: The current and future projects listed above would involve only temporary construction traffic during implementation and would not involve travel to the proposed G-RAMP facilities that may be accessed by RAFB and contractor personnel. Potential direct and cumulative effects from construction and operation of these projects have been addressed through environmental reviews, and would be addressed through existing permit requirements and by permit modifications as necessary. The demolition and construction activities associated with the projects listed above have increased or would increase the area of impermeable surface and temporarily increase air emissions, noise, and volume of solid waste and toxic materials generated. The 116 ACW MSG and Marine Corps projects have already been constructed, and temporary effects associated with the demolition and construction of facilities have already occurred. The CZ Improvements project is currently underway, and construction-related impacts from the CZ improvements are unlikely to occur at the same time as the Proposed Action, thereby further reducing the potential for temporary, cumulative adverse effects. Operations associated with the above-listed projects would not significantly increase air pollutant emissions. September 4, 2012 58 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 The effects of noise generation from construction activities and implementation associated with the projects would be considered temporary and insignificant. Noise would not have a cumulative adverse effect on the environment. The facilities are in the elevated noise environment of the flight line, and long-term combined operations of these facilities would not increase the noise levels significantly. Cumulative increases in the generation of solid waste have or would occur from construction activities. Materials have been or would be recycled where feasible, and waste generation would not be significant compared to the solid waste generation for RAFB. Solid waste generated by the above-listed projects would represent a minimal cumulative contribution relative to the solid waste generated by RAFB. The WTE Plant project would represent a beneficial effect by greatly reducing the amount of waste from RAFB that is entering landfills. Further, the cumulative increase in office-type solid waste generation would be minor relative to the existing RAFB population and insignificant considering the population in the Warner Robins MSA and the number of personnel currently at RAFB. Houston County has committed to providing solid waste disposal services to RAFB. This landfill is a permitted municipal solid waste landfill with 8 years of useful life remaining, and a permitted construction and demolition landfill with 35 years of useful life remaining (GA EPD 2009), and could acquire approximately 50 years of additional capacity through expansion of if needed (URS 2009b). Cumulative increases in the generation of toxic materials may have occurred from the demolition activities in the project areas. Surveys for ACM or LBP would have been performed on the structures before demolition. Identified toxic materials would have been removed and disposed of in accordance with applicable regulations. Cumulative increases in stormwater runoff due to increased impermeable surface area were determined to be insignificant. There would be a net increase in impermeable surface area from the Proposed Action. Site-specific design features have been or would be employed at each project site listed above to limit the volume and rate of stormwater runoff so that the effect from the cumulative volume of runoff would be insignificant. The construction contractor would be required to implement practices under individual approved ESPCPs, as applicable to each project requirement, to control stormwater runoff so that adverse effects on stormwater and surface water quality would be insignificant. Because of these control measures, the resulting cumulative effects on stormwater volume and quality and surface water quality would be insignificant. There would be no cumulative effects on potable water use because the Proposed Action would not share potable water with RAFB but instead use water supplied by the City. There would be no significant cumulative increase in sanitary wastewater generation from the Proposed Action and other projects, based on the City's Ocmulgee River Water Pollution Control Facility No.1 capacity of 3 MGD and the current operating average volume of approximately 1.2 to 1.5 MGD. September 4, 2012 59 G-RAMP Environmental Assessment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Cumulative effects from the loss of flood water storage capacity in the Ocmulgee River floodplain from the Proposed Action and other projects would not be significant because the placing of fill would result in no significant impact on the overall conveyance of stormwater, and the remaining floodplain contains sufficient storage capacity for the displaced flood waters. Cumulative effects from wetland loss or a net change in wetland area are not anticipated. Potential direct and cumulative effects on wetlands resulting from the above-listed projects have been addressed through separate environmental reviews, and would be addressed through existing permit requirements and compensatory mitigation as necessary. The Proposed Action is not anticipated to result in impacts to wetlands. Impacts that may result to wetlands next to the Project Site would be offset in the region by compensatory mitigation. As necessary, the City would compensate for the wetland loss by the purchase of credits from a wetland mitigation bank. The loss of wetland habitat locally would have limited to no effect on wildlife, stormwater, or surface water resources because of the vast acreage of bottomland hardwood swamp and other wetlands located on RAFB and throughout the adjoining Ocmulgee River floodplain, primarily east of the Project Site. The projects as a whole have produced or would produce small positive effects within the region of economic influence during the construction of the facilities. The cumulative effect of these projects would result in significant economic benefits to the local economy. The Proposed Action, in combination with the other projects listed above, would not produce a significant adverse or positive cumulative effect on the remaining environmental resources because the Proposed Action would not make a significant contribution to potential effects, and the other listed projects were not identified as significantly impacting these resources. Therefore, a significant cumulative effect would not occur from the implementation of the Proposed Action. 5.0 Conclusions With implementation of the design, construction, operation, and management actions or mitigation measures identified in the EA (summarized in Table ES-1), no significant adverse environmental impacts are anticipated for the Proposed Action. A FONSI/FONPA is recommended, and an EIS is not required. Table 5-1 below identifies the required permits and plans for implementing the Preferred Alternative and for supporting the FONSI/FONPA. September 4, 2012 60 G-RAMP Environmental Assessment 1 Table 5-1 Summary of Permits for Proposed Action Permits Requirements under Proposed Action Land Disturbing Activity Permit - Houston County NPDES Permit GAR100001 (approval to discharge stormwater associated with construction activity); Notice of Intent o Erosion, Sediment, and Pollution Control Plan N/A o CWA Section 404/401 Permits - Nationwide Permit or Individual Permit from USACE o Analysis under EO 11988, Floodplain Management o Letter of Map Revision from City to FEMA o NPDES Permit GAR100001 (approval to discharge stormwater associated with construction activity); Notice of Intent N/A N/A N/A If PTE emissions of PM2.5, PM10, SO2, CO, NOx, or VOC exceed 100 tons per year or if total HAPs exceed 25 tons per year, or an individual HAP PTE exceeds 10 tons per year, a major source Title V operating permit must be obtained. N/A N/A A storage permit is not required for storage of hazardous waste under 90 days. N/A Noise permit from the City engineer required if construction within City limits occurs between the hours of 6:00 p.m. and 7:00 a.m. N/A N/A N/A N/A N/A o o Resource Area Topography Surface Waters Floodplain and Wetlands Stormwater Geology and Soils Groundwater Water Supply and Drinking Water Air Quality Wastewater Solid Waste Hazardous Materials and Waste Toxic Materials Noise Environment Biological Environment Cultural Resources Socioeconomic Environment Transportation Safety 2 September 4, 2012 61 G-RAMP Environmental Assessment 6.0 List of Preparers Josh Jenkins, PG, PMP Project Manager AMEC Art Warner Warner Robins Office Manager AMEC Elaine Flock Project Scientist AMEC Brian Hoogerwerf Geographic Information System Specialist AMEC Shane Peden Geographic Information System Specialist AMEC Bob Hardy Technical Editor AMEC September 4, 2012 62 G-RAMP Environmental Assessment 7.0 Persons Contacted Russell Adams, 78th CEG/CEANQ Rebecca Crader, NEPA Office Fred Otto, 78 CEG/CEANQ Bob Sargent, 78 CEG/CEAN Heidi Schwingle, 78 CEG/CEANQ Gary Lee, Executive Director, Redevelopment Agency, City of Warner Robins Charles Beauchea, PE, Assistant City Engineer, City of Warner Robins Laura Mathis, Middle Georgia Regional Commission September 4, 2012 63 G-RAMP Environmental Assessment 8.0 References Bureau of Economic Analysis (BEA). 2010. Previously Published Estimates, Regional Accounts. Accessed online at: http://www.bea.gov/histdata/RMyear.asp. Accessed on November 11, 2010. Carbon, R. 2008. Draft G-RAMP Business Plan. Prepared for the City of Warner Robins. August. Carter & Sloope Consulting Engineers (Carter & Sloope). 2009. Preliminary Engineering Report, G-RAMP Project Infrastructure Improvements (Georgia-Robins Aerospace Maintenance Partnership). Prepared for the City of Warner Robins and Houston County Board of Commissioners. June. Council on Environmental Quality (CEQ). 1997. Environmental Justice. Guidance under the National Environmental Policy Act. Available online at: http://clinton4.nara.gov/media/pdf/EJ.pdf. Accessed on November 29, 2010. Cultural Resource Analysts, Inc. (CRA). 2011. Phase II National Register Assessment of Site 9HT10 at the Proposed Georgia-Robins Aerospace Maintenance Partnership Facility, Warner Robins, Georgia. Knoxville, TN. March 30. Department of Defense (DoD). 2003. Unified Facilities Criteria (UFC) 4-010-01, DoD Minimum Antiterrorism Standards for Buildings. October 8. Earth Tech/AECOM. 2008. Final Basewide Groundwater Sampling Spring 2008 Report. Prepared for Environmental Management Directorate, Warner Robins Air Logistics Center, Robins Air Force Base, Warner Robins, Georgia. November. Earth Tech/Rust E&I. 1999. RCRA Facility Investigation Report Site SS036 (Taxiway No. 4). Prepared for Environmental Management Directorate, Warner Robins Air Logistics Center, Robins Air Force Base, Warner Robins, Georgia. August. Ellis Environmental Group, LC. 2005. Final Integrated Cultural Resources Management Plan Robins Air Force Base, Houston County, Georgia Effective 2005 - 2009. December. Warner Robins, GA. Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Technical Report Y-87-1. U.S. Army Engineer Waterways Experiment Station. Vicksburg, MS. Federal Emergency Management Agency (FEMA). 2007. Flood Insurance Rate Map for Houston County, Georgia and Incorporated Areas. Panel 40 of 300. Map No. 13153C0040E. National Flood Insurance Program. Effective date September 28, 2009. September 4, 2012 64 G-RAMP Environmental Assessment Garrow & Associates, Inc. (Garrow) 1996. Archeological Survey of the Upland Portions of a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia. November. Atlanta, GA. Georgia Environmental Protection Division (GA EPD). 2009. List of 2009 Landfill Remaining Capacity. Available online at: http://www.gaepd.org/Documents/regcomm_lpb.html. Accessed on March 1, 2011.Georgia Soil and Water Conservation Commission. 2000. Manual for Sediment and Erosion Control in Georgia. 5th Edition. Georgia Soil and Water Conservation Commission (GSWCC). 2000. Manual for Sediment and Erosion Control in Georgia. 5th Edition. Updated through January 1, 2001. Athens, GA. Hodler, T.W. and H.A. Schretter. 1986. The Atlas of Georgia. Institute of Community and Area Development (ICAD), University of Georgia Press, Athens, GA. Houston County. 2011. Houston County Parcel Data. Houston County, GA. MACTEC Engineering and Consulting, Inc. (MACTEC). 2010. Draft Jurisdictional Waters Delineation Georgia-Robins Aerospace Maintenance Partnership (G-RAMP). MACTEC Project 687010F336. August 23. Alpharetta, GA. National Institute on Deafness and other Communication Disorders. 2010. Sound Ruler website. Available online at: http://www.nidcd.nih.gov/health/education/decibel/decibel_text.htm. Accessed on October 8, 2010. Natural Resources Conservation Service, U.S. Department of Agriculture (NRCS). 2010a. Digital Soil Survey for Houston County, Georgia. Available online at the Soil Data Mart at: http://soildatamart.nrcs.usda.gov/Report.aspx?Survey=GA640&UseState=GA. Accessed on October 1, 2010. Natural Resources Conservation Service, U.S. Department of Agriculture (NRCS). 2010b. Official Soil Series Descriptions. Available online at: http://soils.usda.gov/technical/classification/osd/index.html. Accessed on October 1, 2010. Soil Survey Staff, USDA, NRCS, Lincoln, NE. NatureServe. 2011. NatureServe Explorer: An online encyclopedia of life [online web application]. Version 7.1. NatureServe, Arlington, Virginia. Accessed on June 13, 2011 at http://www.natureserve.org/explorer. Preston Testing & Engineering Company, Inc. (Preston). 2006a. Preliminary Subsurface Investigation Report. August 18. Macon, GA. Preston Testing & Engineering Company, Inc. (Preston). 2006b. Phase 1 Environmental Site Assessment, PT&E #12602 of ?90 acres of Property Located at the Northeast Side of Robins Air Force Base, Warner Robins, Houston County, Georgia. July 31. Macon, GA. September 4, 2012 65 G-RAMP Environmental Assessment Robins Air Force Base (RAFB). 2007. Robins AFB Integrated Natural Resources Management Plan 2006 - 2010. 78th Civil Engineer Group, Environmental Management Division, Robins AFB, Georgia. May. Robins Air Force Base (RAFB). 2010. Integrated Solid Waste Management (ISWM) Plan. Environmental Management, Robins AFB, Georgia. July. Sargent, B. 2011. Comments on G-RAMP Revised EA received on June 2, 2011. 78 CEG/CEAN, RAFB, Warner Robins, GA. U.S. Air Force (USAF). 1998. Air Installation Compatible Use Zone (AICUZ) Study, 1997/1998. Volume 1. Prepared for Robins Air Force Base, Georgia. U.S. Army Corps of Engineers (USACE). 2010. Interim Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Atlantic and Gulf Coastal Plain Region, eds. J.S. Wakeley, R.W. Lichvar, and C.V. Noble. ERDC/EL TR-10-XX. Vicksburg, MS: U.S. Army Engineer Research and Development Center. U.S. Census Bureau. 1995. Statistical Brief, Poverty Areas. Accessed online at: http://www.census.gov/population/socdemo/statbriefs/povarea.html. Accessed on November 29, 2010. Last revised September 5, 2002. U.S. Census Bureau. 2001. Overview of Race and Hispanic Origin. Census 2000 Brief, C2KBR/01-1. Available online at: http://www.census.gov/prod/2001pubs/c2kbr01-1.pdf. Accessed on November 29, 2010. U.S. Census Bureau. 2010. Fact Sheets. Information gathered from Internet Site, http://www.census.gov/. Accessed on November 15, 2010. U.S. Environmental Protection Agency (USEPA). 2009. Technical Guidance on Implementing the Stormwater Runoff Requirements for Federal Projects under Section 438 of the Energy Independence and Security Act. EPA 841-B-09-001. Washington, D.C. U.S. Environmental Protection Agency (USEPA). 2010. National Ambient Air Quality Standards. Accessed online at: http://epa.gov/air/criteria.html. Last updated June 3, 2010. Accessed on March 25, 2011. U.S. Fish and Wildlife Service (USFWS). 2010. Threatened and Endangered Species List. U.S. Fish and Wildlife Service, Region 4, Georgia Ecological Services Field Office. Available online at: http://www.fws.gov/athens/endangered/counties_endangered.html. Accessed on July 23, 2010. September 4, 2012 66 G-RAMP Environmental Assessment U.S. Fish and Wildlife Service (USFWS). 2011. Critical Habitat Portal. Environmental Conservation Online System. Available online at: http://criticalhabitat.fws.gov/crithab/. Accessed on October 5, 2011. U.S. Geological Survey (USGS). 1973 (photorevised 1984). Warner Robins NE, Georgia 7.5minute series topographic quadrangle. U.S. Department of the Interior. TopoScout(R). URS Corporation. (URS). 2012. The Delineation of the Minshew-Thomas-Sullivan Cemetery (9HT128), G-RAMP, Robins AFB and the City of Warner Robins, Houston County, Georgia. Warner Robins, GA. URS Group, Inc. (URS). 2009a. Final Environmental Assessment Clear Zone Improvements on the South End of the Runway at Robins Air Force Base, Georgia. Atlanta, GA. URS Group, Inc. (URS). 2009b. Final Environmental Assessment Demolition of Buildings 2052/2054 and Construction and Operation of New Avionics Facility Project UHHZ033013. Atlanta, GA. September 4, 2012 67 G-RAMP Environmental Assessment APPENDIX A FACILITIES REQUIREMENTS FOR MILITARY AIRCRAFT September 4, 2012 4.4-4444`*? .14.I.IVII lily. . *i24.. .Jo4`xsi4..: 4 II iv II II, II.-, IIPII., Vi3gVv pv,-I I -1-- I I I Vg?4.-.f-Vt_ :ay\ inn Gia. ...4. .4..4-wx-?{Atv} I I .413 4>>54**q.4_ I Ml it-I.,4444IL- LIIV . IuiIIBV 'V4594.. .II.4..7**4*..-. . 5..: 4:_x -, . II .4 Itaixgh I I I I II I -44 _4,t I IIE.-- ..5.- . 0 Ii.;-.4444.;. I . fr 45 -44 . 4,4444`4nYII . Tvwi'; Ig]- lf 7; 5 {ya? NsIll; . .. . hy444Slt.*11.51sm1.- yan.2pijiEXTZQ \.z-qqIEE E0. ?ji-j .5 - -.1-. it i 1 Lo{2mLS1--., . . -- .-.- .. P- ..1--..2 --uy - . 'o'lif 9-rafi{gl..-.-.- - Hugirq, .-.1L--. no--.-3.v-A nnh-.Jiu .I.. IL . tj'5?u4- . L- ig, r- 5.1;1n1>> .. - -.1., 1,.x 1 il? wi1.-.- Alla-I.EUR -5-t:[ggTZ. ate,?-.-I.-I. ., I - A- ra-: - if-IY II 4 - lc G-RAMP Environmental Assessment APPENDIX B AGENCY AND TRIBAL COORDINATION AND RESPONSES September 4, 2012 I .I 4 VV--_ri_ EixgmLing `ilt . P*kt\or fps1*2; 4 1, ,7 `i ilVET `ywo NV ;i ,t_f4T qmpingiy? MQW., rn V. - . fj: -VYi'? 4* {xiEQLY pr'lL. ?1 VV I Ill - - -- -- -- -- ,7 A 2 I 1, . mqvi": I-hh i/i"i*r U.), QYSEJ ~pkI . ria! g` iwkrv.,MrazZirg`; M. -- .74-:;-7.`tv-Kjxgir *--, V--7V V477jgxkwNr.; Lv: '2e~???--7. . rw 7-.V .31.?.7>>rrJ . . . .-77 -- 7?yyr,y.--. . . . .. J*?Zi,7?{ . . . IPL . ..K..--. ,416 . .C--. 7 fx .74*.179;* '/ii? xsi- 7?'qi--7gv. f?7V 7-. 7 .5 . .7..'7=5h--, Mini 'ir {vvVN..57.. ?7 ..7: Q. A .r'L 7 gw j"V 7. 4, **~y12nilr VVAV Vxaix; xy {yam7--1.4 . . 7.?rslwz; 7 - 577[:i_Y7 Wig innVV.: ?7 V5 ~7 77 eV `Vw'7 V. .7 7- 7 77 rvi_7g7;-igyq;. . . I u?k,J Gm rv .7 7 7V.7,.7 77 7,77V"i .7- 7,.7.7 7 7 7; 7. 7~ 777_X-fr 7 7 .., VVA74VFVV7 Vw4.1*.V-77.. 7. 7V 7VV VV DKHV V-ga7?VVIAQ f`?}n};hJ *7 VQ 7 7'"Jk'`7777 yy-.1%..7V-7.-$(7-77 7,.VV.7, -7. 4 4 VH _444 7 -F ='Vi 7 nv {-Ilif-; 4* - 1 (EV ST VV--VLVV-- -.77 .Xihwt .,erwi 6--7. 7.7. 6 r'V1??1v7' $7-7 --7 .V A 777.77 Yi 7.777 7 1- . :7 sv 7 >>27*. 7, vv 77 ..7. 777..7VQ 5 VA V. AAUAVijVoVor*"' rg;!v,f9a -6-K2, fVgina a V. eV 1-,VAVV- arA-AV-AV'wiw AJ AL i?spfi gh;. yy xy- *1 - 7--r7 AA VVA.-A . A .A --4 AV A-VAW. Vx--MV., u, V- .V A mcErWe$-V.-AAVV 2-. {fw,Viw-?-VV..VV A 4.QQMAwc}; iwly JZ A. VW wl`; V, .7. Ita z. A-uf*17iV"r? ngv`r7Y I:7j7y777.2- 37 .: 77?7'? l' ,7 Li L-- 6755*:777* 4* ,7 r`4rx,_sgk_ Nei 7.sCf 17:97* -7- ,,7,{*72 7777 . 7:77 7 7 7 x. ?u77--7*377 Wis374*-7.77,7,. Q7.- .7777-. 777*77o:17\ 7 777*7*"7<7 VV 7 ix 7 UV- 7'T?5;;-475 .,_7q_7l 7- 777,7; 77; r_ 7-.7:7;-hy] r71757)) 7. er |,5o,77r 7.Vx; F7- va-77 ""Ynlx 777 77? ~7-7-igv. 7f 77 "7l?77.77.-, V7 K7V.3757 7STV 77-. 7 7 7777 i'..717 7:2-.7 77.,?77.7.7c7i7.7,7 77 ,7 7737 =~7eL7? {77. ,17 lwkfur r_ 7 77 77 7..7 -777-777 77 777 7.,-7--WVVN 7;**47327'Enh 77-; ggwy 77 bkh`Tcg itas- e-42`lv14..r .. . .7 - {xy; rmvj$'7.-V.7RAXL 1 py si .r . . iqVai{Yipwgcia-'-gigpyak argl"fti VIV. .. A15 gr I ,2 ms? .2g ..IVII . ,r?rj_RL_, . uv.ffiiTA:{TZ lg . ij I BT: o,'ffrf gtk-Vii[Vw vgJu. ji, 'xlr {wd ,11rV?? . VV -- 7''-..-- . -- .v . Sv-gi . . -- -. . wilTPS4...777 . 777777 .. 2 -- . . . ..-- w-.V-.-pgZgli i4VVA U.: .54} 77phJJEV 7 tr Vein YPNY ..-7. 7 . .. 77-7 .VZ gymsV.-7.-. . - - 7-VVMss. qi; Vr V. Vw. V- Nqr..-- .. ,xxJK-..- Qx:1 4??wv;. 4 eV .VV?ia -- *6*4vi`YairVVLV irq ;j%rm I Y-at wzrvv_Y--.- 5 7-. 3 7 nc. ae. 2,7,.pair up{ral Ut-5, gw, 7,Tinv - 7 ., rx7,./.xirr 77>> 7 7 3, Gnu.}; -- i gl -2 af-( i' MM I 9 Tv,` in J5 A. ,7 ji1?f_rex.77-vi -- i_ 7 7_ fs .3;.t -- yr, ..7.?i gn-*ri., .777.v7-?VV}?oo721 2-awrg, {Aj--.-77--Lie.77_7`7I.. .EUR .77;- *1 7777 72 5; ,77 9 gw7.77"y?if *95,93. Mr.45. L. I sr ?rV "7 `jle wi7.7* 7 7 77,7,.,)Gi_-7-M7-V +7 . .-7--. ...777..77gis:.,77_ 77. TVQ77777sa.777 7.-, V7 ?7VV-fw . F7 .. .-. . {3V.-7. . 7 7 . 7..tm7-7--.-- 7. . 7 7 V, Ve 774 o7.?Vg?w-Q-.: 1 5* V, A ig wV Oglrr VV VWV.333*1953yn:. will . ?r_T4.37.44YoAA--. 4CZ .AA5;*1 . [2 5 -- on 4__45 ..'Vyis,r_VV -- j,,r.A.yy.- ki 3 4 FJ ug-ix"; 9:KWVj"`rryy--4 4- 1 3. -V A .7: :51; ;V?vav-if i. q--2-i 7* yp: Hxuu,."`Yir lets`!VKVN ViVAIV 5awe-E.; ki . '1 W-V-- . . ., Z. -- v:.--7?~r_V Vi__ . _jpg,. . V, Jr.J/mv 7 Z-VM{jxir.1QV {Vw_jjVV..- 2. .-- .Vsrv.sul7;._jV -- -- - *jiespir ?.7l 7" rjk-.757:vaq. La`? l* .7. 7 7-.-- -.-- '_,*3.4.cw-1 7 -777r7{7Jj`$viH_ rf9,;,ag*.H., _r.7 *5 7 VV V. 7..7 .7 77:7;va7>7? Lkeju 7-7-..--7.177 *7 __Vr - i--.77.-7 -77.7 .-.7777>>. A4vb..-7. "'g7 -.77 -7 7 I i71"'#-25.77__7 7;7;"ii 777,7,777r-; - _7 -+77 -7 #7 . 7 7 777;,[yl I . . 7--1 . - . . '1rps-! IL I -525 Lurfiiv *\77.-- 7.777 fi;} JV tif" 4 . G: 52Lckli`-inq; 7 J, fl r_ 777_ ff1.-- gifnvii zrgAor_I7.-7,.77{5vv.7..777 _77_ *siwe? sense- 4 >>-vgg . . -Z '7 5 T5 4 V- gz-; v? wo . `gi? (fj; -- . 1 V, wi 777 1**- F1 uusn 4 $1 ,-Wy:- rg A gh. .v uv ';j4'ii g? `jtsn z?-J Ref-; ;r J, . Zig" va -- ig . mrsI., vJ?6?rv;`V-.. ., . *.j'x..VV. - . ., 7 it- `Lyjz .EUR if -7..kaiicyQ-V-VV 1 T, ller:} 9: QM A A 44:sgg Fopit. '{`fiwaiTexwwA-jk1435 Ax. . am - 42 ?Ll_vFlock, Elaine From: Sent: To: Cc: Subject: Jenkins, Josh Thursday, August 19, 2010 9:18 PM Warner, Arthur Bales, Nancy; Flock, Elaine FW: G-RAMP Project From: Bryant J. Celestine [mailto:celestine.bryant@actribe.org] Sent: Thursday, August 19, 2010 9:08 AM To: Jenkins, Josh Subject: G-RAMP Project Dear Mr. Jenkins: On behalf of Mikko Oscola Clayton Sylestine and the Alabama-Coushatta Tribe, our appreciation is expressed on your efforts to consult us regarding the Environmental Assessment for the Georgia-Robins Aerospace Maintenance Partnership Project in Houston and Bibb Counties. Our Tribe maintains ancestral associations within the state of Georgia despite the absence of written documentation to completely identify Tribal activities, villages, trails, or burial sites. However, it is our objective to ensure significances of Native American ancestry, especially of the Alabama-Coushatta Tribe, are administered with the utmost considerations. Upon review of your July 27, 2010 submission, no known impacts to religious, cultural, or historical assets of the Alabama-Coushatta Tribe of Texas should occur from this proposal. Should you require further assistance, please do not hesitate to contact us. Sincerely, Bryant J. Celestine Historic Preservation Officer Alabama-Coushatta Tribe of Texas 571 State Park Rd 56 Livingston, Texas 77351 936 - 563 - 1181 celestine.bryant@actribe.org 1 Joshua L. Jenkins, Project Manager MATEC Engineering and Consulting, Inc. 3200 Town Point Drive, Suite 100 Kennesaw, GA 30144 August 25, 2010 THPO#: 006580 Subject: Georgia-Robins Aerospace Maintenance Partnership (G-RAMP) EA, Houston County, Georgia Dear Mr. Jenkins, The Seminole Tribe of Florida Tribal Historic Preservation Office (STOF-THPO) has received MACTEC Engineering and Consulting's project notification for the aforementioned project. Due to the fact that the project area is within the geographic area considered by the Seminole Tribe of Florida to be ancestral, aboriginal, or ceded (NHPA 1966, Section b1, and 36 CFR, Section 800.2), the STOF-THPO would like to review any future cultural resource surveys prior to making any further comment. We thank you for the notification of this proposed project. Please reference THPO-006580 in any future documentation about this project. Sincerely, Direct routine inquiries to: Willard Steele, Tribal Historic Preservation Officer Seminole Tribe of Florida JLP:am Anne Mullins Compliance Review Supervisor annemullins@semtribe.com - -- DEPARTMENT OF THE ARMY --. SAVANNAH conns or - COASTAL ALBANY nam omca j;f - 1104 NORTH wasrovzn aouravmo. UNITS 4 ALBANY, eaonem arm . A A ii; - ArmNnoNor=: - August 17, 2010 .Regulatory Division 5% SAS-2009-00074 - QI zi] City of Warner Robins fyi Attn: Mr. Charl Beauchea, PE Assistant City Engineer I- 700 Watson Blvd. - PO BOX 1488 I ij-. Warner Robins, Georgia 31099 1; Dear Mr. Beauehea: - .5 referto the recent submittal dated July 27, 2010, sent on your behalf by MACTEC jj; Engineering and Inc., requesting our comments concerning the proposed - construction of an 420,000 square foot aerospace industrial complex adjacent to ?{5f Robins Air Base, in Warner Robins, Houston County, Georgia. This project has been - . _assigned iile number It is important that you refer tothe assigned number in Q-. all communication concerning this matter. . .- . Based on a review of the information provided by MACTEC, as well as the information you . provided by letter dated January 9, 2009, it appears there may be waters of the United States on the project site. The US Army Corps of Engineers has been charged by Congress, under Section I 404 of the Clean Water Act (33 U.S.C. 1344); with the responsibility to regulate all activities performed in the waters ofthe US. The placem of fill material in waters of the US without .- i prior approval constitutes a violation of Section 404. To avoid any unforeseen problems, I recommend that a formal wetland delineation be submitted to our office for verification prior to -5 - ga performing any work on this site. By establishing Corps of Engineer's jurisdictional limits, 2 . possible problem areas within these sites may be addressed and difliculti avoided during the project development phase. Additionally, if you would like to set up a meeting for us to explain -- our program, policy, and procedur you may contact us directly. - i1` An important step in our review of an application is to determine the basic purpose of the project. A project's basic purpose acts to guide the scope of review pursuant to the Section - - 404(b)(l) Guidelines ofthe Clean Water Act as outlined in Title 40 of the Code of Federal Regulations (40. CFR), published in the Federal Register on December 24, 1980. However, a .stated_project purpose cannot_be made so specific that it effectively-precludes allother potential projectsites _ii?om considerationf At the same the project purpose amor `be so eral that -_we cannot make adetermination thatthe preferred alternative is the least enviromnentally- . 1 - - FF . . -2- The 404(b)(1) guidelines are sequential and require that permit applicants: (1) . unnecessary impacts to waters of the US on the preferred alternative to the maximum extent practicable; (2) minimize to the maximum extent practicable the unavoidable adverse impacts to waters of the US on-site; and (3) provide a compensatog; mitigation plan to replace the wetland and/or stream functions lost as a result of unavoidable adverse impacts associated with the . project. The USACE can only issue a permit for the least environmentally damaging practicable H- alternative that meets the project's basic purpose. Therefore, the basic project purpose is a critical element in our evaluation for compliance with the 404(b) (I) Guidelin . Please be advised that for projects impacting l/10 of an acre or more of wetlands or open water and/or 100 linear feet or more of stream, compensatory mitigation will be required to - replace any lost wetland and/or stream iimction. In addition, if either wetland or stream impact I - threshold is exceeded compensatory mitigation would be required for all impacts. The most preferable method of compensatory mitigation is the purchase of mitigation credits from a USACE-approved mitigation bank that services the project area. A complete list of USACE- . _approved mitigation banks in the State of Georgia can be found on our website at, Z: In the event that mitigation credits are . not available, mitigation may be accomplished by restoring, enhancing and/or preserving . wetlands and/or streams on or near the project site. Please be advised that submission of an - - application with an acceptable mitigation plan does not guarantee that a permit will be issued. The application form and information on the Regulatory Program are available on our website at Thank you in advance for completing our Customer Survey Form. This can be accomplished by visiting our web site at and completing the survey on-line. We value your comments and appreciate your taking the time to complete a survey each . time you interact withour office. If you have any questions, please feel free to contact me at 229-430-8567. - Sincerely, Terry C. . Regulatory Specialist, Coastal Branch - so DEPARTMENT o1= THE ARMY SAVANNAH conps or ENGINEERS . . ja COASTAL BRANCH, ALBANY FIELD o1=r=1cB gg ay 1104 NORTH wssrovsn BOULEVARD, UNIT ALBANY, GEORGIA 31707 REPLY T0 OF, January 28, 2011 Regulatory Division SAS--2010-01145 City of Wamer Robins Attention: Mr. Charles P. Beauchea, P.E 700 Watson Boulevard Post Oflice Box 1489 Warner Robins, Georgia 31099 Dear Mr. Beauchea: I refer to your November 23, 2010, letter requesting a preliminary jurisdictional determination for your site located northeast of and adjacent to Robins Air Force Base, southwest of the Ocmulgee River, in Wamer Robins, Houston County, Georgia (Latitude 32.6507, Longitude - 83.5876). This project has been assigned number SAS-2010-01145 and it is important that you refer to this number in all communication concerning this matter. We have completed an expanded preliminary Jurisdictional Determination (J D) for the site pursuant to the March 4, 2009, Public Notice entitled, "Characterization of Jurisdictional Determinations: Purpose, Application and Documentation Requirements as Defined by the Savannah District, US Army Corps of Engineers." I have enclosed a Check Sheet" that srunmarizes the D, delineation and appeals process. In your submittal your consultant, MACTEC Engineering and Consulting, Inc., stated their belief that the subject tract contains two potentially jurisdictional wetlands and one potentially isolated wetland (borrow pit). Their belief that the borrow pit is isolated is based on the presence of a man-made berm that separates theses wetland areas Hom the Ocmulgee River and its associated wetland systems. Wetlands separated from other waters of the US by manmade structures are adjacent to those waters (33 CFR Part 328.3 Further, the borrow pit is located within the 100 year flood plan and appears to have originally been partially excavated from wetlands. The potentially isolated wetland is therefore, considered adjacent to the Ocmulgee River. The wetlands/other waters on the subject property may be waters of the United States within the jurisdiction of Section 404 of the Clean Water Act (CWA) (33 United States Code 1344). The placement of dredged or iill material into any waterways and/or their adjacent wetlands or mechanized land clearing of those wetlands would require prior Department of the Army authorization pursuant to Section 404. - 2 - If you intend to sell property that is part of a project that requires Department of the Army Authorization, it may be subject to the Interstate Land Sales Full Disclosure Act. The Property Report required by Housing and Urban Development Regulation must state whether, or not a permit for the development has been applied for, issued or denied by the US Army Corps of Engineers (Part 320.3(h) of Title 33 of the Code of Federal Regulations). This communication does not convey any property rights, either in real estate or material, or any exclusive privileges. It does not authorize any injury to property, invasion of rights, _or any infringement of federal, state or local laws, or regulations. It does not obviate your requirement to obtain state or local assent required by law for the development of this property. If the information you have submitted, and on which the US Army Corps of Engineers has based its determination is later found to be in error, this decision may be revoked. Thank you in advance for completing our Customer Survey Form. This can be accomplished by visiting our web site at and completing the survey on-line. We value your comments and appreciate your taking the time to complete a survey each time you interact with our office. If you have any questions, please call me at 229-430-8567. Sincerely, i Terry C. Kobs Regulatory Specialist, Coastal Branch Enclosures Copy Furnished: MACTEC Engineering and Consulting, Inc. Attention: Arthur Warner 613A Russell Parkway Wamer Robins, Georgia 31088-6031 YW DEPARTMENT OF THE ARMY If.4 a r; savmum Rscuutronv JuR|s?|cT|oN1?EL|nEAr1ou cm-ack sneer I REPLY T0 memos op, Regulatory Division USACE FILE NUMBER: SAS-2010-01 145 DATE: am_L_ar;y 28, 2011 A. SECTION 1 - PRELIMINARY JU RISDICTIONAL DETERMINATIONS 1. JURISDICTIONAL DETERMINATION (JD). A "preliminary form was completed for the site in accordance with the March 4, 2009, Public Notice entitled, "Characterization of Jurisdictional Determinations: Purpose, Application and Documentation Requirements as Defined by the Savannah District, US Army Corps of Engineers." The form details whether streams, wetlands and/or other waters present on the site may be subject to the jurisdiction of the US Army Corps of Engineers (U SACE). In summary, the USACE has determined the following with regard to waters present on the site: There may be navigable waters of the United States (US) within Rivers and Harbors Act (RHA) jurisdiction present. There may be waters of the US within Clean Water Act (CWA) jurisdiction present. 2. DELINEATION VERIFICATION. With regard to the location and extent of potentially jurisdictional areas present on the site, the USACE has made the following determinations: Wetlands were delineated in accordance with criteria contained in the 1987 "Corps of Engineers Wetland Delineation Manual." Drawings submitted with a Pre-Construction Notification (or other application) depict the approximate location/boundaries of all potentially jurisdictional waters on the project site. The USACE has verified the accuracy of the depicted boundaries of potentially jurisdictional waters in only the irnrnediate vicinity of waters to be impacted. A complete jurisdictional delineation request, including a jurisdictional waters survey, would be required in order for the USACE to consider final verification of all other jurisdictional boundaries on the project site. The drawing entitled dated is an acceptable sketch of the approximate location/boundaries of all the potentially jurisdictional waters in the project area. This sketch can be used for initial real estate plarming; projects with temporary impacts to waters; projects involving minor amounts of fill in waters; or work only subject to our jurisdiction pursuant to Section 10 of the Rivers and Harbors Act of 1899. A complete jurisdictional delineation request, including a jurisdictional waters survey, would be required in order for the USACE to consider final verification of all other jurisdictional boundaries on the proj ect site. 3. APPEALS OF PRELIMINARY JU RISDICTIONAL DETERMINATIONS: The preliminary JD is a "non-binding" written indication that there may be waters of the US on a parcel. Preliminary JDs are advisory in nature and may not be appealed (See agreement with this preliminary JD, then you may request an approved jurisdictional determination for your proj ect site or review area. B. SECTION - EXPANDED PRELIMINARY JURISDICTIONAL DETERMINATIONS: 1. JURISDICTIONAL DETERMINATION (JD). An "expanded preliminary form was completed for the site in accordance with the March 4, 2009, Public Notice entitled, "Characterization of Jurisdictional Determinations: Purpose, Application and Documentation Requirements as Deiined by the Savannah District, US Army Corps of Engineers." The form details whether streams, wetlands and/or other waters present on the site may be subject to the jurisdiction of the USACE. In summary, the USACE has determined the following with regard to waters present on the site: There may be navigable waters of the United States (US) within Rivers and Harbors Act (RHA) jurisdiction present. There may be waters of the US within Clean Water Act (CWA) jruisdiction present. 2. DELINEATION VERIFICATION. With regard to the location and extent of potentially jurisdictional areas present on the site, the USACE has made the following determinations: Wetlands were delineated in accordance with criteria contained in the 1987 "Corps of Engineers Wetland Delineation Manual." The Global Positioning System (GPS) delineation entitled "Georgia-Robins Aerospace Maintenance Partnership Investigation Area and Potential Jurisdictional Waters", dated August ll, 2010, is an accurate delineation of the location/boundaries of all the potentially jurisdictional waters on the site. If you have not already done so, I recornrnend that you place a statement on this delineation to the effect that, AND OTHER WATERS SHOWN ON THIS DRAWING ARE POTENTIALLY UNDER THE JURISDICTION OF THE US ARMY CORPS OF ENGINEERS AS SHOWN. IN USACE FILE NUMBER SAS-2010- 01145. OWNERS MAY BE SUBJECT TO PENALTY BY LAW FOR DISTURBANCE TO THESE WATERS WITHOUT PROPER This delineation will remain valid for a period of 5 years unless new information warrants revision prior to that date. The survey entitled dated and signed by Registered Land Surveyor is an accurate delineation of the location/boundaries of all the potentially jurisdictional waters on the site. If you have not already done so, I recommend that you place a statement on the iinal surveyed property plat to the effect that, AND OTHER WATERS SHOWN ON THIS DRAWING ARE POTENTIALLY UNDER THE JURISDICTION OF THE US ARMY CORPS OF ENGINEERS AS SHOWN IN USACE FILE NUMBER SAS-2010-01145. - 2 OWNERS MAY BE SUBJECT TO PENALTY BY LAW FOR DISTURBAN CE TO THESE WATERS WITHOUT PROPER This delineation will remain valid for a period of 5-years unless new information warrants revision prior to that date. 3. APPEALS OF PRELIMINARY JU RISDICTIONAL DETERMINATIONS: The expanded preliminary JD is a "non-binding" written indication that there may be waters of the US on a parcel. Expanded Preliminary Ds are advisory in nature and may not be appealed (See 33 CFR. 331.2)." If you are not in agreement with this expanded Preliminary JD, then you may request an approved jurisdictional determination for your proj ect site or review area. C. SECTION 3 - APPROVED DETERMINATIONS: As defined in Regulatory Guidance Letter 08-02, an approved JD is an official Savarmah District determination that jurisdictional "waters of the United States" or "navigable waters of the United States," or both, are either present or absent on a particular site. An approved JD precisely identities the limits of those waters on the project site determined to be jurisdictional under the Clean Water Act (CWA) and/or the Rivers and Harbors Act (RHA). 1. JURISDICTIONAL DETERMINATION (JD). An "approved form was completed for the site pursuant to the June 5, 2007, Army Corps of Engineers (USACE) JD Form Instructional Guidebook." The form details whether streams, wetlands and/or other waters present on the site are subject to the jurisdiction of the USACE. In summary, the USACE has determined the following with regard to waters present on the site: There are navigable waters of the (US) within (RHA) jurisdiction present. There are waters of the US within (CWA) jurisdiction present. There are non-jurisdictional waters of the US located in the project area. There are no jurisdictional waters of the US located in the project area. 2. APPROVED DETERMINATION - ISOLATED, NON-JURISDICTIONAL WATERS. If Appendix of the March 4, 2009, Public Notice entitled, "Characterization of Jurisdictional Determinations: Purpose, Application and Documentation Requirements as Deiined by the Savarmah District, US Army Corps of Engineers" was submitted, you have requested that the USACE verify the presence of isolated, non-jurisdictional waters located at the project site or within the review area. The completed Appendix form is available at under the above listed file number. You may also request that a printed copy of the form be mailed to you. This isolated, non-jurisdictional determination will remain valid for a period of 5-years unless new information warrants revision prior to that date. In the USACE has determined the following with regard to isolated, non- jurisdictional waters that are present on the site: Wetlands were delineated in accordance with criteria contained in the 1987 "Corps of Engineers Wetland Delineation Manual." 3 Notification of Administrative Appeal Options and Process (NAP) Fact Sheet and Request for Appeal (RFA) Form. If you request to appeal this/these determination(s) you must submit a completed RFA form to the South Atlantic Division Office at the following address: US Army Corps of Engineers, South Atlantic Division Attention: CESAD-PDS-O, Administrative Appeal Review Officer 60 Street, Room 10Ml5 Atlanta, Georgia 30303-8801 In order for a RFA to be accepted by the USACE, the USACE must determine that it is complete, that it meets the criteria for appeal under 33 CFR, part 331.5, and that it has been received by the Division Office within 60 days of the date of this form. It is not necessary to submit an RFA form to the Division Office if you do not object to this jurisdictional determination. D. SECTION 4 - APPLIES TO ALL OF THE ABOVE. - US DEPARTMENT OF AGRICULTURE (USDA) PROGRAM PARTICIPANTS. This delineation/determination has been conducted to identify the limits of USACE CWA jtuisdiction for this site. This delineation/determination may not be valid for the wetland conservation provisions of the Food Security Act of` 1985, as amended. If` you or your tenant are USDA program participants, or anticipate participation in USDA programs, you should request a certified wetland determination from the local office of the Natural Resources Conservation Service prior to starting work. Attachments: Verified Survey of Jurisdictional Streams, Wetlands and/or Other Waters Verified GPS Delineation of Jurisdictional Streams, Wetlands and/or Other Waters Drawing of Approximate Location of Streams, Wetlands and/or Other Waters Approved Jurisdictional Determination Form(s) Notification of Appeal Process Fact Sheet /Request for Appeal Form fw Terry C. Kobs DATE Regulatory Specialist, Coastal Branch 5 There are isolated non-jurisdictional waters present that are not subject to CWA jurisdiction. Specifically, wetland(s) [letter of wetlands here], as identified on the exhibit entitled is/are isolated, non-jruisdictional wetlands. Department of the Army authorization, pursuant to Section 404 of the Clean Water Act (33 U.S.C. 1344), is not required for dredge and/or till activities in these areas. 3. APPROVED DETERMINATION. (other than isolated, non-jurisdictional waters): If Appendix of the March 4, 2009, Public Notice entitled, "Characterization of Jurisdictional Determinations: Purpose, Application and Documentation Requirements as Defined by the Savannah District, US Army Corps of Engineers" was submitted, you have requested that the USACE verify the presence of jurisdictional waters located at the project site or within the review area. The completed Appendix form is available at under the above listed frle number. You may also request that a printed copy of the form be mailed to you. This jurisdictional determination will remain valid for a period of 5-years unless new information warrants revision prior to that date. In summary, the USACE has determined the following with regard to isolated, non-jurisdictional waters that are present on the site: Wetlands were delineated in accordance with criteria contained in the 1987 "Corps of Engineers Wetland Delineation Manual." The Global Positioning System (GPS) delineation entitled dated is an accurate delineation of all the jurisdictional boundaries on the site. If you have not already done so, I recommend that you place a statement on this delineation to the effect that, WETLANDS AND OTHER WATERS SHOWN ON THIS DRAWING ARE UNDER THE JURISDICTION OF THE US ARMY CORPS OF ENGINEERS AS SHOWN IN USACE FILE NUMBER SAS-2010-01145. OWNERS MAY BE SUBJECT TO PENALTY BY LAW FOR DISTURBAN CE TO THESE JU RISDICTIONAL AREAS WITHOUT PROPER This approved jurisdictional determination will remain valid for a period of 5-years unless new information warrants revision prior to that date. The survey entitled dated and signed by Registered Land Surveyor is an accurate delineation of all the jurisdictional boundaries on the site. If you have not already done so, I recommend that you place a statement on the final surveyed property plat to the effect that, WETLAN DS AND OTHER WATERS SHOWN ON THIS DRAWING ARE UNDER THE - JU RISDICTION OF THE US ARMY CORPS OF ENGINEERS AS SHOWN IN USACE FILE NUMBER SAS-2010-01145. OWNERS MAY BE SUBJECT TO PENALTY BY LAW FOR DISTURBAN CE TO THESE JURISDICTIONAL AREAS WITHOUT PROPER This approved jurisdictional determination will remain valid for a period of 5-years unless new infonnation warrants revision prior to that date. 4. APPEALS FOR APPROVED JU RISDICTIONAL DETERMINATIONS: You may request an administrative appeal for any approved geographic jurisdictional determination under USACE regulations at 33 Code of Federal Regulation (CFR) Part 331. Enclosed you will find a 4 A licant: Ci of Wamer Robins File Number: SAS-2010-01145 Date: Jan 28, 2011 Attached is: See Section below - PROFFERED PERMIT (Standard Permit or Letter of . ermission) A PROFFERED PERMIT Standard Permit or Letter of 'ssion - PERMIT DENIAL - A1>1>11ovE1> JURISDICTIONAL DETERMINATION PRELIMINARY DETERMINATION A: INITIAL PROFFERED PERMIT: You may accept or object to the permit. ACCEPT: If you received a Standard Permit, you may sign the permit document and retum it to the district engineer for final authorization. If you received a Letter of Permission (LOP), you may accept the LOP and your work is authorized. Your signature on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all rights to appeal the permit, including its terms and conditions, and approved jurisdictional determinations associated with the permit. OBJECT: If you object to the permit (Standard or LOP) because of certain terms and conditions therein, you may request that the permit be modified accordingly. You must complete Section of this form and retum the form to the district engineer. Your objections must be received by the district engineer within 60 days of the date of this notice, or you will forfeit your right to appeal the permit in the future. Upon receipt of your letter, the district engineer will evaluate your objections and may: modify the permit to address all of your concems, modify the permit to address some of your objections, or not modify the permit having determined that the permit should be issued as previously written. After evaluating your objections, the district engineer will send you a proffered permit for our reconsideration, as indicated in Section below. B: PROFFERED PERMIT: You may accept or appeal the permit. ACCEPT: If you received a Standard Permit, you may sign the permit document and retum it to the district engineer for final authorization. If you received a Letter of Permission (DOP), you may accept the LOP and your work is authorized. Your signature on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all rights to appeal the permit, including its terms and conditions, and approved jurisdictional determinations associated with the permit. APPEAL: If you choose to decline the pro&`ered permit (Standard or LOP) because of certain terms and conditions therein, you may appeal the declined permit under the Corps of Engineers Administrative Appeal Process by completing Section of this form and sen the form to the division en ineer. This form must be received the division ineer within 60 da ofthe date ofthis notice. C: PERMIT DENIAL: You may appeal the denial of a permit under the Corps of Engineers Administrative Appeal Process by completing Section II of this form and sending the form to the division engineer. This form must be received by the division engineer within 60 da ofthe date of this notice. D: APPROVED JURISDICTIONAL DETERMINATION: You may accept or appeal the approved JD or provide new information. ACCEPT: You do not need to notify the Corps to accept an approved JD. Failure to notify the Corps within 60 days of the date of this notice means that you accept the approved JD in its entirety, and waive all rights to appeal the approved JD. APPEAL: If you disagree with the approved JD, you may appeal the approved JD under the Corps of Engineers Administrative Appeal Process by completing Section II of this form and sending the form to the division engineer. The division engineer must receive this form within 60 da of the date of this notice. E: PRELIMINARY JURISDICTIONAL DETERMINATION: You do not need to respond to the Corps regarding the preliminary JD. The Preliminary JD is not appealable. If you wish, you may request an approved JD (which may be appealed), by contacting the Corps district for firrther instruction. Also you may provide new information for further consideration by the Corps to reevaluate the JD. REASONS FOR APPEAL OR OBJECTIONS: (Describe your reasons for appealing the decision or your objections to an initial proffered permit in clear concise statements. You may attach additional information to this form to clarify where your reasons or objections are addressed in the administrative record.) ADDITIONAL INFORMATION: The appeal is limited to a review of the administrative record, the Corps memorandum for the record of the appeal conference or meeting, and any supplemental information that the review o&icer has determined is needed to clarify the administrative record. Neither the appellant nor the Corps may add new information or analyses to the record. However, you may provide additional information to clarify the location of information that is already in the administrative record. If you have questions regarding this decision and/or the If you only have questions regarding the appeal process you may also appeal process you may contact: contact: Terry Kobs Administrative Appeal Review Officer US Army Corps of Engineers, Savannah District CESAD-PDS-O Coastal Branch, Albany Field Office US Army Corps of Engineers, South Atlantic Division 1104 North Westover Boulevard, Unit 9 60 Street, Room 10Ml 5 Albany, Georgia 31707 Atlanta, Georgia 30303-8801 229-430-8567 RIGHT OF ENTRY: Your signature below grants the right of entry to Corps of Engineers personnel, and any government consultants, to conduct investigations of the project site during the course of the appeal process. You will be provided a 15-day notice of any site investi ation, and will have the yo rtimi to artici ate in all site investi ations. Date: Telephone number: Signature of appellant or agent. - - iz; . . NaturaI_Reeourees Conservation Service . . [3.55 East Hancock Avenue . I Athena, 30601 I "_:August 18,2010 .. I Joshua Jenkins . 2 I MACTEC Engineering Consulting, Inc. 3200 Town Point Dr., Suite 100 - Kennesaw, GA 30144 . -. Re; Coordination Requ . for Qeorgia-Robin Aero pace Maintenance This letter is in reference to your request for information on the possible impacts the proposed aerospace industrial complex project may have on land use, conservation, water quality and other . -- general environmental concerns that may be of interest to our following outlines Lourf concerns to farrnlandlramana Act is `ni-mr" '?pr-rsgrams - have on the unnecessary and irreversible conversion 0f uses. . Projects-?are subject to FPPA requirements if they may irreversibly convert farmland (directly or . indirectly) to nonagricultural use and are completed by a federal agency or with assistance from a federal agency. For the purpose of FPPA, farmland includes prime farmland, imique farmland, . and land of statewide or local importance. Farmland subject to FPPA requirements does not 5 - . have to be currently used_ for cropland. It can be forest land, pastmeland, cropland, or other land - gg uses, but not water or urban built-up land. It should be noted that the FPPA does not authorize . the federal Govemment to regulate the use of private or nonfederal land or, in any way, a&`ect the - property rights of owners. NRCS uses a Land Evaluation and Site Assessment (LESA) system to establish a farmland conversion impact rating score on proposed sites of federally tlmded and assisted projects. This score is used as an indicator for the project sponsor to consider alternative sites if the potential - adverse impacts on the farmland exceed the recommended allowable level. It is our - . understanding that,the proposed project involves federal fimds or assistance, and thus could be subject to this assessment. Please note, FPPA considers indirect as well as direct conversion. will be the project area. Areas planned for direct or _indirect . - conversion should be indicated on plans or maps included in the packet of materials for the - project. You will. need to. complete form USDA AD-11-006 foriyour visit: {iles/AD 1'026"i Instructipdf for for completion of the form? Additionally, contact Sherry Carlson, NRCS, in Tifton for . Helping People Help the Land . . - I P?sneeded at (706) 546-2013. The completed form should be sent to Sherry at . . Tilton Field Office, 1468 Carpenter Road South, Tifton, GA 31793 or . -3 . shgy .carlson@g.usda. gov. lj More than 50 years ago, the U.S. Department of Agriculture was authorized by Congress to help . . local communities with flood control_.and watershed protection through the Watershed Program (PL-534 Flood Control Act of 1944 and PL-566 Watershed Protection and Flood Prevention - - - -2 As--a 1-1,000 dams - .. . in 47 states since 1948. These dams were originally constructed for protection of farnrlands irom - . - flooding impacts. In 2000, PL-566 was amended to provide NRCS authorization to assist communities with rehabilitation of their aging dams. 'Ihe legislation authorizes NRCS to work Qi - with local communities and watershed project sponsors to address public health and safety concerns and potential environmental impacts of aging dams. gi We have reviewed our records and have determined that there are no NRCS dams - or in the vicinity of this project. . TQ- imcs Easements - . . easements relate to our Wetland Reserve.Program and the Farm and Ranch Land Protection Prog1?am. We have reviewed our records and have determined that there are no such . 3 easements within the vicinity of the proposed project that would be impacted. NRCS appreciates this opportunity to comment. If you have questions or need any additional 'on, please contact Dan Wallace of my staff at (706) 546-2278. -- I E. TIL tate Conservationist 7 n" cc: Natasha Brown, Assistant State Conservationist (F O), NRCS, Americus, GA Calvin Essex, District Conservationist, NRCS, Perry, GA - . Sherry Carlson, Resoruce Soil Scientist, NRCS, Tifton, GA . Dan Wallace, State Resource Inventory Coordinator, NRCS, Athens, GA - - Zi; '?IZIY I gc, - . -.. .. Il'. - 2 . ll--.. - 11Vgup"*zF `Lj?oIIv-`ilI-IVIV ill..-as-?iai L. I I- I-- - VIIV I. E4. tit GEOIGIA Nxrulm RESOURCES HISTORIC PRESERVKF ION DIVISION CHRIS CLARK DR DAVID COMMISSIONER DIVISION DIRECTOR August 12, 2010 Joshua L. Jenkins Project Manager MACTEC Engineering and Consulting, Inc. 3200 Town Point Drive, Suite 100 Kennesaw, Georgia 30144 iljenkins@@CTEC.com RE: Build Aerospace Complex, Robins AFB (GTRAMP), Warner Robins Houston County, Georgia HP--100811-009 Dear Mr. Jenkins: The Historic Preservation Division (HPD) has received initial information conceming the above referenced project. Our comments are offered to assist the US Department of the Air Force, Robins Air Force Base, and the City of Warner Robins in complying with the provisions of Section 106 of the National Historic Preservation Act of 1966, as amended (NHPA). Thank you for notifying us of this proposed project. We look forward to receiving Section 106 compliance documentation from you when it becomes available. Please note that HPD's address has changed, as indicated below. Please refer to project number HP-100811-009 in future correspondence regarding this proj ect. If we may be of further assistance, please do not hesitate to contact me at (404) 651-6624. Sincerely, Eli Enviromnental Review Coordinator ES: mn cc: Kristi Harpst, Middle Georgia RC 254 WASHINGTON STREET. Sw GROUND LEVEL GEORGIA 30334 404.656.2840 FAX 404.657.1368 or Nxrumr Resources HISTORIC PRESERVATION DIVISION i MARK WILLIAMS DR. DAVID CRASS COMMISSIONER DIVISION DIRECTOR .Tune 1, 2011 Charles Beauchea, P.E. City of Warner Robins 700 Watson Boulevard Warner Robins, Georgia 31093 RE: Build Aerospace Complex (G-RAMP), Robins Air Force Base, Warner Robins Houston County, Georgia HP-100811-009 Dear Mr. Beauchea: - The Historic Preservation Division has reviewed the report Phase National Register Assessment of Site 9HTI 0 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (G-RAMP) Facility, Warner Robins, Georgia, dated April 12, 2011 and prepared by Cultural Resource Inc. Our comments are oifered to assist the United States Department of the Air Force and Robins Air Force Base in complying with the provisions of Section 106 and Section 110 of the National Historic Preservation Act Based on the information contained in the report, HPD concurs that archaeological site is not eligible for listing in the National Register of Historic Places (NRI-IP). Please submit one electronic copy of the report to HPD. Please ensure the electronic copy is an optical character enabled .pd? For your information, the electronic iile will be sent to the Georgia Archaeological Site File at the University of Georgia, Athens for permanent curation. Please refer to project number HP-100811-009 in any firture correspondence concerning this project. If we may be of further assistance, please do not hesitate to contact Bob Entert] Review Archaeologist, at (404) 651-6775, or me at (404) 651-6624. Sincerely, Elizabeth . ES:ebp oc: Kristina Harpst, Middle Regional Commission I 254 WASHINGTON STREET. SW GROUND LEVEL ATLANTA. GEORGIA 30334 404.656.2840 404.6s7.1368 HISTORIC PRESERVATION DIVISION MARK WILLIAMS DR. DAVID CRASS COMMISSIONER DIVISION DIRECTOR Jrme 20, 2011 Charles Beauchea, PE City of Warner Robbins Asst. City Engineer 700 Watson Boulevard Wamer Robins, Georgia 31093 RE: Build Aerospace Complex (G-RAMP), Robins Air Force Base, Warner Robins Houston County, Georgia HP-100811-009 Dear Mr. Beauchea: The Historic Preservation Division has received the electronic copy ofthe report Phase National Register Assessment of Site 9HT10 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (G-RAMP) Facility, Warner Robins, Georgia which we had recently requested. Thank you for providing I-IPD with the electronic copy. For your information, the electronic copy will be sent to the Georgia Archaeological Site Files at the University of Georgia-Athens for permanent retention. Please refer to project number HP-100811-009 in any future eonespondence on this project. If we may be of further assistance, please do not hesitate to contact me, at (404) 651-6624. Sincerely, Elizabeth Shirk Environmental Review Coordinator ES zkac cc: Kristina Hazpst, Middle Georgia Regional Commission 254 WASHINGTON STREET, SW GROUND LEVEL GEORGIA 30334 404}.656.2840 FAX 404.6S7.1368 DEPARTMENT OF THE AIR FORCE gg ff; 78TH AIR BASE WING (AFMC) ROBINS AIR FORCE BASE GEORGIA APR 0 6 2012 78 620 -9th Sweet, Suite 230 Robins AFB, GA 31.098-1664 Mr. Leland Thompson Cousl1atta.Tribeiof Louisiana P.O. Box 8l8 Elton, LA 70532 RE: Georgia-Robins=Aerospace Maintenance Partnership (GRAMP) EA, Houston County, Georgia Mr. Thompson, I am writing toisend you the results of recent Phase II testing of a smallsite located near Robins Air Force Base, GA. The archaeological site 9'Htl0 received Phase I1 testing by MACTEC Engineering and Consulting (MACT EC) in consonance with the letter MACTEC. sent you on 27 Jihly 2010. The report ofthe Phase testing, entitled Phdse II Naaonal Register Assessment, ofSite at the Proposed Georgia-Robins Aerospace Maihtenan?e Partnership Facility, Warner Robins, Georgia; indicated a low density of artifacts discovered, a lack of identifiable tools, a lack of vertical integrity, and a paucity of diagnostic materials. Resultantly, the MACTEC archaeological staff determined that these findings do not support a recommendation for eligibility for. the National Register of Historic Places Upon review, Robins Air Porce Base concurs with the findings of the report, and, accordingly, also does- not recommend 9Ht l,0 to be_eligible for the RHP. A copy of MACTEC's, report, Blaise Il Natlongl Register Assessment of Site ,9I{t10 at the Proposed Georgia.-Robins Aerospace Mointenonoe Partnership (GRAMP) Facility, Womer Robins, Georgia, is enclosed on a CD. Phase Il National Register Assessment Site 9l--Itl0 atjhe Proposed Georgia-Robins Aerospace Mdintenanee Partnership (GRAMP acilig; Worner Robins, Georgia also mentions archaeologicaisite 9Htl26. This site was investigated by archaeologistsin l996 and was recommended to be ineligible for the RHP because only nine pieces of chert debitage were recovered. The report detailing the findig gs of this investigation, Arohaeologicdl Surve; ofthe Upland Portions oft; Proposed;Base Expiinsion Area Robins Air qree Bose, Houston County, Georgia, is also copied on the CD mentioned above. Site 9Ht],26 was briefly revisited during the pbase II evaluation ofsite 9Ht I0 and three additional pieces of debitagewere found. This site has produced a total of twelve artifacts, and, importantly, lacks diagnostic material and integrity. a result, Robins Air Force Base continues to coneur with the findings o?Archoe.ological Sttruey ofthe Upland Portions of a?Proposed Bose blrpansion. Area, l?obins Air Forfe Base, Houston Gountyi Georgia, and, accordingly, also does not recommend 9Ht I 26 to be eligible for the RHP. I have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, Jr., as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 775 Macon St., 1555, Robins AFB, GA, 3l098-- I664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 775 Macon St., I555, Robins AFB, GA, 31098-220l. MIT CHEL BUTIKOFER, Colonel, USAF Installation Commander Attachment: I. CD containing the reports: Phase ll National Register Assessment of Site at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey of the Upland Portions of a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia DEPARTMENT OF THE AIR FORCE 9 tg 78TH AIR BASE WING (AF MC) ROBINS AIR FORCE BASE GEORGIA APR 0 6 2012 78 620 9th Street, Suite 230 Robins AFB, GA 31098-1664 . Mr. Emman Stain -- -- ActingMarrager--?? - Muscogee (Creek) Nation P.O. Box 580 Okmulgee, OK 74447 RE: Georgia-Robins Aerospace Maintenance Partnership (GRAMP) EA, Houston County, Georgia Mr. Emman, I am writing to send you the results of recent Phase ll testing of a small site located near Robins Air Force Base, GA. The archaeological site 9Htl0 received Phase II testing by MACTEC Engineering and Consulting (MACTEC) in consonance with the letter MACTEC sent you on 27 July 2010. The report of the Phase II testing, entitled Phase II National Register Assessment of Site 9Htl0 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia, indicated a low density of artifacts discovered, a lack of identifiable tools, a lack of vertical integrity, and a paucity of diagnostic materials. Resultantly, the MACTEC archaeological staff detemrined that these findings do not support a recommendation for eligibility for the National Register of Historic Places (NRHP). Upon review, Robins Air Force Base concurs with the findings of the report, and, accordingly, also . does not recommend 9Ht10 to be eligible for the NRHP. A copy of MACTEC's report, Phase ll National Register Assessment of Site 9Htl0 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia, is enclosed on a CD. Phase ll National Register Assessment of Site at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia also mentions archaeological site 9Ht126. This site was investigated by archaeologists in 1996 and was recommended to be ineligible for the NRHP because only nine pieces of chert debitage were recovered. The report detailing the findings of this investigation, Archaeological Survey ofthe Upland Portions a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia, is also copied on the CD mentioned above. Site 9Ht126 was briefly revisited during the phase II evaluation of site 9Ht l0 and three additional pieces of debitage were found. This site has produced a total of twelve artifacts, and, importantly, lacks diagnostic material and integrity. As a result, Robins Air Force Base continues to concur with the findings of Archaeological Survey rf the Upland Portions cna Proposed Base Expansion Area, Robins Air orce Base, Houston Countv, Georgia, and, accordingly, also does not recommend 91-lt126 to be eligible for the NRHP. I have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, Jr., as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 CEGICL, 775 Macon St., 1555, Robins AFB, GA, 3l098- l664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 R, 775 Macon St., l555, Robins AFB, GA, 3 l098-220l. MIT CHEL BUTIKOFER, Colonel, USAF installation Commander Attachment: l. CD containing the reports: Phase II National Register Assessment rf Site 9Htl0 at the Proposed Georgia?Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey of the Upland Portions of a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia fg DEPARTMENT OF THE AIR FORCE 78TH AIR BASE WING (AFMC) ROBINS AIR FORCE BASE GEORGIA A. APR 0 6 2012 78 620 9th Street, Suite 230 Robins AFB, GA 3 l098-1664 Dr. Richard Allen . -- -- Tribal Historic Preservation Officer Cherokee Nation of Oklahoma P.O. Box 948 Tahlequah, OK 74465 RE: Georgia-Robins Aerospace Maintenance Partnership (GRAMP) EA, Houston County, Georgia . Dr. Allen, I am writing to send you the results of recent Phase II testing of a small site located near Robins Air Force Base, GA. The archaeological site 9Ht l0 received Phase II testing by MACTEC Engineering and Consulting (MACTEC) in consonance with the letter MACTEC sent you on 27 July 20l0. The report of the Phase II testing, entitled Phase Il National Register - Assessment of Site 9HtlO at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia, indicated a low density of artifacts discovered, a lack of identifiable tools, a lack of vertical integrity, and a paucity of diagnostic materials. Resultantly, the MACTEC archaeological staff determined that these findings do not support a recommendation for eligibility for the National Register of Historic Places (NRHP). Upon review, Robins Air Force Base concurs with the findings of the report, and, accordingly, also does not recommend 9Ht l0 to be eligible for the NRHP. A copy of MACTEC's report, Phase ll National Register Assessment of Site 9HtlO at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia, is enclosed on a CD. Phase ll National Register Assessment of Site 9Htl0 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia also mentions archaeological site 9Htl26. This site was investigated by archaeologists in l996 and was recommended to be ineligible for the NRHP because only nine pieces of chert debitage were recovered. The report detailing the findings of this investigation, Archaeological Survey ofthe Upland Portions tf a Proposed Base Expansion Area, Robins Air Force Base, Houston ounty, Georgia, is also copied on the CD mentioned above. Site 9Ht 26 was briefly revisited during the phase II evaluation of site 9Htl0 and three additional pieces of debitage were found. This site has produced a total of twelve artifacts, and, importantly, lacks diagnostic material and integrity. As a result, Robins Air Force Base continues to concur with the findings of Archaeological Survey if the Upland Portions of a Proposed Base Erpansion Area, Robins Air Force Base, Houston Countv, Georgia, and. accordingly, also does not recommend 9Ht 26 to be eligible for the RHP. I have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, Jr., as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 775 Macon St., 1555, Robins AFB, GA, 31098- l664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 775 Macon St., l555, Robins AFB, GA, 3 l098-2201. MITCHEL BUTIKOFER, Colonel, USAF Installation Commander Attachment: l. CD containing the reports: Phase National Register Assessment of Site 9Ht10 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey of the Upland Portions raf a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia Il DEPARTMENT OF THE AIR FORCE gt 78TH AIR BASE WING (AF MC) AIR FORCE BASE GEORGIA APR 0 6 2012 78 620 9th Street, Suire.230 Robins AFB, GA 31098-1664 Ms. Augustine Asbury ui-: E- oH.* 2:2 ea-ez-yar--? ar; aenuaanu. un Town P.O. Box 187 Wetumka, OK 74883 RE: Georgia-Robins Aerospace Maintenance Partnership (GRAMP) EA, Houston County, Georgia Ms. Asbury, I am writing to send you the results of recent Phase Ilrtesting of-asmall site located near Robins Ai,r'Force Base, GA. The archaeological site 9Htl0 received Phase LI testing by MACTEC Engineering and Consulting (MACTEC) in consonance with the letter MACTEC sent you on 27 July 2010. The report of the Phase II testing, entitled Phase II National Register Assessment ofSite 9Htl0 a,t,the Proposed Georgia-Robins Aerospace Maintenance Partnership FGRAMP) Facility. Warner Robins, Georgia, indicated a low density of artifacts discovered, a lack of.identifiable?too1s, a lack of vertical integrity, and a paucity of diagnostic materials. Resultantly, the MACTEC archaeological, staff determined that these findings do not support a recommendation for eligibility for the National Register of Historic Places (NRHP). Upon review, Robins Air Force Base concurs with the findings of the report, and, accordingly, also does not recommend 9Htl0 to be eligible for the A copy of MACTEC's report, Phase II . National Register A.sse.ssmen.t gfSite 0 at the;Pribp6sed Aerospace _Maintenange YGRAMP) Facility, Warner Robins, Georgia, i? enclosed on 6 Phase II National Register Assessment afSite 9Htl0 ot the Proposed Georgia-Robins Aerosptuge Maintqnagrce (GRAMR) Facility, Wamer Robins, Georgia also mentions iarohaeological lite 9Ht 1*26. This sitewas investigated by archieologigts in 1996 and was recommended to be ineligible for the RHP because only nine pieces. of chen debitagewere recovered. The- report detailing the findings of this' investigation, Archaeoletgie21lSarweyioffhe Uplan4,Partieins. a Progooed Biise Aren, Robins Air oree Btfse, Houston, Georgia, is also copied on the GD mentioned above. Site 9Ht 1 26 was briefly revisited during the phase of site Qlli 1:0 and- three additional pieces of debitage were found. This; site has produced a total, of twelve importantly, lacks diagnostic material and integrity. As a result, Robins Air Force Base continuesto doneur with the findings of Arc?}taeoI?igi?til of the Upland Portions o`fa Proposed Bose Erparisiaii. Area, Robins Air oree Base, Houston County;. Georgia; and. accordingly, algo does not recommend 9l?l"t 1 26 to be eligible-rfor I I have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, Ir., as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 775 Macon St., l555, Robins AFB, GA, 31098- l664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 775 Macon St., l555, Robins AFB, GA, 3 l098--220l. MITCHEL BUTIKOFER, Colonel, USAF Installation Commander Attachment: I. CD containing the reports: Phase ll National Register Assessment of Site at the Proposed Georgia--Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey of the Upland Portions of a Proposed Base Expansion Area, Robins Air orce Base, Houston County, Georgia DEPARTMENT OF THE AIR FORCE 5 2; 78TH AIR BASE WING (AFMC) ROBINS AIR FORCE BASE GEORGIA r,I. APR 0 6 2012 78 620 9th Street, Suite 230 Robins AFB, GA 31098-1664 Mr. Bryant Celestine - - Historic Preservation Officer Alabama-Coushatta Tribe of Texas 57l State Park Rd 56 Livingston, TX 7735l RE: Georgia-Robins Aerospace Maintenance Partnership (G-RAMP) EA, Houston County, Georgia Mr. Celestine, I am writing to send you the results of recent Phase II testing of a small site located near Robins Air Force Base, GA. The archaeological site 9I--Itl0 received Phase II testing by MACTEC Engineering and Consulting (MACTEC) in consonance with the letter MACTEC sent you on 27 July 20l0. The report of the Phase II testing, entitled Phase ll National Register Assessment of Site 9HtlO at the Proposed Georgia-Robins Aerospace Maintenance Partnership GRAMP) Facility, Warner Robins, Georgia, indicated a low density of artifacts discovered, a lack of identifiable tools, a lack of vertical integrity, and a paucity of diagnostic materials. Resultantly, the MACTEC archaeological staff determined that these findings do not support a recommendation for eligibility for the National Register of Historic Places (NRHP). Upon review, Robins Air Force Base concurs with the findingsof the report, and, accordingly, also does not recommend 9Htl0 to be eligible for the NRHP. A copy of MACTEC's report, Phase II National Register Assessment of Site 9HtlO at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia, is enclosed on a CD. Phase Il National Register Assessment of Site 9HtlO at the Proposed Georgia--Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia also mentions archaeological site 9Htl26. This site was investigated by archaeologists in I996 and was recommended to be ineligible for the NRHP because only nine pieces of chert debitage were recovered. The report detailing the findings of this investigation, Archaeological Survey of the Upland Portions of a Proposed Base Expansion Area. Robins Air Force Base, Houston ounty. Georgia, is also copied on the CD mentioned above. Site 9Htl26 was briefly revisited during the phase II evaluation of site 9Ht l0 and three additional pieces of debitage were found. This site has produced a total of twelve artifacts, and, importantly, lacks diagnostic material and integrity. As a result, Robins Air Force Base continues to concur with the findings of Archaeological Survey rf the Upland Portions (Ja Proposed Base Elrpansion Area. Robins Air Force Base. Houston County, Georgia, and, accordingly, also does not recommend 9Ht I 26 to be eligible for the NRHP. have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, Jr., as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 775 Macon St., l555, Robins AFB, GA, 3l098- [664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 775 Macon St., l555, Robins AFB, GA, 3 l098-220l. MITCHEL I-l BUTIKOFER, Colonel, USAF Installation Commander 1 Attachment: l. CD containing the reports: Phase National Register Assessment (J Site 9Htl0 at the Proposed Georgia-Robins Aerospace Maintenance Partnenship (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey ofthe Upland Portions of a Proposed Base Expansion Area, Robins Air orce Base, Houston County, Georgia ft.! DEPARTMENT OF THE AIR FORCE 78TH AIR BASE WING (AFMC) ROBINS AIR FORCE BASE APR 0 6 2012 78 620,9th Street, Suite:230 Robins AFB, GA 31098-1664 Mr. Willard Steele ln}; h1Td'i' .5 lu Seminole Tribe ef Florida 34725 West Boundary Road Clewi'Ston, FL 53440 RE: Georgia-Robins Aerospace Maintenance Partnership (G-RAMP) EA, Houston County, Georgia Mr. Steele I am writing to send you the results, of recent Phase II testing of a small site located near Robins Air Force Base, GA. The archaeological site 9f?Itl0 received Phase U. testing by MACTEC Engineering and Consulting (MACTEC) in consonance with the letter MACTEC sent you on 27 July 2010. The report of the Phase IT testing, entitled Phase Il National Register Assessment gf Site 9Htl0 at the Proposed Georg'ia-Robimj Aerospace Mairttenwtce Partnership Facility, Wdrner Robins, Georgia; indicated a low density of artifacts discovered, a lack of identifiable tools, a lack of vertical integrity, and a_paucity of diagnostic materials. Resultantly, the MACTEC archaeological staff determined that these findings do n_ot_support a recommendation for eligibility for the National Register of Historic Places Upon review, Robins Ai; Force Base concurs with the findings of the report, and, accordingly, also does. not recommend 9Ht I0 to' be eligible for the NRHP. A copy of report, Phase II Natiqnal Register Assessment ofSi!e. 9Htl0 at?the Proposed Geprgiai-Rqbins Aerospace Maintenance Partnership facility, Wagner Robins, Georgia, is enclosed on a CD. Phtise ll Natipno1,Reg_ister Assessment ef Seite 9Htl0 tit the Gee5rgiEURt;Rgbins Aerospace Maintenance Warner Robins, Georgie? also mentions archaeological site 9I-Itl2.6. This site was. investigated by 'archaeologists in 1996 and was recommended to be ineligible for the RHP because only nine piestes of chert' debitage were recovered. The report detailing the findings of this investigation, Arighigeologiaa-L Survey ofthe Upland Portions Base-Erpasutean Areas Robins Air oroe?BasQe. Hpusto'tt,Goanty, Georgia. i$?Also cdpied on the CD rnentioned above. Site 9?Htl"26 was briefly revisited during the phase II evaluation of site 9Htl0 and threeadditional pieces of debitage were found; 'l`his.site has produced a total of twelve importantly, lacks diagnostic material and integrity. As a result, Robins Air Force Base continues to concur with the findings.ofArc?ht1e0l0giaal Survey gf The Upland Rgrtions ofe Proposed Base Rdbins Air Fgrce Bose, Haustori Geanty, Gegrgiafand, does not zecommenrl 9Ht I 26 to be eligible for the NRHP. I have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, Jr., as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 775 Macon St., 1555, Robins AFB, GA, 31098- l664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 775 Macon St., I555, Robins AFB, GA, 31098-220l. MIT CHEL BUTIKOFER, Colonel, USAF Installation Commander 1 Attachment: l. CD containing the reports: Phase ll National Register Assessment rf Site at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey of the Upland Portions of a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia ll DEPARTMENT OF THE AIR ORCE 78TH AIR BASE WING (AFMC) I ROBINS AIR FORGE BASE GEORGIA APR 0 62012 vs Aawtcc 620 9th street, Suite 230 Robins GA 31098-1664 Ms. Lisa Stopp United Keetoowah Band of Cherokee Indians P.O. Box 746 Tahlequah, OK 74464 RE: Georgia-Robins Aerospace Maintenance Partnership (GRAMP) EA, Houston County, Georgia Ms. Stopp. Lam writing to send, you the results of recent Phase. II testing of a small site located near Robins Air Force.Base, GA. The archaeological site 9Htl0 received Phase II. testing by MACTEC Engineering and Consulting (MACTEC) in consonance with the letter MACTEC sent you on 27 July 2010. The report of the Phase If testing, entitled Phase II National Register Assessment of Site 9Htl0 at the Proposed Georgia--Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia, indicated a low density ofartifacts discovered, a lack of identifiable tools, a lack of vertical integrity, and a_paucity of diagnostic materials. Resultantly, the MACTEC archaeological staff determined that these findings do not support a recommendation for eligibility for the National Register of Historic Places, (N RHP). Upon revie.w, Robins Air Force;B3S? concurs with the tindings of the report, and, accordingly, also does not recommend 9Ht 10 to be eligible for the NRHP. A copy of M.ACTEC's report, Phase Il National Register Assessment of Site at the Proposed Ge0rgia--Robins Aerospace Maintenance Partnership Facility, Warner Robins, Georgia, is enclosed on a CD. Phgse II National, Register Assessment of Site 9Htl0 at the Aerospace Partnership Warner Robins, Georgia also mentions archaeological site 9Ht1'26. This site was investigated by archaeologists in 1996 and was recommended to be ineligible for the NRHP because- only nine pieces of chert debitage were recovered. The report detailing the findings ofthis. investigatiop, Archaeological Survey ofthe Upland Portions of a Proposed Base Expansion Area, Robins'Air or?a Base, Houston ounty Georgia, is also copied on the CD mentioned above. Site. 9I?lil26 was briefly revisited during the phase I1 evaluation of site 9l?ltl0 and three additional pieces of debitage were found. This site has produced a total of twelveanifacts, and, importantly, lacks diagnostic material and integrity. As a result, Robins Air Force. Base continues to concur with the findings of Archaeological, Sunoey?of;the Upland Portioits oft: Proposed Base &tpaitsion Area, Robins Air Bgrce 'Btiise, Georgia, and, accordingly, also does not recommend 91-lt 126 to be eligible for the RHP. I have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, Jr., as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 775 Macon St., l555, Robins AFB, GA, 31098- l664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 775 Macon St., l555, Robins AFB, GA, 31098-2201. MITCHEL BUTIKOFER, Colonel, USAF Installation Commander Attachment: l. CD containing the reports: Phase II National Register Assessment rf Site 9Htl0 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey of the Upland Portions of a Proposed Base Expansion Area, Robins Air orce Base, Houston County, Georgia YG, DEPARTMENT OF THE AIR FORCE IQ 78TH AIR BASE WING (AF MC) ROBINS AIR FORCE BASE GEORGIA APR 0 6 2012 78 620 9th Street, Suite 230 Robins AFB, GA 31098-1664 Ms. Marsey Harjo -- -- - - Tribal Historic Preservation Officer Kialegee Tribal Town of Oklahoma P.O. Box 332 Wetumka, OK 74883 RE: Georgia-Robins Aerospace Maintenance Partnership (GRAMP) EA, Houston County, Georgia Ms. Harjo, I am writing to send you the results of recent Phase Il testing of a small site located near Robins Air Force Base, GA. The archaeological site 9Ht 10 received Phase Il testing by MACTEC Engineering and Consulting (MACTEC) in consonance with the letter MACTEC sent you on 27 July 20 I0. The report of the Phase II testing, entitled Phase II National Register Assessment cy`Site 9Htl0 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia, indicated a low density of artifacts discovered, a lack of identifiable tools, a lack of vertical integrity, and a paucity of diagnostic materials. Resultantly, the MACTEC archaeological staff determined that these findings do not support a recommendation for eligibility for the National Register of Historic Places (N RHP). Upon review, Robins Air Force Base concurs with the findings of the report, and, accordingly, also does not recommend 9Htl0 to be eligible for the NRHP. A copy of MACTEC's report, Phase Il National Register Assessment of Site 9Htl0 at the Proposed Georgia--Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia, is enclosed on a CD. Phase II National Register Assessment if Site 9Htl0 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia also mentions archaeological site, 9Htl26. This site was investigated by archaeologists in 1996 and was recommended to be ineligible for the RHP because only nine pieces of chert debitage were recovered. The report detailing the findings of this investigation, Archaeological Survey rfthe Upland Portions of a Proposed Base Erpansion Area, Robins Air Force Base, Houston oanty, Georgia, is also copied on the CD mentioned above. Site 9Htl26 was briefly revisited during the phase II evaluation of site 9Ht 10 and three additional pieces of debitage were found. This site has produced a total of twelve artifacts, and, importantly, lacks diagnostic material and integrity. As a result, Robins Air Force Base continues to concur with the findings of Archaeological Survey if the Upland Portions rfa Proposed Base Expansion Area, Robins Air Force Base. Houston ounty. Georgia, and, accordingly, also does not recommend 9Ht 126 to be eligible for the RHP. I have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, Jr., as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 775 Macon St., 1555, Robins AFB, GA, 3l098- 1664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 775 Macon St., l555, Robins AFB, GA, 3 l098-2201. MIT BUTIKOFER, Colonel, USAF Installation Commander Attachment: l. CD containing the reports: Phase ll National Register Assessment of Site at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey of the Upland Portions if a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia DEPARTMENT OF THE AIR FORCE 1; 78TH AIR BASE WING (AFMC) ROBINS AIR FORCE BASE GEORGIA s? APR 0 6 2012 78 620 9th Street, Suite 230 Robins AFB, GA 31098-1664 Charles Coleman -. Cultural Resources Director . . . . Thlopthlocco Tribal Town P.O. Box 188 Okemah, OK 74859 RE: Georgia-Robins Aerospace Maintenance Partnership (GRAMP) EA, Houston County, Georgia Mr. Coleman, 1 am writing to send you the results of recent Phase II testing of a small site located near Robins Air Force Base, GA. The archaeological site 9Htl0 received Phase II testing by MACTEC Engineering and Consulting (MACTEC) in consonance with the letter MACTEC sent you on 27 July 2010. The report of the Phase testing, entitled Phase Il National Register Assessment of Site 9Htl0 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia, indicated a low density of artifacts discovered, a lack of identifiable tools, a lack of vertical integrity, and a paucity of diagnostic materials. Resultantly, the MACTEC archaeological staff determined that these findings do not support a recommendation for eligibility for the National Register of Historic Places (N RHP). Upon review, Robins Air Force Base concurs with the findings of the report, and, accordingly, also does not recommend 9Ht I0 to be eligible for the RHP. A copy of MACTEC's report, Phase II National Register Assessment of Site 9Htl0 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia, is enclosed on a CD. Phase ll National Register Assessment cf Site 9Htl0 at the Proposed Georgia--Robins Aerospace Maintenance Partnership (GRAMP) Faciliajv, Warner Robins, Georgia also mentions archaeological site 9l~lt 26. This site was investigated by archaeologists in 1996 and was recommended to be ineligible for the NRHP because only nine pieces of chert debitage were recovered. The report detailing the findings of this investigation, Archaeological Survey ofthe Upland Portions of a Proposed Base lirpansion Area, Robins Air Force Base, Houston County. Georgia, is also copied on the CD mentioned above. Site 9Htl26 was briefly revisited during the phase ll evaluation of site 9Htl0 and three additional pieces of debitage were found. This site has produced a total of twelve artifacts, and, importantly, lacks diagnostic material and integrity. As a result, Robins Air Force Base continues to concur with the findings of Archaeological Sur1?e_v (J the Upland Portions of a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia, and, accordingly, also does not recommend 9Htl26 to be eligible for the NRHP. 1 have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, .1 as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 775 Macon St., 1555, Robins AFB, GA, 31098- 1664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base I Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 775 Macon St., 1555, Robins AFB, GA, 31098-2201. MIT CHEL BUTIKOFER, Colonel, USAF Installation Commander 1 Attachment: 1. CD containing the reports: Phase ll National Register Assessment of Site at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey of the Upland Portions of a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia DEPARTMENT OF THE AIR FORCE . 78TH AIR BASE WING (AFMC) ROBINS AIR FORCE BASE GEORGIA 5; APR 0 6 2012 78 620 9th Street, Suite 230 . Robins_AFB, GA 31098- 1664 Mr. Robert Thrower re Poarch Band of Creek Indians 5811 Jack Springs Road Atmore, AL 35602 RE: Georgia-Robins Aerospace Maintenance Partnership (GRAMP) EA, Houston County, Georgia . Mr. Throwef, . 1`am writing to send you the results of recent Phese II testing of a small site located near Robins,Air Force Base, GA. The arichaeologiqal site 9Htl0 received Phase?II testing by MACTEC Engineering and Consulting (MACTEC) in consonance with the letter MACT EC sent you on 27 July 2010. The report of the Phase Il-testing, entitled Phase Il.Ndtional Register Assessment of .S1ite;9Ht10 ofthe Propijsed Georgia-Robins Aerospace Maimerurn?e (GRAMP) Facility, Warner Robins, Georgia, indicated a low density of artifacts discovered, a lack of identifiable tools, a lack of vertical integrity, and a- paucity of diagnostic materials. MACTEC archaeological staff determined that these .?ndings do not support a recommendation for eligibility for the National Register of Historic Places Upon review, Robins Air Force Base concurs with the findings of the report, and, accordingly, also does not recommend 91-It 10 to be eligible for the NRHP. A copy of report, Phase]! Ncrti?gnal Register Assessment bfSite_9HtlO JL the Geergia-Robins Aer?sp?'rbe' Mttintendnce TGRAMP) Warner Rijbins, Georgia, is enclosed on ?a CD. Phase ll National Register Asse:smetit,Qf ite 9HrlQ artlie Proposed Geargie-Robins Aerospace Meiinsendhce Warner Rdbins, Georgia also mentions archaeological site 9Ht12l$. This site was investigated archaeologists in 1996 and. was recommended to be?ine1igible??l'or the NRHP because only nine pieces of chert debitage were recovered. The report detailing the lindingsof this investigation, Arelfaeblggical Surveyeif flre Upland Pqrti?nspf cr Proposed Base Expansion. Area, R?binseglir Base, Houston G?uiirgg. Geergial is.al'co CD mentioned above.,Site 9Ht 1.26 was briefly revisited during the phasell evaluation of site 9Ht 10 ind three additional pieces of debitage were found. This_$ite hire produced 5 total of twelve artifacits, ?and, importantly, laeks diagnostic material and integrity. As a result, Robins Air Forde Base cbntinuesro concur with the findings of Survgv ofthe Upland Portions efa Area, Robins Air ont? Base, Houstore Gauiigr Geqrgi?. ind, does not recommend 9l~ft IE6 to be eligible for the l5lRI;l,P. have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, Jr., as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 775 Macon St., 1555, Robins AFB, GA, 3l098- l664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 775 Macon St., l555, Robins AFB, GA, 3 l098-2201. MIT CHEL I-l BUTIKOFER, Colonel, USAF Installation Commander I Attachment: l. CD containing the reports: Phase Il National Register Assessment of Site 9Htl0 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey ofthe Upland Portions of a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia DEPARTMENT QF THE AIR FORCE 78TFI AIR BASE WING (AFMC) ROBINS AIR FORCE BASE GEORGIA APR 0 6 2612 78 620 9th Street, Suite.230 Robins AFB, GA 31098-1664 Mr. Russell Townsend '?Fl'ib8?l? - in we z- Fi Eastern Band of Cherokee indians P.O. Box 455 Cherokee, NC 28719 RE: Georgia-Robins Aerospace Maintenance Partnership (GRAMP) EA, Houston County, Georgia .Mr. Townsend, .. l?am writing to send you the results of Phase II testing of 'a small site located near Robins Air Force Base, GA. Thearchaeologicalrsite 9Htl0 received Phase II testing by MACT EC Engineering and Consulting (MACTEC) in consonance with the letter MACTEC sent you on 27 July 20 The report of the Phase ll testing, entitled Phase II NatiQnalRegi1ster Assessment qf Site aethe Pr?ppsed" Georgiq,-Robins Aerospace Maintenarace Partnership, Warner Robins, Geargia, indicated a low density of artifacts, discovered, a lack ofidentihable tools, a lack of vertical integrity, and a paucity of diagnostic materials. Resultantly, the MACT Ec archaeological staff determined-that these Endings do not support a recommendation for eligibility for the National Register of Historic Places (NRI-LP). Upon review,'Robins Air Force Base concurs with the findings of the report, and, accordingly, also does not recommend 9Ht 10 to be eligible for the NRHP. A copy of report, Phase Il Assessmei1t_Q`f Site 9Ht,l0 dt the Georgia-Robins Aergsp?ce Maintenance- P?rtnership Wdmer Robins, Georgia, is enclosed on a CD. Phase il National Register Assessmenx OfSite 9HtlO at the Aarespti?e curilieg, Wtimer Rgbins, Geqrgitmlso m??ti0?$ archaeological site 9Ht.l26. This site was investigated by archaeologists in 1996-and was recommended to be ineligible for the RHP because onfy nine pieces of chert debirage. were recovered. The report detailing the findings of this investigation, Upliind Portions of Z1 Prepared Base ExpdF1.sign'Arep; Robins Air Eorce Base, Hciusteirt is also copied on the-CD mentioned above. Site 9l*ltl%6 was briefly revisited during the phase H: evaluation of site 9Ht 10 and three additional pieces of debitage were found. This ?iI'e has produced 'a total of tweLve_arrifacts, and. importantly, lacks diagnostic material.-and integrity. Asa result, Robins Air Force Base continues to concur with the findings of Surmyieftlre Upland Base Robins Air P0rce?B?itse, Geirgicr, and, accordingly, also do6s not recommend 9Ht l'2.6 no be eligible for the NRH P. I have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, Jr., as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 775 Macon St., 1555, Robins AFB, GA, 31098- 1664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 R, 775 Macon St., 1555, Robins AFB, GA, 31098-2201. MIT CHEL BUTIKOFER, Colonel, USAF Installation Commander 1 Attachment: 1. CD containing the reports: Phase II National Register Assessment ry'Site at the Proposed Georgia-Robins Aerospace Maintenance Partnenrhip (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey of the Upland Portions a Proposed Base Erpansion Area, Robins Air orce Base, Houston County, Georgia DEPARTMENT OF THE AIR FORCLE eve jig 78TH AIR BASE IMNG (AFMC) ROBINS AIR FORCE BASE GEORGIA APR 0 6 2012 78 620 9th Street., Suite 230 Robins AFB, GA 3 1098-l664 Ms. Natalie Deere 9* te Ee +o o' *o iiw Seminole Niti-on of Oklahoma P.O. Box I498 Wewoka, OK 7?884 RE: Georgia-Robins Aerospace Maintenance Partnership (GRAMP) EA, Houston County, Georgia Ms, Deere, I am writing to send you the results- of recent Phase testing of a smallgsite located near Robins Air Force Base, GA. The archaeological site.;9Htl0 ueceived Phase testing by MACTEC Engineering and Consulting QMACTEC) in consonance with the letter MACTEC sent you on 27 July 2010. The report of the Phase II testing, entitled Phase Il National Register Assessment pf Site at the Propgsed Georgia-Robins Aermpace Maintenaitce Partnership F'aLcility, Warner Robins, Georgia; indicated a low density ofartifaets discovered, a lack of identifiable tools, a laclcof vertical integrity, and a paucity of diagnostic materials. Resuitantly, the MACTEC archaeologieal staff determined that these findings do not support a recommendation for eligibility for the..National Register of Historic Places. (N RHP). Upon review, Robins Air Force Base- concurs with the findings of the report, and, accordingly, also does not reoommend to be eligible for the RHP. A copy report, Phase II Natigvnai Register Asaessrhent qf Site,,9Hiol0 et the Preposed Geiergia?R6biris Aer?sp?u;e Maingeaan?e Partnership (GRAMP) Warner Robins;. Geergig, isenclosed on a CD. Phage ll Nagtieital Register Assessment Q}"Site at the Prepared Ge?rgitii-Roigins. Aeraspa?e Maintenance Partnership Warner Relying, Georgia, also mentions. archaeological site 9Ht 26. was investigated byEURarchaeologist.s- in l996 and was recommended to be ineligible for the NRHP because. only nine pieces ofichert debitage were recovered. The report-detailing the findings of this investigation, Synteg of Upland Portiens qfa Prepdsed Beige Brpitnsipn Area, Robins Air F?rae Base, Hemfgn County. Geengia, is also copied on the CD mentioned above. Site>>9Ht'l'26 was briefly revisited phase II evaluation of site 9Htl0 and three additional pieces oiidebitage were found. This site has produced a total of twelveartifacts, and, importantly, material and integrity. As atesult, Robins Air Force Basecontinues to concur with the findings of Arvhaealpgiqai Sz?rrt?ey?oj" the Uplaird Parriens oft? Prepared Base Area; ?Rebins Air Base; Haustgit Gout}; Gegrgia, and, aeqordingly, Eloes,n_oL recommend 9l-it L26 to be eligible for the RHP. I have designated the Robins Air Force Base Civil Engineer, Mr. Otis L. Hicks, Jr., as the Robins Air Force Base liaison for correspondence with you to foster communications between you and Robins Air Force Base; he can be reached at (478) 926-3093. Once you have had an opportunity to review the report, please send comments you have conceming these documents or any other issues to him at: 78 775 Macon St., l555, Robins AFB, GA, 3l098- 1664. Additionally, if your staff wishes to correspond directly with the Robins Air Force Base Cultural Resources staff, please contact Ms. Andrea Pyron at (478) 327-7438 or at 78 775 Macon St., l555, Robins AFB, GA, 3l098-2201. MIT CHEL BUTIKOFER, Colonel, USAF installation Commander Attachment: l. CD containing the reports: Phase II National Register Assessment tj Site 9Htl0 at the Proposed Georgia-Robins Aerospace Maintenance Partnership (GRAMP) Facility, Warner Robins, Georgia and Archaeological Survey of the Upland Portions tf a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia August 1, 2012 Fred Hursey, Chief Environmental Restoration & Conservation Section Environmental Branch Department of the Air Force Robins Air Force Base 78 CEG/CEANR 775 Macon St., Bldg. 1555 Robins AFB, Georgia 31098 Attn: Andrea Pyron RE: CDBG/One GA: Robins AFB: G-Ramp, Extend Taxiway & Const Hangars, Perimeter Rd. Houston County, Georgia GA-090708-013 Dear Mr. Hursey: The Historic Preservation Division (HPD) has reviewed the information submitted concerning the above referenced project. Our comments are offered to assist the U.S. Department of the Air Force and Robins Air Force Base (AFB) in complying with the provisions of Section 106 of the National Historic Preservation Act of 1966, as amended (NHPA). The subject project consists of G-RAMP, extend taxiway and construct hangars on Perimeter Road at Robins Air Force Base. Previously, HPD found no archaeological resources listed or eligible for listing in the National Register of Historic Places (NRHP) would be affected by the proposed undertaking. Additionally, since the cemetery would be avoided and a 20-foot buffer maintained surrounding the cemetery, HPD found that the proposed project would have no adverse effect on the potentially eligible cemetery, as stated in a letter dated July 24, 2009. Based on the additional information provided in The Delineation of the Minshew-ThomasSullivan Cemetery (9HT128), G-Ramp Robins AFB and the City of Warner Robins, Houston County, Georgia report and the Department of the Air Force cover letter dated June 29, 2012, HPD concurs with the recommendation that the one acre cemetery boundary accurately delineates the known cemetery interments. However, HPD recommends an additional 50-foot buffer on the east side of the cemetery plot be protected from ground-disturbing activities in order to protect additional unmarked graves and to include two additional plated cemetery boundaries. In the event future work requiring ground surface disturbance is proposed for this area, it is our opinion that a ground penetrating radar (GPR) survey to detect additional unmarked graves would be warranted. HPD also recommends that the trash and debris piled within the northern portion of the cemetery be carefully removed and grassed to bring the cemetery back to a natural setting. Please submit one electronic copy of The Delineation of the Minshew-Thomas-Sullivan Cemetery (9HT128), G-Ramp Robins AFB and the City of Warner Robins, Houston County, Georgia report to HPD. Please ensure the electronic copy is an optical character recognition enabled .pdf. For your information, the electronic copy will be sent to the Georgia Archaeological Site File at the University of GeorgiaAthens for permanent retention. Hursey GA-090708-013 August 1, 2012 Page 2 Please refer to project number GA-090708-013 in any future correspondence on this project. If we may be of further assistance, please do not hesitate to contact Elizabeth Shirk, Environmental Review Coordinator, at (404) 651-6624. Sincerely, Karen Anderson-Cordova Program Manager Environmental Review and Preservation Planning KAC:jad cc: Keith Dyche, EDA Chan Layson, Middle Georgia Regional Commission Kristi Harpst, Middle Georgia Regional Commission G-RAMP Environmental Assessment APPENDIX C MINIMUM STANDARDS FROM GEORGIA STORMWATER MANAGEMENT MANUAL September 4, 2012 ..SECTION.. 1.2 STORMWATER MANAGEMENT STANDARDS 1.2.1 Overview This section presents a comprehensive set of minimum performance standards for stormwater management for development activities in the state of Georgia. The overall aim is to provide an integrated approach to address both the water quality and quantity problems associated with stormwater runoff due to urban development. The goal of a set of minimum stormwater management standards for areas of new development and significant redevelopment is to reduce the impact of post-construction stormwater runoff on the watershed. This can be achieved by (1) maximizing the use of site design and nonstructural methods to reduce the generation of runoff and pollutants; (2) managing and treating stormwater runoff though the use of structural stormwater controls; and (3) implementing pollution prevention practices to limit potential stormwater contaminants. It should be noted that the standards presented here are recommended for all communities in Georgia. They may be adopted by local jurisdictions as stormwater management development requirements and/or may be modified to meet local or watershed-specific stormwater management goals and objectives. Please consult your local review authority for more information. The minimum standards for development are designed to assist local governments in complying with regulatory and programmatic requirements for various state and Federal programs including the National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) permit program and the National Flood Insurance Program under FEMA. 1.2.2 Minimum Standards for Development 1.2.2.1 Applicability The stormwater management standards for new development and redevelopment are intended to apply to any development site that meets one or more of the following criteria: (1) New development that includes the creation or addition of 5,000 square feet or greater of new impervious surface area, or that involves land disturbing activity of 5,000 square feet of land or greater. (2) Redevelopment that includes the creation or addition of 5,000 square feet or greater of new impervious surface area, or that involves land disturbing activity of 1 acre or more. (3) Any commercial or industrial new development or redevelopment, regardless of size, with a Standard Industrial Classification (SIC) code that falls under the NPDES Industrial Stormwater Permit program, or a hotspot land use as defined below. In addition, redevelopment sites that involve land disturbing activity of 5,000 square feet or greater, but less than 1 acre, must meet Minimum Standard 8 (to meet state and NPDES construction erosion and sediment control requirements) and should meet Minimum Standards 2, 9 and 10 to the maximum extent practicable. Volume 2 (Technical Handbook) Georgia Stormwater Management Manual 1.2-1 Definitions New development is defined as land disturbing activities, structural development (construction, installation or expansion of a building or other structure), and/or creation of impervious surfaces on a previously undeveloped site. Redevelopment is defined as structural development (construction, installation or expansion of a building or other structure), creation or addition of impervious surfaces, replacement of impervious surface not part of routine maintenance, and land disturbing activities associated with structural or impervious development. Redevelopment does not include such activities as exterior remodeling. A hotspot is defined as a land use or activity on a site that produces higher concentrations of trace metals, hydrocarbons or other priority pollutants than are normally found in urban stormwater runoff. Examples of hotspots include gas stations, vehicle service and maintenance areas, salvage yards, material storage sites, garbage transfer facilities, and commercial parking lots with high-intensity use. Exemptions The following development activities are suggested to be exempted from the minimum stormwater management standards: (1) Developments that do not disturb more than 5,000 square feet of land; (2) Individual single family residential lots. (Single family lots that are part of a subdivision or phased development project should not be exempt from the minimum standards); and (3) Additions or modifications to existing single-family structures. Additional Requirements New development or redevelopment in critical or sensitive areas, or as identified through a watershed study or plan, may be subject to additional performance and/or regulatory criteria. Furthermore, these sites may need to utilize or restrict certain structural controls in order to protect a special resource or address certain water quality or drainage problems identified for a drainage area. 1.2.2.2 Minimum Stormwater Management Standards The following standards are the recommended minimum stormwater management performance requirements for new development or redevelopment sites falling under the applicability criteria in subsection 1.2.2.1. (The word "shall" in brackets is provided for local jurisdictions that wish to adopt these standards as part of their stormwater management ordinances) A more detailed explanation of each minimum standard is provided in the next subsection. ? Minimum Standard #1 - Use of Better Site Design Practices for Stormwater Management Site designs should preserve the natural drainage and treatment systems and reduce the generation of additional stormwater runoff and pollutants to the fullest extent practicable. Minimum Standard #2 - Stormwater Runoff Quality All stormwater runoff generated from a site should [shall] be adequately treated before discharge. Stormwater management systems (which can include both structural stormwater controls and better site design practices) should [must] be designed to remove 80% of the average annual post-development total suspended solids (TSS) load and be able to meet any other additional watershed- or site-specific water quality requirements. It is presumed that a stormwater management system complies with this performance standard if: ? 1.2-2 Georgia Stormwater Management Manual Volume 2 (Technical Handbook) o o o It is sized to capture and treat the prescribed water quality treatment volume, which is defined as the runoff volume resulting from the first 1.2 inches of rainfall from a site; and Appropriate structural stormwater controls are selected, designed, constructed, and maintained according to the specific criteria in this Manual. Runoff from hotspot land uses and activities is adequately treated and addressed through the use of appropriate structural stormwater controls and pollution prevention practices. ? Minimum Standard #3 - Stream Channel Protection Stream channel protection should [shall] be provided by using all of the following three approaches: (1) 24-hour extended detention storage of the 1-year, 24-hour return frequency storm event; (2) erosion prevention measures such as energy dissipation and velocity control; and (3) preservation of the applicable stream buffer. Minimum Standard #4 - Overbank Flood Protection Downstream overbank flood protection should [shall] be provided by controlling the postdevelopment peak discharge rate to the predevelopment rate for the 25-year, 24-hour return frequency storm event. If control of the 1-year, 24-hour storm (Minimum Standard #3) is exempted, then overbank flood protection should [shall] be provided by controlling the postdevelopment peak discharge rate to the predevelopment rate for the 2-year through the 25year return frequency storm events. Minimum Standard #5 - Extreme Flood Protection Extreme flood protection should [shall] be provided by controlling and/or safely conveying the 100-year, 24-hour return frequency storm event such that flooding is not exacerbated. Existing and future floodplain areas should be preserved as possible. Minimum Standard #6 - Downstream Analysis A downstream hydrologic analysis should [shall] be performed to determine if there are any additional impacts in terms of peak flow increase or downstream flooding while meeting Minimum Standards #1 through 5. This analysis should [shall] be performed at the outlet(s) of the site, and downstream at each tributary junction to the point(s) in the conveyance system where the area of the portion of the site draining into the system is less than or equal to 10% of the total drainage area above that point. Minimum Standard #7 - Groundwater Recharge Annual groundwater recharge rates should be maintained to the extent practicable through the use of nonstructural methods. Minimum Standard #8 - Construction Erosion and Sedimentation Control Erosion and sedimentation control practices shall be utilized during the construction phase or during any land disturbing activities. Minimum Standard #9 - Stormwater Management System Operation and Maintenance The stormwater management system, including all structural stormwater controls and conveyances, should [shall] have an operation and maintenance plan to ensure that it continues to function as designed. Minimum Standard #10 - Pollution Prevention To the maximum extent practicable, the development project should [shall] implement pollutant prevention practices and have a stormwater pollution prevention plan. Minimum Standard #11 - Stormwater Management Site Plan The development project should [shall] prepare a stormwater management site plan for local government review that addresses Minimum Standards #1 through 10. ? ? ? ? ? ? ? ? Volume 2 (Technical Handbook) Georgia Stormwater Management Manual 1.2-3 1.2.2.3 Explanation of Minimum Standards Use of Better Site Design Practices for Stormwater Management (Minimum Standard #1) All site designs should implement a combination of approaches collectively known as stormwater better site design practices to the fullest extent possible. Through the use of these practices and techniques, the impacts of urbanization on the natural hydrology of the site and water quality can be significantly reduced. The goal is to reduce the amount of stormwater runoff and pollutants that are generated, provide for natural on-site control and treatment of runoff, and optimize the location of stormwater management facilities. Better site design concepts can be viewed as both water quantity and water quality management tools and can reduce the size and cost of required structural stormwater controls. Better site design practices are described in Section 1.4. Stormwater Runoff Quality (Minimum Standard #2) Stormwater runoff generated on the development site is to be treated by the stormwater management system to remove at least 80% of the calculated average annual post-development TSS loading from the site. This can be achieved through the use of site design practices and structural stormwater controls. This requirement is quantified and expressed in terms of engineering design criteria through the specification of a water quality volume (WQv) that must be treated to the 80% TSS removal performance goal. The water quality treatment volume is equal to the runoff generated on a site from 1.2 inches of rainfall. The water quality volume is one of the unified stormwater sizing criteria, which are used in conjunction to size and design stormwater management facilities to address stormwater impacts. The unified stormwater sizing criteria and methods to calculate the WQv are discussed in Section 1.3. Structural stormwater controls are sized and designed to treat the WQv. Depending on their removal efficiency or site constraints, more than one structural control may need to be used in parallel or in series (treatment train) to meet the water quality treatment requirement. Further, this standard assumes that structural stormwater controls will be designed, constructed and maintained according to the criteria in this Manual. Stormwater discharges from land uses or activities with higher or special potential pollutant loadings may require the use of specific structural controls and pollution prevention practices. A detailed overview of structural stormwater controls is provided in Section 3.1. The use of nonstructural site design practices that provide water quality benefits allows for a reduction (known as a "credit") of the water quality volume. The applicable design practices and stormwater site design credits are covered in Section 1.4. Stream Channel Protection (Minimum Standard #3) Protection of stream channels is to be provided to both downstream as well as on-site channels. This is accomplished through three complementary criteria: The first method of providing streambank protection is the extended detention of the 1-year, 24hour storm for a period of 24 hours using structural stormwater controls. It is known that the increase in runoff due to development can dramatically increase stream channel erosion. This standard is intended to reduce the frequency, magnitude and duration of post-development bankfull flow conditions. The volume to be detained is also known as the channel protection volume (Cpv). The channel protection volume is one of the unified stormwater sizing criteria, which are used in conjunction to size and design stormwater management facilities to address stormwater impacts. The unified stormwater sizing criteria and methods to calculate the storage requirements and routing of Cpv are discussed in Section 1.3. The use of nonstructural site design practices that reduce the total amount of runoff will also reduce Cpv by a proportional amount. This requirement may be waived by a local jurisdiction for sites that discharge directly into piped stormwater drainage systems, larger streams, rivers, wetlands, lakes, estuaries, tidal waters, or other situations where the reduction in the smaller flows will not have an impact on streambank or channel integrity. 1.2-4 Georgia Stormwater Management Manual Volume 2 (Technical Handbook) The second streambank protection method is to implement velocity control, energy dissipation, streambank stabilization, and erosion prevention practices and structures as necessary in the stormwater management system to prevent downstream erosion and streambank damage. Energy dissipation and velocity control methods are discussed in Section 4.5. The third method of providing for stream channel protection is through the establishment of riparian stream buffers on the development site. Stream buffers not only provide channel protection but also water quality benefits and protection of streamside properties from flooding. It is recommended that 100foot buffers be established where feasible. Additional stream buffer guidelines are presented in Section 1.4. Downstream Overbank Flood Protection (Minimum Standard #4) Overbank flood protection for downstream channels is to be provided by preventing the postdevelopment 25-year, 24-hour storm peak discharge rate (denoted Qp25) from exceeding the predevelopment (or natural conditions) discharge rate using structural stormwater controls. The overbank flood protection peak rate is one of the unified stormwater sizing criteria, which are used in conjunction to size and design stormwater management facilities to address stormwater impacts. The unified stormwater sizing criteria and methods to calculate the storage requirements and routing of Qp25 are discussed in Section 1.3. The use of nonstructural site design practices that reduce the total amount of runoff will also reduce Qp25 by a proportional amount. Smaller storm events (e.g., 2-year and 10-year) are effectively controlled through the combination of the extended detention for the 1-year, 24-hour event (channel protection criterion) and the control of the 25year peak rate for overbank flood protection. These design standards, therefore, are intended to be used in unison. If the control of the 1-year, 24-hour storm under Minimum Standard #3 is exempted, then for overbank flood protection, peak flow attenuation of the 2-year (Qp2) through the 25-year (Qp25) return frequency storm events must be provided. This standard may be adjusted by a local jurisdiction for areas where all downstream conveyances and receiving waters have the natural capacity to handle the full build-out 25-year storm through a combination of channel capacity and overbank flood storage without causing flood damage. Extreme Flood Protection (Minimum Standard #5) Extreme flood protection is to be provided by controlling and/or safely conveying the 100-year, 24-hour storm event (denoted Qf). This is accomplished either by (1) controlling Qf through structural stormwater controls to maintain the existing 100-year floodplain, or (2) by sizing the on- site conveyance system to safely pass Qf and allowing it to discharge into a receiving water whose protected floodplain is sufficiently sized to account for extreme flow increases without causing damage. In this case, the extreme flood protection criterion may be waived by a local jurisdiction in lieu of provision of safe and effective conveyance to receiving waters that have the capacity to handle flow increases at the 100-year level. The extreme flood protection peak rate is one of the unified stormwater sizing criteria, which are used in conjunction to size and design stormwater management facilities to address stormwater impacts. The unified stormwater sizing criteria and methods to calculate the storage requirements and routing of Qf are discussed in Section 1.3. The use of nonstructural site design practices that reduce the total amount of runoff will also reduce Qf by a proportional amount. Downstream Analysis (Minimum Standard #6) Due to peak flow timing and runoff volume effects, some structural controls fail to reduce discharge peaks to predevelopment levels downstream from the development site. A downstream peak flow analysis is to be provided to the point in the watershed downstream of the site or the stormwater management system where the area of the site comprises 10% of the total drainage area. This is to help ensure that there are minimal downstream impacts from the developed site. Volume 2 (Technical Handbook) Georgia Stormwater Management Manual 1.2-5 The downstream analysis may result in the need to resize structural stormwater controls, or may allow the waiving of some unnecessary peak flow controls altogether. The use of a downstream analysis and the "ten-percent" rule are discussed in Section 2.1. Groundwater Recharge (Minimum Standard #7) Recharge to groundwater should be implemented to the extent practicable through the use of nonstructural better site design techniques that allow for recharge of stormwater runoff into the soil. The annual recharge from the post-development site should approximate the annual recharge from the pre-development or existing site conditions, based on soil types. Stormwater runoff from a hotspot site or land use should not be infiltrated without effective pretreatment. The recommended stormwater runoff volume to be recharged to groundwater should be determined using the existing site (pre-development) soil conditions. The recommended rates of recharge for various hydrologic soil groups are as follows: Hydrologic Group A B C D Volume to Recharge (x Total Impervious Area) 0.40 inches of runoff 0.25 inches of runoff 0.10 inches of runoff n/a More information on site design practices that promote infiltration is found in Section 1.4. Construction Erosion and Sedimentation Control (Minimum Standard #8) All new development and redevelopment sites must meet the regulatory requirements for land disturbance activities under the Georgia Erosion and Sedimentation Control Act and/or the NPDES General Permit for Construction Activities. This involves the preparation and implementation of an approved erosion and sedimentation control plan, including appropriate best management practices, during the construction phase of development. Further guidance on practices for construction site erosion and sedimentation control can be found in the Manual for Erosion and Sediment Control in Georgia. Better site design practices and techniques that can reduce the total amount of area that needs to be cleared and graded should be implemented wherever possible. It is essential that erosion and sedimentation control be considered and implemented in stormwater concept plans and throughout the construction phase to prevent damage to natural stormwater drainage systems and previously constructed structural stormwater controls and conveyance facilities. Stormwater Management System Operation and Maintenance (Minimum Standard #9) All new development and redevelopment sites are to prepare a comprehensive operation and maintenance plan for the on-site stormwater management system. This is to include all of the stormwater management system components, including drainage facilities, structural stormwater controls, and conveyance systems. To ensure that stormwater management systems function as they were designed and constructed, the operation and maintenance plan must provide: (1) a clear assignment of stormwater inspection and maintenance responsibilities; (2) the routine and non-routine maintenance tasks to be undertaken; (3) a schedule for inspection and maintenance; and (4) any necessary legally binding maintenance agreements. Pollution Prevention (Minimum Standard #10) All new development and redevelopment sites are to consider pollution prevention in the design and operation of the site, and prepare a formal stormwater pollution prevention plan. Specific land use types and hotspots may need to implement more rigorous pollution prevention practices. The preparation of pollution prevention plans and the full set of pollution prevention practices are covered in Volume 3 of this Manual. 1.2-6 Georgia Stormwater Management Manual Volume 2 (Technical Handbook) Stormwater Management Site Plan (Minimum Standard #11l All new development and redevelopment sites are to develop a stormwater management site plan. The stormwater site plan is to provide details, including a narrative and technical information and analysis, that indicates how the proposed development meets Minimum Standards #1 through 10 (or the applicable local stormwater regulatory requirements). The preparation of stormwater management site plans is covered in Section 1.5. Volume 2 (Technical Handbook) Georgia Stormwater Management Manual 1.2-7 G-RAMP Environmental Assessment APPENDIX D DOD POLICY MEMORANDUM OUTLINING REQUIREMENTS UNDER EISA September 4, 2012 OFFICE OF THE UNDER SECRETARY OF DEFENSE 3000 DEFENSE PENTAGON WASHINGTON, DC 20301?3000 ACQUISITION, TECHNOLOGY AND LOGISTICS MEMORANDUM FOR ACTING ASSISTANT SECRETARY OF THE ARMY (INSTALLAnONS AND ENVIRONMENT) ACTING ASSISTANT SECRETARY OF THE NAVY (INSTALLATIONS AND ENVIRONMENT) ACTING ASSISTANT SECRETARY OF THE AIR FORCE (INSTALLATIONS, LOGISTICS, AND ENVIRONMENT) SUBJECT: DoD Implementation of Storm Water Requirements under Section 438 of the Energy Independence and Security Act (EISA) Reducing the impacts of storm water runoff associated with new construction helps to sustain our water resources. In October 2004, DoD issued Unified Facilities Criteria on Low Impact Development (LID) (UFC 3-210-10), a storm water management strategy designed to maintain the hydrologic functions of a site and mitigate the adverse impacts of storm water runoff from DoD construction projects. Using LID techniques on DoD facility projects can also assist in fulfilling environmental regulatory requirements under the Clean Water Act. Since 2004, DoD has implemented LID techniques for controlling storm water runoff on a number of projects. EISA Section 438 (Title 42, US Code, Section 17094) establishes into law new storm water design requirements for Federal development and redevelopment projects. Under these requirements, Federal facility projects over 5,000 square feet must "maintain or restore, to the maximum extent technically feasible, the predevelopment hydrology of the property with regard to the temperature, rate, volume, and duration of flow." Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic Performance (October 5,2009), directed the U.S. Environmental Protection Agency (EPA) to issue EISA Section 438 guidance. DoD shall implement EISA Section 438 and the EPA Technical Guidance on Implementing the Stormwater RunoffRequirements for Federal Projects under Section 438 ofthe Energy Independence and Security Act, using LID techniques in accordance with the policy outlined in the attachment. EISA Section 438 requirements are independent of storm water requirements under the Clean Water Act and should not be included in permits for storm water unless a State (or EPA) has promulgated regulations for certain EISA Section 438 requirements (i.e., temperature/heat criteria) that are applicable to all regulated entities under its Clean Water Act authority. The attached policy will be incorporated into applicable DoD Unified Facilities Criteria within six months. My points of contact are Thadd Buzan at (703) 571-9079 and Ed Miller at (703) 604-1765. Dorothy Robyn Deputy Under Secretary of Defense (Installations and Environment) Attachment: As stated C/kaflrJ DoD Policy on Implementing Section 438 of the Energy Independence and Security Act (EISA) 1. EISA Section 438 requirements apply to projects that construct facilities with a footprint greater than 5,000 gross square feet, or expand the footprint of existing facilities by more than 5,000 gross square feet. The project footprint consists of all horizontal hard surfaces and disturbed areas associated with the project development, including both building area and pavements (such as roads, parking, and sidewalks). These requirements do not apply to internal renovations, maintenance, or resurfacing of existing pavements. 2. The overall design objective for each project is to maintain predevelopment hydrology and prevent any net increase in storm water runoff. DoD defines "predevelopment hydrology" as the pre-project hydrologic conditions of temperature, rate, volume, and duration of storm water flow from the project site. The analysis of the predevelopment hydrology must include site-specific factors (such as soil type, ground cover, and ground slope) and use modeling or other recognized tools to establish the design objective for the water volume to be managed from the project site. 3. Project site design options shall be evaluated to achieve the design objective to the maximum extent technically feasible. The "maximum extent technically feasible" criterion requires full employment of accepted and reasonable storm water retention and reuse technologies (e.g., bio-retention areas, permeable pavements, cisterns/recycling, and green roofs), subject to site and applicable regulatory constraints (e.g., site size, soil types, vegetation, demand for recycled water, existing structural limitations, state or local prohibitions on water collection). All site-specific technical constraints that limit the full attainment of the design objective shall be documented. If the design objective cannot be met within the project footprint, LID measures may be applied at nearby locations on DoD property (e.g., downstream from the project) within available resources. 4. Prior to finalizing the design for a redevelopment project, DoD Components shall also consider whether natural hydrological conditions of the property can be restored, to the extent practical. 5. Estimated design and construction costs for implementing EISA Section 438 shall be documented in the project cost estimate as a separate line item. Final implementation costs will be documented as part of the project historical file. Postconstruction analysis shall also be conducted to validate the effectiveness of as-built storm water features. The following flowchart illustrates the DoD implementation process for EISA Section 438, consistent with the U.S. Environmental Protection Agency's Technical Guidance on Implementing the Stormwater Runoff Requirements for Federal Projects under Section 438 of the Energy Independence and Security Act (December 2009) (http://www.epa.gov/owow/nps/lid/section438/. Flowchart for EISA ?438 Implementation 1. Determine applicability Requirement: apply to all Federal projects with a footprint greater than 5,000 square feet Requirement: maintain or restore predevelopment hydrology 2. Establish design objective OPTIONS 1 Total volume of rainfall from 95th percentile storm is to be managed on-site. 2 Determine predevelopment hydrology based on site-specific conditions and local meteorology by using continuous simulation modeling techniques, published data, studies, or other established tools. Determine water volume to be managed onsite. Design water volume (to be retained) 3. Evaluate design options Design water volume (to be retained) Requirement: meet design objective to maximum extent technically feasible (METF) TECHNICAL CONSTRAINT EXAMPLES o Retaining storm water on site would adversely impact receiving water flows o Site has shallow bedrock, contaminated soils, high groundwater, underground facilities or utilities o Soil infiltration capacity is limited o Site is too small to infiltrate significant volume o Non-potable water demand (for irrigation, toilets, wash-water, etc.) is too small to warrant water harvesting and reuse systems o Structural, plumbing, or other modifications to existing buildings to manage storm water are infeasible o State or local requirements restrict water harvesting o State or local requirements restrict the use of green infrastructure/LID TYPICAL ON-SITE DESIGN OPTIONS Bio-retention areas Permeable pavements Cisterns / recycling Green roofs Use any combination of on-site options to achieve the design objective to the METF. Document site-specific constraints. remaining water volume? Selected on-site design options OFF-SITE OPTIONS (optional) Selected offsite design options 4. Finalize design and estimate cost G-RAMP Environmental Assessment APPENDIX E NOTICE OF DECISION, NO FURTHER ACTION, GA EPD September 4, 2012 1 Georgia Department of Natural Resources - ., 2 Martin Luther King Jr. Drive, S.E., Suite 1154, Atlanta, Georgia 30334 J, Lonice C. Barrett, Commissioner . Environmental Protectidn Division Hamid F. Flehois, Director COPY September 12, 2002 CERTIFIED MAIL - RETURN RECEIPT REQUESTED Steven W. Coyle, Director Environmental Management 455 Byron Street, Suite 465 Robins Air Force Base, GA 31098-1860 RE: Notice of Decision; Modifications to the Robiris Air Force Base Hazardous Waste Facility Permit EPA ID No. GA1 570 024 330. Dear Mr. Coyle: The Hazardous Waste Management Branch of the Gecirgia Environmental Protection Division (EPD) has made final decisions: (1) to modify the Corrective Action Plan for Landfill Nos. 1 2 [Solid Waste Management Units (SWMUs) 1 2, respectively] dated February 2001 in order to incorporate Replacement Pages 40-52 59-68 and a new Figure 1 for Appendix A submitted to our agency in correspondence (Coyle to Rabon) dated May 10, 2002 [Also see our correspondence (Khaleghi to Coyle) dated May 20, 2002]; (2) to approve the Corrective Action Plan for the Greater Base Industrial Area Trichloroethene Groundwater Contamination (SWMU 20) dated February 27, 2002; (3) to approve the Corrective Action Plan for the Machine Shop at Building 140 (SWMU 40) dated March 8, 2002, as amended; (4) to approve the Corrective Action Plan for the IP-8 Product Line along Main Controlled Taxiway and JP-8 Product Line near intersection of Taxiway No. 2 and Taxiway No. 3 (SWMUs 59 60, respectively) dated December 2001, as amended; (5) to approve the Corrective Action Plan for the Third Street Storm Sewer and Outfall; (SWMU 62) dated March 2001, as amended; (6) that No Further Action is required at this time for the JP-4 Spill Site (SWMU 10A) in response to your Class 3 Permit Modification Request contained in correspondence (Coyle to Ussery) received by our agency on May 15, 2002; Mr. Steven W. Coyle September 12, 2002 Page 2 (7) that No Further Action is required at this time for the Test Firing Range for M61-20mm Guns (Buildings 2041, 2042 2043) (SWMU 63) in response to your Class 3 Pemtit Modification Request contained in correspondence (Coyle to Ussery) dated January 23, 2002; and (8) that No Further Action is required at the Plastic Shop Baghouses at Building 670 (Former Dry Cleaning Facility), Oil/Water Separator at Building 680, Chemical Storage Shed at Building 680, Building 110 - Aircraft Hangar, and Area of Concem (AOC) near Taxiway No. 4 (SWMUs 43, 51, 52 69 and AOC1, respectively). Please note that Item Nos. 1-8 listed above have been incorporated into the modified Permit attached to this correspondence. Our final decisions are based upon the requirements set forth in the Georgia Hazardous Waste Management Act, as amended, O.C.G.A. ?12-8-60, et seq.; and the Rules for Hazardous Waste Management, Chapter 391-3-11, promulgated pursuant thereto, as amended (Rules), Chapter 391-3-11, which incorporates by reference the Code of Federal Regulations found in 40 CFR Parts 124, 260-268, 270, 273 and 279. Prior to making final decisions to incorporate these changes into the Robins Air Force Base Hazardous Waste Facility Permit the Rules require EPD to provide an opportunity for public comment. Accordingly, the forty-five (45) day public comment period began on July 28, 2002 and ended on September 10, 2002. No comments were received during this public comment period. Should you have any questions conceming this correspondence, please contact Brent Rabon of my staff at (404)656- 2833. Sincerely, Harold F. Reheis, Director Attachment c: Mr. Don Webster, EPA Region IV Hle: Robins(R) G-RAMP Environmental Assessment APPENDIX F EXECUTIVE SUMMARY OF PHASE II ARCHEOLOGICAL SURVEY REPORT September 4, 2012 Contract Publication Series TN11-01 PHASE II NATIONAL REGISTER ASSESSMENT OF SITE 9HT10 AT THE PROPOSED GEORGIA-ROBINS AEROSPACE MAINTENANCE PARTNERSHIP FACILITY, WARNER ROBINS, GEORGIA By Paul G. Avery, RPA, and Patrick H. Garrow, RPA Prepared for MACTEC Engineering and Consulting, Inc. 613A Russell Parkway Warner Robins, Georgia 31088 Prepared by Cultural Resource Analysts, Inc. 2908 Sevier Avenue Knoxville, Tennessee 37920 CRA Project No.: T11M001 pgavery@crai-ky.com (865) 249-6035 _______________________ Principal Investigator Paul G. Avery, RPA March 30, 2011 MANAGEMENT SUMMARY Cultural Resource Analysts, Inc. (CRA), was contracted by MACTEC Engineering and Consulting, Inc., to conduct archaeological testing at Site 9HT10 in Warner Robins, Georgia. The site is bounded on the north by the bluff above the Ocmulgee River swamp, to the west by the Warner Robins Water Pollution Control Plant #2, and on the south and east by a large sand quarry. Archaeologists with CRA conducted the archaeological fieldwork between February 9 and 17, 2011. Paul G. Avery, RPA, served as principal investigator and field director. Mr. Avery was assisted in the field by archaeological technicians Chad Caswell, Mike Curran, Dan Marcel, and Jason Ross. Site 9HT10 was recorded in 1977 during the survey for the sewage treatment plant. The site was described as a disturbed lithic scatter and was not considered to be eligible for inclusion on the National Register of Historic Places (NRHP) at that time (Griffin 1977). The site was revisited by archaeologists from Garrow and Associates, Inc., in 1996. Shovel tests conducted at that time revealed intact buried deposits and produced two Middle to Late Archaic projectile points, along with numerous pieces of chert debitage. Further research was recommended on the site based on the artifact density and the presence of intact cultural soil deposits (Espenshade and Holland 1996). Five 1 x 1 m test units and one 1 x 2 m test unit were excavated, which produced 1,799 artifacts. The artifact assemblage consisted primarily of chert flakes, although one Ledbetter, one Elora, and one partial Morrow Mountain I projectile point were recovered. The Elora and Morrow Mountain points were associated with a partially intact buried A-horizon that was recorded in all but one test unit. Based on this association, it is likely that the A-horizon marks the living surface during the Middle to Late Archaic period. Five small ceramic sherds recovered from the plow zone may mark a minor Woodland occupation of the site. Based on the excavations and artifacts recovered, Site 9HT10 has been interpreted as a sporadically occupied camp site with a low density of artifacts. This interpretation is based on the lack of cultural features, lack of identifiable tools, and the high frequency of small flakes, which is indicative of tool maintenance rather than manufacture. The site was likely used as a seasonal camp during periods when resources were sought along the Ocmulgee River and in the wetlands associated with it. The site dates primarily to the Middle and Late Archaic but has a very small Woodland component. A buried A-horizon that was likely the ground surface during the Middle and Late Archaic period occupation of the site was noted in all of the test units south of the access road. Bioturbation has caused the migration of artifacts out of this zone and into the apparently undisturbed soil beneath it. Therefore, the vertical integrity of the A-horizon has been compromised. Based on the lack of vertical integrity and the paucity of diagnostic materials, Site 9HT10 is not recommended eligible for inclusion on the NRHP. The site lacks the potential to provide important information on the past lifeways of the inhabitants. No further research is recommended prior to construction. i G-RAMP Environmental Assessment APPENDIX G MINSHEW-THOMAS-SULLIVAN (WELLSTON) CEMETERY DELINEATION REPORT September 4, 2012 THE DELINEATION OF THE MINSHEW-THOMAS-SULLIVAN CEMETERY (9HT128), G-RAMP, ROBINS AFB AND THE CITY OF WARNER ROBINS, HOUSTON COUNTY, GEORGIA WARNER ROBINS AIR LOGISTICS CENTER ROBINS AFB, GEORGIA Prepared for: 78th Civil Engineer Group, Environmental Management Robins Air Force Base, Georgia Prepared by: URS Corporation Stephen A. Hammack, RPA June 2012 This page intentionally left blank Minshew-Thomas-Sullivan Cemetery Delineation TABLE OF CONTENTS Introduction ................................................................................................................................................. 3 Methodology ................................................................................................................................................ 6 Results of Historical Research ................................................................................................................... 6 Results of Fieldwork ................................................................................................................................... 9 Recommendations ..................................................................................................................................... 15 Recommendations for the City of Warner Robins .................................................................................. 15 Recommendations for Robins AFB ........................................................................................................ 16 Recommendations for the EA ................................................................................................................. 17 Acknowledgments ..................................................................................................................................... 17 References Cited ........................................................................................................................................ 17 FIGURES Figure 1 Annotated Aerial Photograph Depicting Minshew-Thomas-Sullivan Cemetery in Relation to Buildings at Robins AFB, Houston County Georgia (Houston County Board of Tax Assessors 2012)...........................................................................................................4 Figure 2 Minshew-Thomas-Sullivan Cemetery (9Ht128), also known as the Old Wellston Cemetery (Espenshade and Holland 1996:42)...............................................................................5 Figure 3 1847 Deed of Sale for Half of Land Lot 230, Except for One Acre Graveyard (Houston County Superior Court Deed Book J:331)..........................................................................8 Figure 4 The Sullivan Plot, Showing Base Fence in Background, view southwest..........................14 Figure 5 The Minshew-Thomas Plot, view northwest............................................................14 Figure 6 Flags Marking Locations of Unmarked Graves, view southwest.....................................14 Figure 7 Trash Pile and Area of Infant Graves, view southeast.................................................14 MAPS Map 1 TABLES Table 1 Minshew-Thomas-Sullivan Cemetery Data.............................................................11 The Minshew-Thomas-Sullivan Cemetery...............................................................10 1 Minshew-Thomas-Sullivan Cemetery Delineatian This page intentionally left blank 2 Minshew-Thomas-Sullivan Cemetery Delineation Introduction The Georgia Robins Aerospace Maintenance Partnership (G-RAMP) is a proposed development involving the City of Warner Robins and Robins Air Force Base (AFB) in northern Houston County, Georgia. The Executive Summary (ES) of the October 5, 2011 Draft Environmental Assessment (EA) for this project proposed the establishment of a protective fence and 20-foot buffer around a historic family cemetery (Figure 1) on the project area's southern boundary (AMEC 2011:50; ES-11). This buffer was deemed necessary due to uncertainty as to whether or not there might be unidentified graves around the margin of the cemetery. Three early sources referencing the cemetery posited differing numbers of graves. Howell (1982:121) reported nine marked and 11 unmarked graves in this cemetery, Maltais (Garrow and Holland 1993:8) documented seven marked and 11 unmarked graves, and Espenshade and Holland (1996) reported that the cemetery "contains 15 marked graves and at least 12 depressions that may represent unmarked graves." The latter report included a sketch map (Figure 2) of the cemetery, but it was not based on an archaeological delineation. In fact, no investigation of the cemetery thus far, including a more recent investigation by Cultural Resource Analysts (Avery and Garrow 2011) has delineated the cemetery's precise boundaries via standard techniques. On 14 March 2011, Robins AFB's onsite archaeologist (hereafter "Project Archaeologist") performed a pedestrian survey of this cemetery, and in the process identified a minimum of 18 marked graves and at least 15-20 east-west depressions (i.e., probable unmarked graves). Based on this information, and with the approval and cooperation of the Engineering Department of the City of Warner Robins and Robins AFB's 78th Civil Engineer Group (78 CEG), an archaeological delineation was subsequently performed to establish the cemetery's actual physical boundaries. This delineation, conducted by the Project Archaeologist in consultation with Assistant City Engineer Charles Beauchea and the Sullivan family, was performed between February and May 2012. The goal of this study was to use accepted professional techniques to locate and map all marked and unmarked graves, thereby ensuring their protection during the development of the property. 3 Minshew-Thomas-Sullivan Cemetery Delineation Figure 1. Annotated Aerial Photograph Depicting Minshew-Thomas-Sullivan Cemetery in Relation to Buildings at Robins AFB, Houston County Georgia (Houston County Board of Tax Assessors 2012) 4 Minshew-Thomas-Sullivan Cemetery Delineation Figure 2. Minshew-Thomas-Sullivan Cemetery (9Ht128), also known as the Old Wellston Cemetery (Espenshade and Holland 1996:42) 5 Minshew-Thomas-Sullivan Cemetery Delineation Methodology The Project Archaeologist consulted historical maps, county records, and oral history. A title search for deeds pertaining to the property was performed in the Record Room of the Houston County Superior Court. Various will books, estate inventory and sales books, and minute books were consulted at the Houston County Probate Court. Information was also gathered from the Sullivan family, including copies of deeds, plat maps, and other family data relating to the individuals interred in the cemetery. A thorough pedestrian surface inspection of all exposed ground was performed to locate evidence of eastwest depressions, since these can be indicators of unmarked graves. Archaeological probing was the specific methodology utilized for this project, employing a four-foot-long tile probe rod at six-inch intervals over the entire cemetery and adjacent areas. Probing is a method used by professional archaeologists on a widespread basis, and constitutes an accepted form of "ground-truthing." All potential grave locations (both marked and unmarked) were individually mapped using a survey-grade total station. Both the recording of coordinates and the creation of the map were completed by the staff of Robins AFB's 78 CEG. Results of Historical Research The cemetery is located in the extreme southeastern corner of Land Lot 230 in Houston County's 5th Land District. This lot was offered up to the public in Georgia's 4th Land Lottery of 1821. This system of land dispersal was unique to Georgia, and was one of seven such land lotteries in the state. Mary Dew, a widow then living in Chatham County's Mills Militia District, acquired Houston County's Land Lot 230 in this lottery. It is not known if she ever occupied her land. It is known that John Deshazo owned the land a few years later, however, and when he sold it to Nathan Minchew (sic) on August 15, 1827, Deshazo was living in Bullock County northwest of Savannah, evidently never having settled on the land (Houston County Superior Court Deed Book C:429). Nathan Minshew (1770-1846) was a native of North Carolina and was the son of Nathan M. and Elizabeth Bryan Minshew of Dobbs County, North Carolina. He and at least two of his brothers, along with their families, evidently moved to Twiggs County on the Georgia frontier just after the county was opened up to settlement in 1807. The names of his brothers, Jacob and Phillip "Mincey," were listed on a Georgia Militia payroll as privates who assisted in the construction of Fort Twiggs in August 1813 during the Creek War (Clark 1999:434). This fort was probably located along the River Road near the Ocmulgee River in Twiggs County, somewhere in the vicinity of Tarversville. Phillip purchased property in that part 6 Minshew-Thomas-Sullivan Cemetery Delineation of original Houston County that is situated north of Echeconnee Creek in an area that was later transferred to Bibb County (Clark 1999:103). As late as 1829, Nathan Minshew was still paying taxes on his Twiggs land, which encompassed Land Lot 187 (202.5 acres) in Twiggs' 25th Land District in Captain Moors' Militia District. The Minshew family owned property in the vicinity of the cemetery from 1827 until at least 1847. In 1821, Nathan had drawn Land Lot 250 in Houston's 5th Land District when he was living in Twiggs County's Chain Militia District. Land Lot 250 was located just two land lots east and one land lot south of Land Lot 230, indicating that Nathan was attempting to increase the size of his holdings. Nathan was listed as "Head of Household" in the 1830 Census of Houston County, and had three free white males, four free white females, and two slaves living with him at the time (Central Georgia Geneaological Society 1986a:32). He served as a justice of the peace from January 1831-January 1833 (Central Georgia Geneaolgical Society 1998:56). Only a Calvin "Minchew" is listed in the 1840 Census, and no Minshews/Minchews/Minceys are listed at all in the 1850 or 1860 Censuses (Central Georgia Geneaological Society 1986b; 1986c; 1986d). However, Nathan's daughter Margaret married Merrill Thomas, and they are listed as living in close proximity to the area in the 1850 and 1860 Censuses (Central Georgia Geneaological Society 1986c:46; Central Georgia Geneaological Society 1986d:48-49). Her obituary reads as follows: "Mrs. M. E. Thomas, mother of Dr. L. J. Thomas, died on Jul. 15, 1882 after a brief illness. She was 67 years old and the daughter of Nathan Minshew. Her husband had died in Mar. 1863" (Central Georgia Geneaological Society 1998:158). Land Lot 230 was granted by Nathan to his son Redding R. Minshew in 1846, but this was contingent upon the death of Nathan's wife Elizabeth (Houston County Probate Court Will Book A:208). Nathan died on February 24, 1846 and Elizabeth died on the 9th of November in the same year. The next year Redding began selling his father's Houston County land, including Land Lot 230, with one vital exception. The deed of sale (see Figure 3) for the east half of that land lot, which was sold by Redding to William Herrington, contained the words "...all that tract or parcel of land lying and being situate [situated] in the fifth district of said county of Houston and known and distinguished as the East half of lot of land number two hundred and thirty (except one acre in the South East corner of said lot where the grave yard is) in the plan of said district containing one hundred and one fourth of an acre" (Houston County Superior Court Deed Book J:331). It is crucial that this be understood from a property title standpoint, since this deed created "an express reservation of land for burial purposes," even though mention of the cemetery appears to have been omitted from subsequent property deeds (Van Voorhies 2003:5). 7 Minshew-Thomas-Sullivan Cemetery Delineation Figure 3. 1847 Deed of Sale for Half of Land Lot 230, Except for One Acre Graveyard (Houston County Superior Court Deed Book J:331) The title search did not locate any records pertaining to this corner of Land Lot 230 again until the year 1899. The next time the property changed hands appears to have been one-half of this land lot, along with other land, that Julia E. Vinson sold to Ben Roberson in 1899 ( Houston County Superior Court Deed Book BB:501). In 1913, Ben Roberson sold 50 acres in the southeast corner of Land Lot 230 to H. B. Campbell (Houston County Superior Court Deed Book 20:516). Campbell subsequently borrowed money in 1913 from Julia H. Harper, using the property as collateral. This debt was later paid in full (Houston County Superior Court Deed Book 18:386-387). Campbell then sold the 50 acres in 1915 to John B. Haines (Houston County Superior Court Deed Book 20:516). While the cemetery is not mentioned in any of these deeds, it was located on this 50-acre parcel. Although it is not known who owned the property between the years 1915 and 1941, the Sullivan family owned land in this area at the time and utilized the cemetery as their family graveyard for many years. In fact, Thomas Osborn Sullivan leased "the Gray Place" (an unknown location nearby) from L. J. Thomas (Nathan Minshew's grandson) in 1905, and purchased Land Lot 234, which is situated adjacent to the cemetery's eastern side, from Thomas in 1911 for $1,350 (Houston County Superior Court Deed Book 5: 571; Houston County Superior Court Deed Book 15:516). Sullivan died on November 17, 1912, and his obituary stated that "...burial was in the family cemetery about 100 yards from his home. He was 86 years old and had lived on his farm for 30 years, which is near the Ocmulgee River" (Howell 1982:283). It is not currently known if Sullivan actually owned either part or all of Land Lot 230. 8 Minshew-Thomas-Sullivan Cemetery Delineation While no deeds were found between 1915 and 1941, it is clear that the Sullivan family did own that part of Land Lot 230 where the cemetery is located for part or all of that time. The next deed that references this part of Land Lot 230 dates to 1941, when Mattie Lee (Sullivan) Thornton, Thomas O. Sullivan's daughter, sold the east half of the land lot and all of Land Lot 234 to Martin J. Reid for $3,200 (Houston County Superior Court Deed Book 50:555). Reid eventually acquired a total of 623.64 acres of contiguous land, including the cemetery tract, and his heirs retained the property until 1997. However, their ownership is quite difficult to understand since "undivided interests" based on percentages were awarded to four heirs in 1966 (HCSC DB 272:34-36). Furthermore, one of Reid's daughters had married a West, obtained three of the four interests, and died intestate by 1968. Although her interest was awarded to her husband, son, and daughter, the Wests (controlling a 3/4 interest) and the other heir (with a 1/4 interest) appear to have worked together for their common benefit, and leased the land to the Georgia Department of Natural Resources (DNR) in the late 1970s. The family finally sold the entire tract to the Georgia Department of Natural Resources in 1997, and it remained part of Oaky Woods Wildlife Management Area until deeded to the City of Warner Robins just in 2006. A plat dated 1964 shows the property where the city would build its sewage treatment plant (Houston County Superior Court Plat Book 9:84). Although it does show the corner of the four land lots where the cemetery is, it does not show the cemetery at this location. The entire Reid property is shown on a plat dated 1970, but this plat does not depict the cemetery either (Houston County Superior Court Plat Book 15:220), and neither do the two plats granting easements through the Reid property granted to the City of Warner Robins in 1976 and to the owners of Bradley Plywood Company in 1979 (Houston County Superior Court Plat Book 18:300; Houston County Superior Court Plat Book 22:371). The first plat to actually depict the cemetery is the Georgia Department of Natural Resources (DNR) Plat of 1979, although this plat was not actually recorded until 1997 (Houston County Superior Court Plat Book 50:24). Finally, a copy of Arthur Sullivan, Sr.'s 2006 plat of the cemetery (entered for him into the records of the Superior Court), and provided by him personally, shows a slightly larger area than that shown on the 1979 plat. Results of Fieldwork The cemetery was delineated during February to May of 2012. The following discussion of the delineation will refer to the project map, included below as Map 1, and to Table 1, which contains important field data (including UTMs in NAD 83 for each grave) and information on the identities of the interred both from the tombstones and from family history. All four corners of the original cemetery boundary survey were located early in the field work. It was initially thought that the survey plat was drawn in 2002; hence this date is found on the smaller of the two rectangles (in green) on the project map. Recent title research 9 Cemetery Delineatian thi [lawfi.- . I >>-.1. - .e - A We QE: Bri" A I Llufr f, IHA-- is 1 igggs, -- e'eeThe Cemetery 10 Minshew-Thomas-Sullivan Cemetery Delineation Table 1. Minshew-Thomas-Sullivan Cemetery Data Grave Name Marked/Unmarked* Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Robert Proctor Sarah (Sally) Watson Sullivan Thomas Osborn Sullivan, CSA Son of Thomas and Sarah Sullivan Son of Thomas and Sarah Sullivan Minnie Cobb Rogers Unknown R. A. Thomas Unknown Unknown Unknown Unknown Unknown Unknown Elizabeth Minshew Nathan Minshew Unknown Unknown Unknown Unknown Unknown Unknown Unknown Lizzie Hutto Walter Hutto Frank S. Sullivan Mrs. F. S. Sullivan Ernest F. Sullivan Unknown Sullivan child Elizabeth Self Sullivan Anna Hoskins Betty Jean Fincher Unknown Confederate Soldier Unknown Unknown Unknown Unknown Unknown Unmarked Marked Unmarked Unmarked Marked Marked Unmarked Unmarked Marked Marked Marked Marked Unmarked Unmarked Marked Unmarked Unmarked Unmarked Marked Marked Marked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Marked Unmarked Marked Unmarked Unmarked Unmarked UTM Easting (X) 256740.4113 256728.0077 256734.2118 256733.7309 256721.6631 256733.7836 256742.8252 256725.92 256729.4208 256728.8588 256729.8111 256727.9765 256740.2064 256745.254 256715.9927 256744.0155 256733.6445 256740.7325 256727.2114 256729.7499 256727.9501 256735.1531 256741.5429 256746.6497 256740.8773 256726.5496 256746.3738 256719.8608 256722.9339 256734.6504 256746.5099 256743.3154 256726.9272 256742.5237 256729.3911 256728.8322 256728.1025 256729.415 UTM Northing (Y) 3615582.983 3615539.985 3615571.669 3615565.583 3615572.563 3615559.613 3615567.787 3615569.661 3615570.1 3615569.202 3615541.011 3615540.899 3615544.735 3615543.716 3615534.614 3615580.991 3615564.59 3615538.56 3615548.59 3615539.775 3615539.048 3615581.79 3615554.696 3615564.992 3615575.299 3615540.993 3615579.853 3615552.472 3615552.417 3615577.749 3615581.002 3615574.389 3615546.135 3615569.044 3615536.807 3615566.836 3615542.725 3615571.837 11 Minshew-Thomas-Sullivan Cemetery Delineation Grave Number 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 FT1** FT2 FT3 FT4 FT5 FT6 FT7 FT8 UTM Easting (X) 256746.5909 256729.0389 256729.8198 256729.6563 256739.9254 256732.1906 256725.9022 256722.8398 256733.8405 256734.8515 256744.6008 256734.7762 256741.643 256746.0528 256723.2352 256748.5414 256742.5126 256740.6083 256728.0017 256744.6255 256719.6684 256740.9027 256726.6982 256727.1217 256723.7019 256745.2878 256744.9104 256746.3414 256740.0094 256740.6619 256723.0381 256729.6572 256724.4819 256715.6869 256715.8792 256732.8533 256726.9951 256719.9653 256723.2553 UTM Northing (Y) 3615563.552 3615567.861 3615542.317 3615538.475 3615542.79 3615536.608 3615570.908 3615551.132 3615563.13 3615579.122 3615548.046 3615580.439 3615564.356 3615574.563 3615571.059 3615560.344 3615571.243 3615574.371 3615541.75 3615545.816 3615551.305 3615576.442 3615573.264 3615547.328 3615574.262 3615550.55 3615548.984 3615582.181 3615540.286 3615547.221 3615567.875 3615530.583 3615529.891 3615532.751 3615536.144 3615549.902 3615578.913 3615553.841 3615555.995 Name Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Robert Proctor's Mother? Robert Proctor's Mother? Unknown Unknown Unknown Unknown Marked/Unmarked* Unmarked Unmarked Marked Marked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Marked Unmarked Unmarked Unmarked Marked Unmarked Unmarked Unmarked Unmarked Marked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Unmarked Marked Unmarked Unmarked * The Marked/Unmarked column denotes any marker of any kind, including concrete slabs, bricks, or headstones ** Grave numbers FT1-8 (below number 69) are those reported by Mr. Sullivan according to Family Tradition (FT), and could not be verified through archaeological probing. 12 Minshew-Thomas-Sullivan Cemetery Delineation has shown that this survey was actually performed in 1979 for the Georgia Department of Natural Resources. Mr. Arthur Sullivan, Sr. also provided a copy of the more recent survey he had performed in 2006, and all four corners shown on this plat were also located on the ground. As the map indicates, these two surveys share their southeastern and southwestern corners, but the other two corners differ considerably. Mr. Sullivan also pointed out the locations of graves according to family tradition, and while these areas were carefully tested with the probe rod, nothing was found that would have indicated graves in these areas. Despite this result, it is always important to utilize oral tradition as much as possible, so these graves are also depicted on the project map. These include eight individual graves (depicted in yellow and numbered 1-8 on the map, and numbered as Family Tradition [FT] 1-8 on the table), as well as three other areas where multiple graves were reported. These three areas are depicted in the map by the rectangles containing red, blue, and green stripes. Of the yellow numbered graves, only one individual grave could be identified. Although Mr. Sullivan was unsure which one, either Grave 3 or 4 (in yellow) represents the location of the grave of Robert Proctor's mother, and was the last burial identified in the cemetery. Eighteen marked graves were located. Some of these had names and/or other information on them, and some had no information of any kind. During the process of delineating the cemetery, 51 previously unknown graves were documented, including some with concrete slabs and others with brick edging that were covered with leaves or pine straw. The vast majority of these graves were located with the probe rod, and had no marker of any kind associated with them, including 14 graves located north of the presumed cemetery boundary. Several of these were north of the proposed 20-foot buffer. The Minshew-Thomas Plot, in the northeastern part of the cemetery, contained four marked and eight other previously undocumented graves (Graves 6-17) within a wrought iron fence (see Figure 5). A large number of cola bottles were found in the northeastern corner of this plot and outside the fence to the northeast. It is unknown at this time if this represents something cultural or merely an old bottle dump, but the latter is more likely. The Sullivan Plot, in the south-central part of the cemetery, contained nine marked and three other previously undocumented graves (Graves 18-29) within a wrought iron fence (see Figure 4). The identities of individuals interred in seven other marked graves (Graves 2-5, 30-32) were provided by Mr. Sullivan. The remainder of the graves was located outside of these fenced plots, and are mostly unknown (Graves 33-69) (see Figure 6). Four large trees, identified in the map legend as "relevant flora," are also depicted on the map because they are among the largest trees in the cemetery and were used in reference to grave locations during verbal interview, primarily with Mr. Sullivan. 13 Minshew-Thomas-Sullivan Cemetery Delineation Most of the previously undocumented graves were situated in the eastern half of the cemetery (Graves 3369), and extended northward towards the trash dump, a debris pile which consisted of an extensive area where bricks, tires, sheet metal, concrete, farm equipment, car parts, and other debris were dumped during the last 50 years. City workers used a backhoe to push the central portion of the debris up into a trash pile (depicted in gray on the map) so that probing could be performed in this area. Although the remaining debris prevented successful probing, Mr. Sullivan also reported graves in this most northerly portion of the cemetery. He said that his father told neighbors and family members not to bury anyone outside the old wire fence line (represented by the northern line of his 2006 survey plat), but some people did not listen and buried an unknown number of infants in the area now covered by a trash dump (see Figure 7). This area is depicted on the map by the green striped rectangle. Figure 4. The Sullivan Plot, Showing Base Fence in Background, view southwest Figure 5. The Minshew-Thomas Plot, view northwest Figure 6. Flags Marking Locations of Unmarked Graves, view southwest Figure 7. Trash Pile and Area of Infant Graves, view southeast 14 Minshew-Thomas-Sullivan Cemetery Delineation Recommendations Recommendations for the City of Warner Robins Further field work is still needed to establish the northern boundary of the Minshew-Thomas-Sullivan Cemetery. The trash dump covering this part of the cemetery should be removed carefully according to the following methodology, so the delineation can be completed. A backhoe is the primary tool recommended for removing the trash dump, since it can be a satisfactory archaeological excavation tool when equipped with either a bucket lacking teeth (a flat, straight digging edge), or the temporary addition (i.e., spot welding) of a section of grader blade that is the width of the bucket and that entirely covers and extends beyond the leading edge of the bucket teeth. A backhoe bucket equipped with a straight cutting edge, or one that is modified as described above to have a straight cutting edge, will produce a smooth cut across the soil when skimmed, and will allow for the careful removal of the majority of the debris. Removal of the debris will also necessitate removing some material that has already begun to sink into the ground, so it is recommended that after most of the easier-to-remove debris is out of the way, the backhoe operator should carefully strip off the grass in the debris field in order to expose other material that has already sunk into the ground. This will also make it quite easy to see dark stains, or features, in the top layer of soil, and a professional archaeologist can determine if these dark stains are graves or not, and record them as such if necessary. The removal of sunken debris with a backhoe should proceed slowly and carefully under the supervision of an archaeologist, not disturbing soil in excess of three inches as each pass is made along the full reach of the backhoe arm. If the archaeologist identifies a feature, or probable grave, during the backhoe skimming of the grass, the operator must cease immediately in order to permit an assessment of the feature. Some combination of probing and remote sensing is also recommended in this area after the trash dump has been removed. It is also recommended that the city hire an experienced real estate attorney to perform a more detailed title search regarding the one-acre cemetery reservation. Because the 1847 deed specifically reserved one acre for the cemetery, and no later deeds were found that mentioned this fact, there is some legal question as to the current ownership of the cemetery. Fee simple (absolute ownership) to this one-acre reservation may indeed be held by the City of Warner Robins, but every effort should be made to locate other deeds to verify this. The legal question to answer in the absence of more recent deeds specifically mentioning the cemetery is whether adverse possession ("a method of acquisition of title to real property by possession or a statutory period under certain conditions") under color of title ("that which is a semblance or appearance 15 Minshew-Thomas-Sullivan Cemetery Delineation of title, but is not title in fact or in law") can or cannot run against a cemetery (Black 1979:49, 24; James M. Preston, Cadastral Land Surveyor, personal communication, May 17, 2011). Until further field work can clarify the possible existence of graves in the northern portion of the cemetery, and until a more detailed title search can clarify the question of ownership of the cemetery reservation, it is recommended that the City of Warner Robins protect an area slightly larger than one acre in size. The orange line on the project map depicts the presumed one acre parcel reserved by the 1847 deed, based on the findings of this delineation and the two survey plats. Since the 2006 cemetery plat extends approximately 20 feet east of the common boundary between Land Lots 230 and 234, it is further recommended that the protected area be extended to the eastern boundary of the 2006 survey. This line is also shown on the project map (in blue), and is easy to locate since it includes the north-south measurement of 185.42 feet. Recommendations for Robins AFB A number of studies have found that historical cemeteries were purposely placed on property lines, probably to maximize available agricultural land and to keep from having to farm around graves. While this is true across the South, and probably across the nation, there are specific examples from northern Alabama and middle Georgia that can be cited. For instance, Bankhead National Forest in northwestern Alabama has examples of this type of cemetery placement (Jefferson M. Thomson, personal communication, May 18, 2012). There are also examples of this closer to home in middle Georgia. A recent cemetery relocation project in southern Bibb County, just a few miles north of the project area, revealed that the Avondale Burial Place was situated along land lot lines (Matternes et al. 2012). And the Parker Cemetery, which was removed from Robins Air Force Base in 1952, was situated at the common corner of four land lots (Hammack 2011: Figure 17). Although the southern-most grave reported at the Minshew-Thomas-Sullivan Cemetery is 18.25 feet from the Robins AFB property line and 25.86 feet from the Base perimeter fence, as depicted in the Base Geographic Information System (GIS), it is 28.9 feet from the corner of the four land lots. According to early installation records, Land Lot 230 was not included in the original land bought by the City of Macon and given to the U.S. Government (McConnell 1944: Appendix 2). Because the cemetery was situated at the corner of four land lots, as stated in the 1847 deed of sale, this means that the Base boundary line is 10.65 feet north of its correct physical location on the land lot line. It also means that there could be additional graves all the way down to or even south of the actual land lot corners, inside the current fence line. 16 Minshew-Thomas-Sullivan Cemetery Delineation It is therefore recommended that Robins AFB investigate this area archaeologically in order to determine whether any graves associated with the Minshew-Thomas-Sullivan Cemetery are on Base property. The use of the multiple methodologies of probing, Ground Penetrating Radar, and magnetometry, which were used in a previous Base cemetery project, would offer the best results (Hammack et al. 2008). If additional graves relating to the Minshew-Thomas-Sullivan Cemetery are located on installation property in the future, then they should be protected according to the guidelines specified in the Base's recent Cemetery Preservation Plan (Hammack 2011). Recommendations for the EA Once this report is reviewed and approved by the relevant personnel at both Robins AFB and the City of Warner Robins, it will be submitted by Robins AFB to the Georgia State Historic Preservation Office (SHPO) for a 30-day review period, as stated in the mitigation plan. Upon the receipt of a letter from the SHPO concerning the report, the City will be informed and provided with a copy of this letter. It is recommended that both the letter and the full archaeological report be included as an appendix in the next revision of the EA by the City's contractor (AMEC), and that the text of the EA also be revised to include the recommendations of this report. Acknowledgments This project could not have been conducted without the participation of several individuals. First and foremost, Arthur Sullivan, Sr., his wife Betty, and son Arthur Sullivan, Jr. were kind enough to meet at the cemetery, share family traditions concerning the cemetery, point out where unmarked graves are located, and provide copies of family records and the 2006 cemetery plat. Second, Warner Robins Assistant City Engineer Charles Beauchea provided access to the cemetery multiple times, and also assisted in the field with the location of survey pins. Third, the Robins AFB survey crew, consisting of Jim Hurst, Krista Mott, and Josh Winters recorded GPS points for all the graves and other points shown on the project map. And finally, Krista Mott used her considerable GIS talents in creating the wonderful map, thereby making it the centerpiece of this project and this report. To all of these individuals a vast debt of gratitude is due. Further, the project would not have been possible without the funding provided by the 78 CEG. References Cited AMEC E&I, Inc. (AMEC) 2011 Georgia Robins Aerospace Maintenance Partnership (G-RAMP) Draft Environmental Assessment. AMEC E&I, Inc., Kennesaw, GA, October 5, 2011. 17 Minshew-Thomas-Sullivan Cemetery Delineation Avery, Paul G. and Patrick H. Garrow 2011 Phase II National Register Assessment of Site 9Ht10 at the Proposed G-RAMP Facility, Warner Robins, Georgia. Cultural Resource Analysts, Inc., Knoxville, TN. Black, Henry Campbell 1979 Black's Law Dictionary, 5th Edition. West Publishing Co., St. Paul, MN. Central Georgia Genealogical Society (CGGS) 1986a 1830 Federal Census for Houston County, Georgia. CGGS, Warner Robins, GA. 1986b 1840 Federal Census for Houston County, Georgia. CGGS, Warner Robins, GA. 1986c 1850 Federal Census for Houston County, Georgia. CGGS, Warner Robins, GA. 1986d 1860 Federal Census for Houston County, Georgia. CGGS, Warner Robins, GA. 1998 First Hundred and Ten Years of Houston County, Georgia, 1822-1932. CGGS, Warner Robins, GA. Clark, Bess Vaughn 1999 Twiggs County Georgia Records: A Reconstructed Heritage: A Collection from Newspapers, Deeds, Bible Records, Military Records, Wills, Personal Journals, and Papers. Wolfe Publishing, Fernandina Beach, FL. Espenshade, Christopher T. and Jeffrey Holland 1996 Archaeological Survey of the Upland Portions of a Proposed Base Expansion Area, Robins Air Force Base, Houston County, Georgia. Garrow & Associates, Inc., Atlanta, GA. Garrow, Patrick H. and Jeffrey L. Holland 1993 Historical and Archaeological Studies of Cemeteries Located Within Robins Air Force Base, Houston County, Georgia. Garrow & Associates, Atlanta, GA. Hammack, Stephen A. 2011 Cemetery Preservation Plan, Robins Air Force Base, Houston County, Georgia. URS Group, Warner Robins, GA. Hammack, Stephen A., Matthew A. Barner, and Timothy J. King 2008 History and Remote Sensing of Cemeteries on Robins Air Force Base, Houston County, Georgia. URS Corporation, Warner Robins, GA. Houston County Board of Tax Assessors (HCBTA) 2012 Annotated Aerial Photograph Depicting Thomas & Sullivan Cemetery in Relation to Buildings at Robins AFB. URL: http://www.qpublic.net/ga/houston/, accessed January 20, 2012. Houston County Probate Court (HCPC) n.d. Various Will Books (WB). Houston County Superior Court (HCSC) n.d. Various Deed Books (DB) and Plat Books (PB). Howell, Addie Paramor 1982 Cemeteries & Obituaries of Houston County Georgia. Omni Press, Macon, GA. Matternes, Hugh, Valerie Davis, Julie Coco, Staci Richey, and Sarah Lowry 2012 Hold Your Light on Canaan's Shore: A Historical and Archaeological Investigation of the 18 Minshew-Thomas-Sullivan Cemetery Delineation Avondale Burial Place (9BI164) Volume I: Report of Investigation. New South Associates, Stone Mountain, GA. McConnell, Lewis A. 1944 History of Warner Robins Air Service Command, CY 1941-43, Volume I. History Office, Robins AFB, GA. Van Voorhies, Christine 2003 Grave Intentions: A Comprehensive Guide to Preserving Historic Cemeteries in Georgia. Georgia Department of Natural Resources, Historic Preservation Division, Atlanta, GA. 19 Minshew-Thomas-Sullivan Cemetery Delineatian This page intentionally left blank 20