Next NGA West Draft EIS, St. Louis - Executive Summary

Executive Summary
ES-1 Introduction
The National Geospatial-Intelligence Agency (NGA) is investigating sites for the construction and operation
of the Next NGA West Campus in the greater St. Louis metropolitan area. This effort is required to replace
mission critical facilities at the current St. Louis facility (South 2nd Street facility), which have exceeded their
service life and can no longer support the technology changes required for the NGA mission.
The Kansas City District of the U.S. Army Corps of Engineers (USACE) has developed the enclosed
environmental impact statement (EIS) in accordance with the National Environmental Policy Act of 1969
(NEPA) to evaluate the social and environmental impacts associated with the construction and operation of
the Next NGA West Campus. NGA is the proponent of this action and the U.S. Air Force (USAF) is a
cooperating agency under NEPA because the USAF may be the ultimate property owner of the Next NGA
West Campus. The Federal Aviation Administration (FAA) is a coordinating agency on this action because it
participated in the purchase of the St. Clair County Site and has associated grant assurance obligations. The
FAA is also acting as the airspace authority for this EIS.
NGA will decide on a site for the construction and operation of the Next NGA West Campus. NGA will
develop the final decision on site selection after gathering information from agencies, the public, and others
through the NEPA process and by performing the environmental impact analysis shown in this EIS. NGA will
consider the information gathered during the EIS, along with other critical factors such as its ability to
perform its mission, maintain a secure environment, and meet the construction schedule. The final selection
criteria and decision will be documented in the Record of Decision (ROD), which will be distributed after
publication of the Final EIS (FEIS).
The scope of this EIS includes the potential environmental impacts caused by the proposed construction and
operation of the Next NGA West Campus in the St. Louis metropolitan area. The intent of the EIS is to
inform the NGA decision makers of the potential project impacts through a complete and objective analysis of
the alternatives. Four site alternatives that would meet the purpose and need of the project, as well as a No
Action Alternative, are considered in the analysis.
If NGA moves from its existing location, the current property owner, the USAF, in conjunction with the NGA
and General Services Administration, will be responsible for addressing the future use of the vacated South
2nd Street facilities. Insufficient information is available to discuss possible future uses of the South 2nd Street
facilities at this time; therefore, use of these facilities after NGA vacates is not part of this EIS. The USAF will
prepare the necessary NEPA documentation and conduct the National Historic Preservation Act Section 106
consultation for the future use of the South 2nd Street facilities when potential alternative uses have been
identified.
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EXECUTIVESUMMARY
ES-2 Purpose and Need for Action

ES-2.1 Purpose
The purpose of Next NGA West Campus is to enhance current and future missions, improve resiliency, and
resolve security challenges associated with the South 2nd Street facilities. Challenges associated with the
South 2nd Street facilities include the proximity to floodplains and incompatible adjacent industrial activities,
as well as the age and physical setting of the existing buildings, which limit NGAs ability to economically
renovate the facilities to meet current facility standards. In addition, the South 2nd Street facilities cannot be
made to meet post-9/11 requirements for protection of the workforce and mission.
ES-2.2 Need
NGA needs a new campus capable of supporting current and future mission requirements at a location that
complies with established standards for such facilities. Construction and operation of the campus needs to
meet the following site location and facility requirements:
1. Allows for continuity and resiliency for existing and future NGA operations
2. Provides purpose-built facilities that are safe, secure, flexible, and efficient
3. Is conducive to recruiting and retaining top-quality employees
4. Stays within anticipated funding limits for construction, operation, and maintenance
5. Supports future changes to mission requirements
6. Provides necessary utilities, telecommunication, and transportation infrastructure
7. Contains a boundary that is a usable shape for necessary buildings and infrastructure and is outside a
100-year floodplain
8. Provides physical security and force protection with appropriate setbacks from adjacent roads,
railroads, and property boundaries
9. Provides potential to use topography and landscape to enhance security
10. Site is available for acquisition and construction in early 2017
11. Meets or exceeds current building standards and codes, particularly those related to the design,
detailing, and construction of structural and non-structural components, to resist the effects of seismic
and other natural or human-made events
ES-3 Description of the Proposed Action

The NGAs Proposed Action is to site, construct, and operate a purpose-built geospatial collection, analysis,
and distribution campus. The purpose-built facility will provide an open and flexible work environment that is
scalable, reconfigurable, and adaptive to changing mission requirements. The Next NGA West Campus would
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EXECUTIVESUMMARY
be designed to accommodate a workforce of approximately 3,150 government personnel and contractors.

Construction activities are expected to begin the summer of 2017 and last for approximately 5 years.
For the purpose of this EIS, a full build-out of the construction area is assumed, and no existing buildings or
infrastructure would remain. The following facilities would be constructed at the site:
Main operations building
Data center (may be constructed sometime in the future)
Central utility plant
Visitor control center
Remote inspection facility
Primary and secondary access control points
Security fencing around the site perimeter
Supporting infrastructure, such as parking, interior roads, and sidewalks
ES-4 Description of the No Action Alternative

Under the No Action Alternative, the NGA would not construct or operate a new campus. NGA would remain
at the South 2nd Street location and these facilities would not be renovated or upgraded. Further, it is assumed
the current conditions at each of the proposed sites would continue. The No Action Alternative does not meet
the purpose and need of the Proposed Action. The No Action Alternative analysis serves as the baseline for
the comparison of environmental impacts.
ES-5 Alternatives Carried Forward for Analysis

Siting, construction, and operation of the Next NGA West Campus at one of four alternative locations
(Figure ES-1) are considered in the EIS. The alternative locations are described in detail in the following
subsections.
ES-5.1 Fenton Site

The Fenton Site (1050 Dodge Drive, Fenton, Missouri) is located in south St. Louis County, Missouri, on a
167-acre tract adjacent to Interstate 44/U.S. Route 50. This site is located within a larger 294-acre parcel
proposed for redevelopment as mixed-use build to suit industrial/commercial use along the Meramec River.
This property is the former location of a Chrysler automobile assembly plant that was demolished in 2009.
The existing site is flat and covered almost entirely in concrete and asphalt, which would be removed under
the Proposed Action. The property is unoccupied with the exception of a trailer used by the site developers as
a sales office. The Fenton Site is owned by a private developer and is currently for sale.
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ES-3
Fenton
UNCLASSIFIED
Prospective
Site Locations
St. Louis City
2nd Street
Mehlville
St. Clair Countyy
D
D
UNC
UNCLASSIFIED
CLA
LAS
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AS
A
SSI
SIFIED
SIF
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Arnold
UNCLASSIFIED
Figure ES-1
Proposed Site Locations
EXECUTIVESUMMARY
ES-5.2 Mehlville Site

The Mehlville Site (13045 Tesson Ferry Road, St. Louis, Missouri) encompasses a 101-acre tract in south
St. Louis County, Missouri. The site is slightly graded with an existing 645,520-square-foot two-story office
complex with interconnected buildings constructed for Metropolitan Life Insurance Company in 1976. The
Mehlville property has a well-maintained office setting and grounds with parking, infrastructure, and interior
stormwater retention pond. Along the southern border of the Mehlville Site, the property contains natural
forested conditions. Because of NGAs unique requirements, the existing office complex cannot be renovated.
The building, structures, and infrastructure would be removed as part of the Proposed Action. The Mehlville
Site is owned by private interests.
ES-5.3 St. Louis City Site

The St. Louis City Site (2300 Cass Avenue, St. Louis, Missouri) is a 100-acre site located within the city
limits of the city of St. Louis. This area is predominantly vacant land with some residential, light industrial,
and commercial use. It is situated just north of the city of St. Louis downtown at the intersection of Jefferson
and Cass Avenues. The city of St. Louis recommended this site for review because it is part of an ongoing
redevelopment effort by the city. Divestment has occurred over decades at the site, leading to a current
70 percent vacancy rate, and the city has designated the site a blighted community. A limited number of
community resources and homes remain within the proposed area footprint. Many of the vacant residential
lots are unmaintained and some have been converted into urban garden plots. The St. Louis City Site is within
the proposed NorthSide Regeneration Project area (NorthSide Regeneration St. Louis, 2015) and within the
U.S. Department of Housing and Urban Developments footprint for an Urban Promise Zone initiative for the
city of St. Louis.
ES-5.4 St. Clair County Site

The St. Clair County Site (Wherry Road and Rieder Road) comprises 182 acres situated between Scott Air
Force Base (AFB) and MidAmerica St. Louis Airport near Shiloh, Illinois. This site is undeveloped and
relatively level, and approximately 80 percent of the location has been used as cultivated, agricultural land for
the past century. Scott AFB and its Cardinal Creek Golf Course bound the site to the south. The St. Clair
County Site is currently owned by St. Clair County.
ES-6 Public Outreach and Involvement

A variety of public involvement activities, tools, and techniques were used to engage community members
and government agencies during the EIS process, including a project website, formal public meetings,
informal stakeholder phone calls and meetings, elected and public official briefings, media briefings, mailed
announcements, emails, newspaper advertisements, and press releases. During NEPA scoping, NGA sought
input from government agencies, tribes, elected officials, non-governmental organizations, and the public on
the proposed construction and operation of a new campus. Input received during the scoping period assisted
NGA in identifying the concerns to focus on in the EIS. Public scoping meetings were held at the
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EXECUTIVESUMMARY
South 2nd Street facilities for NGA personnel and in community centers near each of the alternative sites for
the public. A detailed summary of the scoping meetings are presented in Appendix 1B NGA EIS Scoping
Report (Vector, 2015), and a full list of comments received along with government responses is provided in
Appendix 1C.
ES-7 Environmental Justice

Each alternative site location was assessed in consideration of Executive Order (E.O.) 12898 Federal Actions
to Address Environmental Justice in Minority Populations and Low-Income Populations. Section 5.0,
Environmental Justice, presents a description of the community around each site, along with the comparative
proportion of minority and low-income populations. USEPA's environmental justice screening and mapping
tool (EJSCREEN) and Census data were used to determine whether there are environmental justice concerns
present at each site.
The St. Louis City Site is the only site with substantial minority and low-income populations that may be
affected by the Next NGA West Campus, based on the EJSCREEN tool results and Census data. If the
St. Louis City Site is selected, the short-term impacts of relocation for residents and business would be borne
primarily by minority and low-income populations. However, this impact is not high and adverse in light of
the Missouri relocation statutes (Sections 523.200215, RSMo, 2014), which also meet the requirements of
the federal Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended.
Additionally, the Next NGA West Campus is consistent with the city of St. Louis redevelopment plans for
the area and may provide a stabilizing effect, indirectly leading development attraction and eventual
momentum toward enhancing the NorthSide community resources.
E.O. 12898 calls for federal agencies to provide opportunities for stakeholders to obtain information and
provide comment on federal actions. NGA is complying with E.O. 12898 by conducting a public involvement
program that includes targeted efforts to engage, inform, and solicit input from minority and low-income
populations as demonstrated through additional meetings in the St. Louis City Site neighborhood and added
outreach to community leaders.
ES-8 Selection of Preferred Alternative

Council on Environmental Quality (CEQ) regulations at Title 40 of the Code of Federal Regulations (CFR)
Section 1502.14(e) require an agency to identify its preferred alternative, if one exists, in the Draft EIS. At
this time, NGA does not have a preferred alternative. However, NGA will identify the preferred alternative in
the FEIS.
ES-9 Approach to Environmental Analysis

The direct, indirect, and cumulative impacts of implementing NGAs Proposed Action are evaluated in
accordance with the CEQs guidance for implementing NEPA (CEQ, 1983, 1997). The construction of the
proposed project would occur over a 5-year period and would include direct and indirect effects on the human
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and natural environments. Direct effects are caused by the action and occur at the same time and place,
whereas indirect effects are caused by the action, reasonably foreseeable, and occur later in time. Cumulative
impacts result from the incremental impact of the action when added to other past, present, and reasonably
foreseeable actions, which may be undertaken by other private or public entities. Fourteen natural and human
resource areas are analyzed in the EIS.
ES-10 Comparison of Environmental Impacts by Alternative

Table ES-1 presents the direct/indirect impacts, cumulative impacts, and the environmental protection
measures by resource area to illustrate the impact differences between the alternatives. Table ES-1
summarizes the areas where potential environmental impacts are present; impacts that were deemed
no/negligible in the analysis are not described in detail.
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EXECUTIVESUMMARY
TABLE ES-1
Summary of Impacts
Resource
No Action
Fenton Site
Mehlville Site
St. Louis City Site
St. Clair County Site
Socioeconomics
Direct/Indirect
Benefits
Direct/Indirect
Impacts
Only no/negligible impacts
Minor to moderate, short-term benefit from

construction employment

Minor to moderate, short-term benefit from construction

employment


construction employment (households and
industry)

construction employment (households and
industry)
Minor to moderate, short-term benefit from construction

employment (households and industry)

construction employment (households and industry)
Minor to moderate short-term benefit from

increased spending during construction
Minor to moderate short-term benefit from increased

spending during construction
Minor to moderate short-term benefit from

increased spending during construction
Minor to moderate short-term benefit from increased

spending during construction
Minor to moderate long-term benefit induced employment
Minor to moderate long-term benefit

induced employment
Minor to moderate long-term benefit

induced employment
Minor to moderate long-term benefit induced

employment
Minor to moderate, negative, long-term

impact from loss of earnings tax

impact from loss of earnings tax
Minor to moderate, negative, long-term impact from loss

of property tax
Minor to moderate, negative, long-term impact from

loss of earnings tax

impact from loss of property tax

impact from loss of property tax
Cumulative Impacts
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Environmental
Protection Measures
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Minor to moderate, long-term benefit to

onsite land use

surrounding land use
Minor to moderate, long-term benefit to onsite land use.

surrounding land use
Minor to moderate, long-term benefit to surrounding land

use
Minor to moderate, long-term benefit to surrounding

land use
Minor to moderate, long-term benefit from stabilizing

influence in community
Minor to moderate long-term benefit from NGA operations
Minor to moderate, negative, short-term impact from

displacement and relocation of current residents and
businesses
Minor to moderate, negative, short-term impact from

displacement of agricultural leases
Minor to moderate, negative, long-term impact from

displacement of Scott AFB driving range
Minor to moderate, negative short-term impact from

construction
Minor to moderate, negative, and short-term

cumulative impacts to community cohesion from
reduction in farmland
Minor to moderate, negative, and long-term

cumulative impacts potential to community cohesion
due to disruption from multiple ongoing construction
projects
Land Use and Community Cohesion

Direct/Indirect
Benefits
Direct/Indirect
Impacts
Cumulative Impacts
Environmental
Protection Measures
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Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Preparation and approval of a site

development plan
Preparation and approval of a site

development plan
Construction will occur primarily on

weekdays and during normal working hours
Construction will occur primarily on

weekdays and during normal working hours
Minor to moderate, negative, and long-term cumulative

impacts potential to community cohesion due to disruption
from multiple ongoing construction projects
Preparation and approval of a site development plan
Preparation and approval of a site development plan
All acquisitions will be in compliance with Missouri statutes

governing acquisition and relocations
NRCS Form AD-1006 documenting the conversion of

prime farmlands
Construction will occur primarily during weekdays and

working hours
Efforts will be made to not obstruct streets surrounding the

site to the extent practical during construction.
Crosswalks could be installed at intersections with sidewalks

and stop lights
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EXECUTIVESUMMARY
TABLE ES-1
Summary of Impacts
Resource
No Action
Fenton Site
Mehlville Site
St. Louis City Site
Health & Safety

Direct/Indirect
Benefits
Minor to moderate, long-term benefit in

reduction of crime
Minor to moderate, long-term benefit on occupational

health
Minor to moderate, long-term benefit on crime
Minor to moderate, long-term benefit to child safety
Direct/Indirect
Impacts
Not applicable
Minor to moderate, negative, long-term impact on

emergency response time and demand due to 3 minute
increase in response time
Cumulative
Not applicable
No cumulative impacts

impacts to emergency response times
Environmental
Protection Measures
Not applicable
Develop and implement a construction health

and safety plan (HSP) as a best management
practice (BMP)
Develop and implement a construction HSP as

a BMP
Develop and implement a construction HSP as a BMP
Develop and implement a construction HSP as a BMP
NGA personnel will comply with applicable OSHA and

DoD- and NGA-specific safety protocols as a BMP
NGA personnel will comply with applicable

OSHA and DoD- and NGA-specific safety
protocols as a BMP
NGA personnel will comply with applicable OSHA and

DoD- and NGA-specific safety protocols as a BMP
Fencing and signage will be installed around construction site

as a BMP for protection of children
Fencing and signage will be installed around

construction site as a BMP for protection of children
NGA personnel will comply with applicable

Occupational Safety and Health
Administration (OSHA) and U.S. Department
of Defense (DoD)- and NGA-specific safety
protocols as a BMP
Avoid and minimize floodplain impacts as a

BMP, and any infrastructure located within the
floodplain will be designed and constructed in
compliance with all applicable regulatory
requirements pertaining to floodplains

construction site as a BMP for protection of
children
Minor to moderate, negative, and short

term due to construction traffic

construction site as a BMP for protection of
children
NGA will coordinate its site plans with local emergency

responders
Minor to moderate, negative, and long term

to existing year level of service (LOS)
Minor to moderate, negative, and long term to existing

year LOS
Minor to moderate, negative, and long term to

existing year LOS
Minor to moderate, negative, and short

term due to construction traffic
Minor to moderate, negative, and long term to future year

LOS
Minor to moderate, negative, and long term to future

year LOS
Minor to moderate, negative, and short term due to

construction traffic
Minor to moderate, negative, and short term due to

construction traffic
Traffic & Transportation

Direct/Indirect
Impacts
Cumulative Impacts
Minor to moderate, negative, short-term

cumulative impacts to traffic and
transportation from construction activities
Minor to moderate, negative, short-term

cumulative impacts to traffic and
transportation from construction activities
Minor to moderate, negative, short-term cumulative

impacts to traffic and transportation from construction
activities
Minor to moderate, negative, short-term cumulative

impacts to traffic and transportation from construction
activities
Environmental
Protection Measures
Not applicable
Implement a Construction Management Plan
Coordinate with Missouri Department of

Transportation (MoDOT) to install a traffic
signal
NGA to coordinate with the city of St. Louis to install traffic

signal
Coordinate with Illinois Department of Transportation

(IDOT) to create a right turn lane for existing year LOS
NGA will coordinate with St. Clair County to install a

traffic signal
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EXECUTIVESUMMARY
TABLE ES-1
Summary of Impacts
Resource
No Action
Fenton Site
Mehlville Site
St. Louis City Site
Noise
Direct/Indirect
Impacts
Minor to moderate, negative, and shortterm impact from construction noise
Minor to moderate, negative, and shortterm impact from construction noise
Minor to moderate, negative, and short-term impact from

construction noise
Cumulative Impacts
Not applicable
Minor to moderate, negative, and shortterm cumulative impacts for constructionrelated noise
Minor to moderate, negative, and shortterm cumulative impacts for constructionrelated noise
Minor to moderate, negative, and short-term cumulative

impacts for construction-related noise
Environmental
Protection Measures
Not applicable
Construction and operation activities will

comply with the St. Louis Noise Ordinance
Construction and operation activities will

comply with the St. Louis Noise Ordinance
Construction and operation activities will comply with the

St. Louis Noise Ordinance
Not applicable
Hazardous Materials & Solid Waste

Direct/Indirect
Benefits
Minor to major, long-term benefit,

commensurate with the severity of
contamination to be remediated
Minor to moderate, long-term benefit,

commensurate with the severity of
contamination to be remediated
Minor to major, long-term benefit, commensurate with the

severity of contamination to be remediated
Minor to moderate, long-term benefit, commensurate

with the severity of contamination to be remediated
Direct/Indirect
Impacts
Minor to moderate, negative short-term

impact on area landfills from construction and
demolition-related solid waste
Minor to moderate, negative short-term

impact on area landfills from construction and
demolition-related solid waste
Minor to moderate, negative short-term impact on area

landfills from construction and demolition-related solid waste
Cumulative Impacts
Not applicable

cumulative impacts to solid waste disposal

cumulative impact to solid waste disposal

impacts to solid waste disposal
Not applicable
Environmental
Protection Measures
Not applicable
Complete site characterization and removal or

remediation of contamination will be
completed as a mitigation measure prior to
acquisition of the site

remediation of contamination will be
completed as a mitigation measure once
government as acquires the site.
Complete site characterization and removal or remediation of

contamination will be completed as a mitigation measure
prior to acquisition of the site

remediation of contamination will be completed as a
mitigation measure prior to acquisition of the site
VI assessment prior to construction and

implementation of mitigation measures
VI assessment prior to construction and implementation of

mitigation measures
Vapor intrusion (VI) assessment prior to

construction and implementation of mitigation
measures
VI assessment prior to construction and implementation

of mitigation measures
Hazardous materials and wastes will be used, stored, disposed

of, and transported during construction in compliance with all
applicable laws and regulations as BMP
Hazardous materials and wastes will be used,

stored, disposed of, and transported during
construction in compliance with all applicable
laws and regulations as BMP
Spill response plan for accidental spills/releases during

construction activities and operation as BMP
Hazardous materials and wastes will be used, stored,

disposed of, and transported during construction in
compliance with all applicable laws and regulations as
BMP
Creation of a construction management plan, including

hazardous materials protocols
Spill response plan for accidental spills/releases during

construction activities and operation as BMP
Creation of a construction management plan, including

hazardous materials protocols
Secondary containment BMP for diesel storage
When possible, demolition materials, such as soils from

grading, will be used onsite as BMP
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Hazardous materials and wastes will be used,

stored, disposed of, and transported during
construction in compliance with all applicable
laws and regulations as BMP
Spill response plan for accidental

spills/releases during construction activities
and operation as BMP
Creation of a construction management plan,

including hazardous materials protocols
Secondary containment BMP for diesel

storage
When possible, demolition materials, such as

soils from grading, will be used onsite as BMP
Divert a large portion of the debris as BMP

from landfills through reuse and recycling
NGA will continue to implement solid waste

management and waste reduction, including
recycling programs, as BMP
Spill response plan for accidental

spills/releases during construction activities
and operation as BMP
Creation of a construction management plan,
including hazardous materials protocols
Secondary containment BMP for diesel storage
When possible, demolition materials, such as soils from

grading, will be used onsite as BMP
Secondary containment BMP for diesel

storage
When possible, demolition materials, such as

soils from grading, will be used onsite as BMP
Divert a large portion of the debris as BMP from landfills

through reuse and recycling
NGA will continue to implement solid waste management

and waste reduction, including recycling programs, as BMP
Divert a large portion of the debris as BMP from

landfills through reuse and recycling

management and waste reduction, including recycling
programs, as BMP
Divert a large portion of the debris as BMP

from landfills through reuse and recycling

management and waste reduction, including
recycling programs, as BMP
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EXECUTIVESUMMARY
TABLE ES-1
Summary of Impacts
Resource
No Action
Fenton Site
Mehlville Site
St. Louis City Site
Utilities
Direct/Indirect
Impacts
Minor to moderate, negative, and shortterm impacts to power supply and service
Minor to moderate, negative, and shortterm impacts to power supply and service
Minor to moderate, negative, and short-term impacts to

power supply and service

impacts to power supply and service
Minor to moderate, negative, and shortterm impacts to potable water supply and
service
Minor to moderate, negative, and shortterm impacts to potable water supply and
service

potable water supply and service

impacts to potable water supply and service
Minor to moderate, negative, and shortterm impacts to wastewater and stormwater

service

wastewater and stormwater service
Minor to moderate, negative, and shortterm impacts to wastewater and stormwater

service

impacts to wastewater and stormwater service

impacts to natural gas supply and service
Minor to moderate, negative, and shortterm impacts to natural gas supply and
service

natural gas supply and service
Minor to moderate, negative, and shortterm impacts to natural gas supply and
service

communication service

impacts to communication service
Minor to moderate, negative, and shortterm impacts to communication service
Minor to moderate, negative, and shortterm impacts to communication service
Cumulative Impacts
Not applicable
Minor to moderate, negative, and shortterm cumulative impacts because disruptions

of service and outages are not expected
Minor to moderate, negative, and shortterm cumulative impacts because disruptions

of service and outages are not expected

impacts because disruptions of service and outages are not
expected

cumulative impacts because disruptions of service and
outages are not expected
Environmental
Protection Measures
Not applicable
Outages will be avoided as a BMP, to the

extent possible
Outages will be avoided as a BMP, to the

extent possible
Outages will be avoided as a BMP, to the extent possible
Prior to construction, public utilities within

the potential impact area will be positively
located as a BMP
Prior to construction, public utilities within the potential

impact area will be positively located as a BMP
Outages will be avoided as a BMP, to the extent

possible
Prior to construction, public utilities within the

potential impact area will be positively located as a
BMP
NGA will incorporate DoD energy policies

and Leadership in Energy and Environmental
Design (LEED) or Green Globes green
building goals as BMPs
NGA will incorporate DoD energy policies

and LEED or Green Globes green building
goals as BMPs
NGA will incorporate DoD energy policies and LEED

or Green Globes green building goals as BMPs
Major, negative, and long-term impacts to a known

archeological site
Minor to moderate, negative, and long-term impacts

to unidentified archaeological resources from
construction
Major, negative, and long-term cumulative impacts

potential to archeological resources due to the impacts
to known cultural resources within the APE
NGA and USACE will consult with the Illinois SHPO

to determine appropriate mitigation measures
Potential mitigation measures likely to include data

recovery at archaeological Site
Comply with Unintended Discovery Plan as a

mitigation measure if prehistoric- or historic-period
archaeological sites are encountered
Prior to construction, public utilities within

the potential impact area will be positively
located as a BMP
NGA will incorporate DoD energy policies and LEED or

Green Globes green building goals as BMPs
Cultural Resources1
Direct/Indirect
Impacts
Cumulative Impacts
Environmental
Protection Measures
Not applicable

mitigation measure if prehistoric- or historicperiod archaeological sites are encountered

mitigation measure if prehistoric- or historicperiod archaeological sites are encountered
Major, negative, and long-term impacts to known historic

properties as result of demolition of NRHP-listed buildings
or contributing resources to an NRHP-listed historic district
Minor to moderate, negative, and long-term impacts to

unidentified archaeological resources from construction
Major, negative, and long-term cumulative impacts to

historic properties within the Area of Potential Effect (APE)

impacts to potential archeological cultural resources
NGA and USACE will consult with the Missouri State

Historic Preservation Officer (SHPO) to determine the
appropriate mitigation measures
Comply with Unintended Discovery Plan as a mitigation

measure if prehistoric- or historic-period archaeological sites
are encountered
1AllfindingsandimpactdeterminationsaresubjecttochangependingconsultationwithStateHistoricPreservationOfficers(SHPOs).
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EXECUTIVESUMMARY
TABLE ES-1
Summary of Impacts
Resource
No Action
Fenton Site
Mehlville Site
St. Louis City Site
Visual Resources
Direct/Indirect
Benefits
Major, beneficial, and long-term impact by

changing the overall visual quality of the site
from low to high
Major, beneficial, and long-term impact by changing the

overall visual quality of the site from low to high
Cumulative Impacts
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Environmental
Protection Measures
Not applicable
Design landscaping and architecture

commensurate with viewer sensitivity and
campus security as a BMP
Design landscaping and architecture

commensurate with viewer sensitivity and
campus security as a BMP
Design landscaping and architecture commensurate with

viewer sensitivity and campus security as a BMP
Design landscaping and architecture commensurate

with viewer sensitivity and campus security as a BMP
Minor to moderate, negative, and longterm impact to floodplains during

construction
Minor to moderate, negative, and longterm impact to wetlands during construction
Minor to moderate, negative, and long-term impact

to wetlands during construction
Minor to moderate, negative, and longterm impact to surface waters during

construction

to surface waters during construction

cumulative impacts to floodplains

cumulative impacts to wetlands

cumulative impacts to wetlands
Minor to moderate, negative, and shortterm cumulative impacts to surface water
Minor to moderate, negative, and long-term to

surface water
Require a Clean Water Act (CWA) Section

404 (Dredge and Fill) Permit from USACE
and a CWA Section 401 Water Quality
Certification from MoDNR because of
impacts to wetland and surface waters during
construction
Require a CWA Section 404 (Dredge and Fill) Permit

from USACE and a CWA Section 401 Water Quality
Certification from Illinois Environmental Protection
Agency (IEPA) because of impacts to wetland and
surface waters during construction
Mitigation measures requirements will be determined

and implemented during wetlands and surface water
permitting
Appropriate BMPs, such as silt fencing, will be

implemented during construction to avoid and
minimize potential indirect impacts (erosion,
sedimentation, and pollution) to offsite wetlands and
surface waters
Requires a General National Pollutant Discharge

Elimination System (NPDES) Permit for Stormwater
Discharges from Construction Site Activities from
IEPA
Water Resources
Direct/Indirect
Impacts
Cumulative Impacts
Environmental
Protection Measures
ES093014083520ATL
Not applicable
Not applicable
Appropriate BMPs, such as silt fencing, will

be implemented during construction to avoid
and minimize potential indirect impacts
(erosion, sedimentation, and pollution) to
offsite wetlands and surface waters
Obtain a Missouri State Operating Permit

from Missouri Department of Natural
Resources (MoDNR) for proposed project
that would disturb 1 acre or more
Mitigation measures requirements will be

determined and implemented during wetlands
and surface water permitting
Appropriate BMPs, such as silt fencing, will

be implemented during construction to avoid
and minimize potential indirect impacts
(erosion, sedimentation, and pollution) to
offsite wetlands and surface waters
Obtain a Missouri State Operating Permit

from MoDNR for proposed project that
would disturb 1 acre or more
Not applicable
Appropriate BMPs, such as silt fencing, will be implemented

during construction to avoid and minimize potential indirect
impacts (erosion, sedimentation, and pollution) to offsite
wetlands and surface waters
Obtain a Missouri State Operating Permit from MoDNR for

proposed project that would disturb 1 acre or more
ES-13
EXECUTIVESUMMARY
TABLE ES-1
Summary of Impacts
Resource
No Action
Fenton Site
Mehlville Site
St. Louis City Site
Biological Resources
Direct/Indirect
Benefits
Direct/Indirect
Impacts
Minor to moderate, long-term benefit to the

natural environment from management and
removal of noxious weeds in landscaped areas
Not applicable
Not applicable
Minor to moderate, negative, and longterm direct and indirect impacts to native
vegetation
Minor to moderate, negative, and longterm impacts to wildlife during construction

and operation
Minor to moderate, long-term benefit to the natural

environment from management and removal of noxious
weeds in landscaped areas
Minor to moderate, negative, and short-term to migratory

birds during construction activities
Minor to moderate, long-term benefit to the natural

environment from management and removal of
noxious weeds in landscaped areas
Minor to moderate, long-term benefit due to the

reduced likelihood of Bird/Animal Aircraft Strike
Hazard incidents
Minor to moderate, negative, and long-term direct

and indirect impacts to native vegetation due to
mortality and loss of natural habitat during
construction

to wildlife during construction and operation
Minor to moderate, negative, and longterm impact to wildlife habitat

to wildlife habitat
Minor to moderate, negative, and shortterm impacts to federally listed species

potential habitat

impacts to federally listed species potential habitat
Minor to moderate, negative, and shortterm impact to migratory birds during

construction activities

to state-listed species potential habitat
Minor to moderate, negative, and short-term impact

to migratory birds during construction activities
Cumulative Impacts
Not applicable
Not applicable
Minor to moderate, negative, and shortterm cumulative impacts to biological

resources

impacts to biological resources

cumulative impacts to biological resources.
Environmental
Protection Measures
Not applicable
NGA will coordinate with the U.S. Fish and

Wildlife Service (USFWS) regarding the
Migratory Bird Treaty Act (MBTA) to
establish and implement appropriate
mitigation
NGA will coordinate with USFWS under

Section 7 of the Endangered Species Act
(ESA) to determine if mitigation measures are
required and how those measure are to be
implemented
NGA will coordinate with USFWS regarding the MBTA to

establish and implement appropriate mitigation
NGA will coordinate with the FAA and Scott AFB to

ensure that campus design features do not attract birds
or other wildlife to the site
NGA requested USFWS concurrence with its no affect

determination to roosting habitat or hibernacula of
three species of bats under Section 7 of the ESA
NGA will coordinate with USFWS regarding the

MBTA to establish and implement appropriate
mitigation
NGA will coordinate with USFWS regarding

the MBTA to establish and implement
appropriate mitigation
Geological & Paleontological Resources

Direct/Indirect
Impacts
Cumulative Impacts
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
Environmental
Protection Measures
Not applicable
Appropriate BMPs such as silt fencing will be

implemented during construction to minimize
potential soil erosion and sedimentation

implemented during construction to minimize
potential soil erosion and sedimentation
Appropriate BMPs such as silt fencing will be implemented

during construction to minimize potential soil erosion and
sedimentation

implemented during construction to minimize potential
soil erosion and sedimentation
NGA will follow all federal procedures

pertaining to the management of the
discovered resources in accordance with the
Paleontological Resources Preservation Act of
2009 as a BMP
NGA will follow all federal procedures

pertaining to the management of the
discovered resources in accordance with the
Paleontological Resources Preservation Act
of 2009 as a BMP
NGA will follow all federal procedures pertaining to the

management of the discovered resources in accordance with
the Paleontological Resources Preservation Act of 2009 as a
BMP
NGA will follow all federal procedures pertaining to

the management of the discovered resources in
accordance with the Paleontological Resources
Preservation Act of 2009 as a BMP
ES-14
ES093014083520ATL
EXECUTIVESUMMARY
TABLE ES-1
Summary of Impacts
Resource
No Action
Fenton Site
Mehlville Site
St. Louis City Site
Air Quality & Climate Change

Direct/Indirect
Impacts
Cumulative Impacts
Environmental
Protection Measures
Not applicable
Not applicable
Minor to moderate, negative, and

short-term impact to air quality from
construction emissions

short-term impact to air quality from
construction emissions

long-term impact to air quality from
operational emissions

long-term impact to air quality from
operational emissions

long-term impact to air climate change
during operation

long-term impact to air climate change
during operation

short-term cumulative impacts from
construction-related emissions

construction-related emissions

operation-related emissions

operation-related emissions
NGA will implement a Dust Control

Plan to control onsite and offsite
fugitive dust emissions, as prescribed in
the Missouri Code of State Regulations
(CSR)
NGA will implement a Dust Control

Plan to control onsite and offsite
fugitive dust emissions, as prescribed in
the Missouri CSR
NGA will implement a BMP to reduce

onsite and offsite heavy-duty diesel
vehicle emissions by limiting the time
that vehicles can idle to no more than 5
minutes in any 60-minute period
NGA will Implement a BMP to reduce

sulfur dioxide (SO2) emissions into the
atmosphere from industrial boilers, and
thereby, also reducing emissions of fine
particulate matter (PM2.5)
NGA will implement a BMP to reduce

onsite and offsite heavy-duty diesel
vehicle emissions by limiting the time
that vehicles can idle to no more than 5
minutes in any 60-minute period
NGA will Implement a BMP to reduce

SO2 emissions into the atmosphere from
industrial boilers, and thereby, also
reducing emissions of PM2.5
Minor to moderate, negative, and short-term impact to air quality

from construction emissions

impact to air quality from construction emissions
Minor to moderate, negative, and long-term impact to air quality

from operational emissions

to air quality from operational emissions
Minor to moderate, negative, and long-term impact to air climate

change during operation

to air climate change during operation
Minor to moderate, negative, and short-term cumulative impacts

from construction-related emissions
Minor to moderate, negative, and short-term cumulative impacts

from operation-related emissions

cumulative impacts from construction-related
emissions

cumulative impacts from operation-related emissions
NGA will implement Dust Control Plan for

controlling onsite and offsite fugitive dust emissions,
as prescribed in the Illinois Administrative Code
NGA will Implement a BMP to reduce SO2 emissions into the

atmosphere from industrial boilers, and thereby, also reducing
emissions of PM2.5
NGA will implement BMP to reduce onsite and

offsite heavy-duty diesel vehicle emissions by
limiting the time that vehicles can idle to no more
than 5 minutes in any 60-minute period
NGA will implement BMP to limit photochemically

reactive material in architectural coatings to no more
than 20 percent by volume in containers having a
capacity of more than 1 gallon
NGA will implement a Dust Control Plan to control onsite and offsite
fugitive dust emissions, as prescribed in the Missouri CSR
NGA will implement a BMP to reduce onsite and offsite heavy-duty

diesel vehicle emissions by limiting the time that vehicles can idle to
no more than 5 minutes in any 60-minute period
Airspace
Direct/Indirect
Impacts

impacts to current airspace conditions
Cumulative Impacts
Not applicable
Not applicable
Not applicable
Not applicable

impacts to current airspace conditions
Environmental
Protection Measures
Not applicable
NGA will coordinate with the FAA

during the design phase to avoid or
minimize glint and glare through
selection of building materials and
modifying orientation and angles that
could cause glint or glare
NGA will coordinate with the FAA

during the design phase to avoid or
minimize glint and glare through
selection of building materials and
modifying orientation and angles that
could cause glint or glare
NGA will coordinate with the FAA during the design phase to avoid
or minimize glint and glare through selection of building materials
and modifying orientation and angles that could cause glint or glare
NGA will perform an aeronautical feasibility study,

through submittal of FAA Form 7460-1, Notice of
Proposed Construction or Alteration
NGA will coordinate with the FAA during the design

phase to avoid or minimize glint and glare through
selection of building materials and modifying
orientation and angles that could cause glint or glare
ES093014083520ATL
ES-15
EXECUTIVESUMMARY
ES-11 Summary of Findings by Site

Similar environmental impacts exist across the sites. For example, construction impacts such as use of
hazardous materials, noise generation and economic spending would be about the same regardless of the site
chosen. However, disparate impacts also exist between the sites: floodplains would be impacted only at the
Fenton Site, historic properties would be impacted only at the St. Louis City Site, and airspace would be
impacted only at the St. Clair County Site. The impacts associated with each site are briefly summarized in
the following subsections.
ES-11.1 Fenton Site

The land uses surrounding the Fenton Site are largely commercial and industrial, which are compatible with the
Proposed Action. No major negative environmental impacts would be expected from siting, constructing, and
operating the Next NGA West Campus at the Fenton Site.
Minor to moderate benefits may result from health and safety improvements, construction spending, induced
employment, land use improvements, cleanup of existing hazardous contamination, and the reduction of weed
species.
It is anticipated that the following minor to moderate, negative environmental impacts could occur if the Next
NGA West Campus is located at the Fenton Site:
SocioeconomicsChanging to federal ownership at this location would result in a loss of property tax
paid to the city of Fenton (approximately $5,502) and St. Louis County (approximately $462,308).
The city of St. Louis would lose approximately $2.19 million in City Total Earnings Tax through the
loss of tax from NGA non-residents of St. Louis.
Traffic and transportationThe surrounding road network would be affected during construction
periods only. There would likely be no transportation infrastructure failures as a result of the
increased traffic.
NoiseNoise from construction activities would be noticeable, but construction activities would
comply with state and local ordinances.
Hazardous material and solid wasteThis site would generate approximately 1,198,730 cubic yards of
solid waste before re-use or recycling. This amount is approximately 0.56 percent of the total
permitted capacity of the three regional landfills that accept construction and demolition material.
UtilitiesSite development would require upgrades to utility infrastructure and new connections,
including supply and service, potable water supply and services, wastewater and stormwater services,
and communications.
Water resourcesNo water resources or regulated waters would be impacted; however, construction
activities could occur within the 500-year floodplain. Any infrastructure located within the 500-year
ES093014083520ATL
ES-17
EXECUTIVESUMMARY
floodplain would be designed and constructed in compliance with all applicable federal guidelines
and regulatory requirements pertaining to floodplains.
Air quality and climate changeAn increase in National Ambient Air Quality Standards (NAAQS)
criteria pollutant and carbon dioxide equivalents (CO2e) emissions would occur. However, emission
levels would be below regulatory thresholds.
Environmental protection measures, including standard best management practices (BMPs) as defined in
Table ES-1 and summarized at the end of each resource section, would need to be implemented to ensure
environmental impacts are maintained below defined thresholds.
ES-11.2 Mehlville Site

The land uses surrounding the Mehlville Site are largely commercial along Tesson Ferry Road, which is
compatible with the Proposed Action. No major benefits or negative environmental impacts would be expected
from siting, constructing, or operating the Next NGA West Campus at the Mehlville Site. Minor to moderate
benefits may result from construction spending, induced employment, surrounding land use improvements,
and cleanup of any existing contamination.
It is anticipated that minor to moderate, negative environmental impacts could occur to the following
resources:
paid to St. Louis County (approximately $545,495). The city of St. Louis would lose approximately
$2.19 million in City Total Earnings Tax through the loss of tax from NGA non-residents of St.
Louis.
Traffic and transportationThere would be an impact to the roadway network at the entrance to the
Next NGA West Campus, along Tesson Ferry Road. NGA would work with MoDOT to install a
traffic signal to alleviate this concern.
NoiseNoise from construction activities would be noticeable, but construction would comply with
state and local ordinances.
Hazardous material and solid wasteThis site would generate approximately 116,920 cubic yards of
including supply and service, potable water supply and services, wastewater and stormwater services,
and communications.
ES-18
ES093014083520ATL
EXECUTIVESUMMARY
Water resourcesA single, forested wetland, approximately <0.01 acres in size, is located below an
onsite retention pond. Under the Proposed Action, construction activities could displace surface
waterbodies and the small wetland within the site. The maximum amount of surface water
area/disturbance that would be displaced consists of 2,658 linear feet of intermittent stream,
373 linear feet of ephemeral stream, and a 3.5-acre stormwater retention pond. Impacts to the surface
waterbodies that qualify as waters of the United States would require a CWA Section 404 permit
from USACE, St. Louis District and a Section 401 Water Quality Certification from Missouri
Department of Natural Resources.
Biological resourcesSite development would impact present wildlife and vegetation.
Air Quality and Climate ChangeAn increase in NAAQS criteria pollutant and CO2e emissions would
occur. However, emissions levels would be below regulatory thresholds.
Standard BMPs, as defined in Table ES-1 and summarized at the end of each resource section, would need to
be implemented to ensure environmental impacts are maintained below defined thresholds.
ES-11.3 St. Louis City Site

The city of St. Louis intends to redevelop the St. Louis City Site and offered this site as an option to evaluate
for the EIS. The city has since amended the 2009 Redevelopment Master Plan to accommodate the NGA
proposal. Granting opportunities through the U.S. Department of Housing and Urban Development and other
federal initiatives have been advanced, making this project consistent with area future land use plans. There
would be both major impacts and benefits associated with the St. Louis City Site.
Within the footprint of the St. Louis City Site, there are known historic properties listed on the National
Register of Historic Places (NRHP). The construction of the project would require the demolition of the
Buster Brown-Blue Ribbon Shoe Factory and homes within the footprint of the St. Louis Place Historic
District. NGA, USACE, and the city of St. Louis are currently reaching out to the Advisory Council on
Historic Preservation, the Missouri State Historic Preservation Office, and local historic interest groups to
determine the appropriate mitigation for impacts to NRHP-listed resources.
Siting the Next NGA West Campus at the St. Louis City Site could result in major benefits from the change in
visual character at the site. Additional non-major benefits would include health and safety improvements,
construction spending, induced employment, cleanup of existing hazardous contamination, land use
improvements, and the reduction of weed species.
ES093014083520ATL
ES-19
EXECUTIVESUMMARY
Following the analysis performed for the St. Louis City site, it is anticipated that other minor to moderate
negative environmental impacts could occur to the following resources:
paid to the city of St. Louis (approximately $64,180), but the City would retain the City Total
Earnings Tax from NGA personnel.
Land UseThe city of St. Louis is working on agreements with local community members for
property purchases and relocations. All relocations and displacements would occur in compliance
with the Missouri relocation statutes, which require fair compensation for relocated individuals.
Health and safetyRoad realignments could result in a minor impact to emergency response times in
the area.
Traffic and transportationThere would be an impact to the roadway network at the two entrances to
the NGA campus without signals, which are located along Jefferson Avenue and Cass Avenue. NGA
would coordinate with MoDOT to install actuated traffic signals to alleviate this issue.
NoiseNoise during construction would be noticeable to nearby residences and businesses.
Hazardous material and solid wasteThis site would generate approximately 85,650 cubic yards of
BiologyMigratory birds could be affected by the Proposed Action during construction.
including power supply and service, potable water supply and services, wastewater and stormwater
services, and communications.
Air quality and climate changeAn increase in NAAQS criteria pollutant and CO2e emissions would
occur. However, emission levels would be below regulatory thresholds.
ES-11.4 St. Clair County Site

St. Clair County offered the St. Clair County Site as an option to be evaluated for the EIS. To accommodate
the NGA proposal, a county zoning restriction of building heights has been lifted to allow for campus
construction at this location. No major environmental benefits are associated with this site; however, there is a
potential major negative impact.
A previously identified archaeological site listed on the NRHP is located within the footprint of the St. Clair
County Site. Because of the potential impacts to this archeological site, NGA, USACE, and St. Clair County
ES-20
ES093014083520ATL
EXECUTIVESUMMARY
are currently reaching out to the Illinois State Historic Preservation Office and local interest groups to
determine the appropriate mitigation for impacts to this resource.
Minor to moderate benefits may result from the reduction of potential noxious weeds on the site, health and
safety improvements, land use improvements.
Following the analysis performed for the St. Clair County site, it is anticipated that minor to moderate,
negative environmental impacts could occur to the following resources:
SocioeconomicsThe city of St. Louis would lose approximately $2.19 million in City Total Earnings
Tax through the loss of tax from NGA non-residents of St. Louis. There would be no change to the
Countys property tax revenue; the site is already exempt from property taxes because it is
County-owned. However, St. Clair County would no longer receive the income associated with
current agricultural leases.
Traffic and transportationThere would be an impact to the St. Clair County Site roadway network at
the signalized intersection of Route 158 at Wherry Road. NGA would coordinate with IDOT to add
an exclusive right turn lane to westbound Wherry Road to alleviate this issue.
including power supply and service, potable water supply and services, wastewater and stormwater
services, and communications.
Water resourcesA single, forested wetland, approximately 2.1 acres in size, is located in the
southwestern part of the site. Under the Proposed Action, construction activities would most likely
displace the wetland on the site. Other surface waters include a 2,092-linear-foot perennial stream, an
intermittent stream, and a 0.9-acre pond. Impacts to the surface waterbodies that qualify as waters of
the United States from the proposed infrastructure construction would require a CWA Section 404
permit from USACE, St. Louis District and Section 401 Water Quality Certification from IEPA.
Biological resourcesSite development would impact present wildlife and vegetation.
Air quality and climate changeIt is anticipated that an average roundtrip commute would increase
from 26.4 miles to 58.2 miles based on current workforce zip codes. Despite the increase in commute
distance, the annual operational emissions would be less than the federal de minimis thresholds for
criteria pollutants and the 25,000-metric ton reporting threshold for CO2e.
AirspaceBecause of the proximity to Scott AFB, NGA would coordinate with the FAA to perform an
aeronautical study under 14 CFR 77 to determine the potential impacts to flight patterns and operations
within the existing airspace. There should be minimal change to flight patterns if this site is selected.
ES093014083520ATL
ES-21

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Executive Summary

ES-2 Purpose and Need for Action

ES-3 Description of the Proposed Action

be designed to accommodate a workforce of approximately 3,150 government personnel and contractors.

Main operations building

Data center (may be constructed sometime in the future)

Central utility plant

Visitor control center

Remote inspection facility

Primary and secondary access control points

Security fencing around the site perimeter

Supporting infrastructure, such as parking, interior roads, and sidewalks

ES-4 Description of the No Action Alternative

ES-5 Alternatives Carried Forward for Analysis

ES-5.1 Fenton Site

St. Louis City

St. Clair Countyy

ES-5.2 Mehlville Site

ES-5.3 St. Louis City Site

ES-5.4 St. Clair County Site

ES-6 Public Outreach and Involvement

ES-7 Environmental Justice

ES-8 Selection of Preferred Alternative

ES-9 Approach to Environmental Analysis

ES-10 Comparison of Environmental Impacts by Alternative

St. Louis City Site

St. Clair County Site

Only no/negligible impacts

Only no/negligible impacts

Minor to moderate, short-term benefit from

Minor to moderate, short-term benefit from

Minor to moderate, short-term benefit from construction

Minor to moderate, short-term benefit from

Minor to moderate, short-term benefit from

Minor to moderate, short-term benefit from

Minor to moderate, short-term benefit from construction

Minor to moderate, short-term benefit from

Minor to moderate short-term benefit from

Minor to moderate short-term benefit from increased

Minor to moderate short-term benefit from

Minor to moderate short-term benefit from increased

Minor to moderate long-term benefit induced employment

Minor to moderate long-term benefit

Minor to moderate long-term benefit

Minor to moderate long-term benefit induced

Minor to moderate, negative, long-term

Minor to moderate, negative, long-term

Minor to moderate, negative, long-term impact from loss

Minor to moderate, negative, long-term impact from

Minor to moderate, negative, long-term

Minor to moderate, negative, long-term

Minor to moderate, long-term benefit to

Minor to moderate, long-term benefit to

Minor to moderate, long-term benefit to onsite land use.

Minor to moderate, long-term benefit to

Minor to moderate, long-term benefit to surrounding land

Minor to moderate, long-term benefit to surrounding

Minor to moderate, long-term benefit from stabilizing

Minor to moderate long-term benefit from NGA operations

Minor to moderate, negative, short-term impact from

Minor to moderate, negative, short-term impact from

Minor to moderate, negative, long-term impact from

Minor to moderate, negative short-term impact from

Minor to moderate, negative, and short-term