DRAFT

ENVIRONMENTAL ASSESSMENT

for

DEVELOPMENT OF AN ENERGY SECURITY AND RESILIENCE PROJECT

at

NAVAL BASE SAN DIEGO, CALIFORNIA

September 2017
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Naval Base San Diego Environmental Assessment September 2017

Abstract-i

Abstract

Abstract

Designation: Environmental Assessment

Title of Proposed Action: Development of an Energy Security and Resilience Project

Project Location: Naval Base San Diego

Lead Agency for the EA: Department of the Navy

Cooperating Agency: None

Affected Region: San Diego, California

Action Proponent: Naval Base San Diego

Point of Contact: Rebecca Loomis

Senior Environmental Planner/Project Manager

Naval Facilities Engineering command Southwest

2730 McKean Street, Building 291

Naval Base San Diego, CA 92136

Email address: rebecca.l.loomis@navy.mil

Date: September 2017

The U.S. Department of the Navy (hereinafter referred to as the Navy) has prepared this Environmental 

Assessment in accordance with the National Environmental Policy Act, as implemented by the Council 

on Environmental Quality Regulations and Navy regulations for implementing the National 

Environmental Policy Act. As part of the Proposed Action, the Navy would enter into an agreement with 

an energy provider (private partner) to construct, operate and maintain energy asset(s) to enhance 

energy security and resilience at Naval Base San Diego with a contract duration of up to 37 years, with 

35 years of system(s) service, approximately one year for construction and approximately one year for 

decommissioning. The agreement would ensure in-kind consideration for the use of Navy lands where 

such energy assets would be located, as well as help the Navy diversify its energy portfolio and supply 

safe, reliable, and affordable power at Naval Base San Diego during grid outages. This Environmental 

Assessment evaluates the potential environmental impacts associated with the four action alternatives

and the No Action Alternative to the following resource areas: air quality, visual resources, noise, 

infrastructure, transportation and public health and safety. 
Naval Base San Diego Environmental Assessment September 2017

Abstract-ii

Abstract

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Naval Base San Diego Environmental Assessment September 2017

ES-1

Executive Summary

EXECUTIVE SUMMARY

ES.1 Proposed Action

The Proposed Action would include the construction and operation of an energy security and resilience 

project that may include a natural gas peaker plant, installation of grid-integrated battery storage or 

other energy assets at Naval Base San Diego (NBSD) in San Diego and National City, California. The Navy 

would enter into an agreement with a private partner to construct, operate and maintain energy 

asset(s) at NBSD with a contract duration of up to 37 years, with 35 years of system(s) service and 

approximately one year for construction and one year for decommissioning. The agreement would 

ensure fair compensation for the use of Navy lands where the proposed activities related to energy 

security/resilience and/or renewability would take place. The U.S. Department of the Navy (Navy) is the 

lead agency for the Proposed Action.

ES.2 Purpose of and Need for the Proposed Action

The purpose of the Proposed Action is to increase Navy installation energy security, operational 

capability, strategic flexibility, and resource availability through the development of energy generating 

systems that would support secure resilient and/or renewable energy.

The need for the Proposed Action is to:

• Ensure security and energy resilience at NBSD by providing an enhanced back-up power supply 

distribution system, to ensure sufficient power is available to support key functions;

• Ensure sufficient power is available to support key installation missions/facilities in a power 

outage or emergency situations affecting power supply and distribution; and 

• Meet the energy security and energy reliability standards put forth by the Energy Policy of 2005, 

and SECNAV's goals and priorities for national energy resilience.

ES.3 Alternatives Considered

Alternatives were developed for analysis based upon the following reasonable alternative screening 

factors: consistency with current land use as identified in the Installation Master Plan; proximity to 

distribution substation, building switchgear, or distribution lines; avoidance of interference with NBSD 

mission and avoidance of creation of unsafe conditions; providing electricity at or below the current cost 

of traditional power; and, providing energy security and resilience regarding power distribution and inkind consideration. The Navy is considering four action alternatives that meet the purpose of and need 

for the Proposed Action and a No Action Alternative. Alternative 1 would result in the conversion of an

existing 40-MW cogeneration plant to a natural gas peaker plant on Site 1. Alternative 2 would result in 

the construction and operation of a natural gas peaker plant on Site 2. Alternative 3 would result in the 

construction and operation of a large integrated battery facility with photovoltaic systems on Site 2. 

Alternative 4 would result in the full-time operation of the existing 40-MW plant cogeneration power 

plant on Site 1 with some minor re-tooling, but no major upgrades would occur to the existing facility. 

The No Action Alternative would allow the lease to expire for the existing 40-MW steam cogeneration 

plant, which would involve decommissioning and removal by the operator/owner.
Naval Base San Diego Environmental Assessment September 2017

ES-2

Executive Summary

ES.4 Summary of Environmental Resources Evaluated in the EA

Council on Environmental Quality regulations, the National Environmental Policy Act, and Navy 

instructions for implementing the National Environmental Policy Act specify that an Environmental 

Assessment (EA) should address those resource areas potentially subject to more than negligible 

impacts. In addition, the level of analysis should be commensurate with the anticipated level of 

environmental impact. 

The following resource areas have been addressed in this EA: air quality, visual resources, noise, 

infrastructure, transportation, and public health and safety. Because potential impacts were considered 

to be negligible or nonexistent, the following resources have not be analyzed in detail in this EA: coastal 

resources, geological resources, water resources, cultural resources, biological resources, land use, 

socioeconomics, and environmental justice.

ES.5 Summary of Potential Environmental Consequences of the Action Alternatives and 

Major Mitigating Actions

Table ES-1 provides a tabular summary of the potential impacts to the resources associated with each of 

the alternative actions analyzed.

ES.6 Public Involvement

The Navy circulated the Draft EA for public review from October 2, 2017 to October 31, 2017.
Naval Base San Diego Environmental Assessment September 2017

ES-3

Executive Summary

Table ES-1

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Operation of 

Existing 

Cogeneration Plant 

on Site 1

Air Quality Under the No Action 

Alternative, the 

Proposed Action would 

not occur and there 

would be no near-term 

change to baseline air 

quality. Demolition of 

the existing plant was 

addressed under the 

previous 

environmental 

documentation.

Alternative 1 would result 

in emissions of air 

pollutants during both 

construction and 

operations. Emissions 

would be below de 

minimis levels. Therefore, 

implementation of 

Alternative 1 would not 

result in an adverse effect 

related to air quality. 

Alternative 2 would result 

in emissions of air 

pollutants during both 

construction and 

operations essentially 

identical to those 

estimated for Alternative 

1. Emissions would be 

below de minimis levels. 

Therefore, implementation 

of Alternative 2 would not 

result in an adverse effect 

related to air quality. 

Alternative 3 would result 

in emissions of air 

pollutants comparable to 

the construction-related 

emissions estimated for 

Alternative 1. The 

photovoltaic system would 

replace the natural gas 

turbine, thereby 

eliminating the primary 

source of operationsphase emissions described 

under Alternative 1. 

Conversely, the energy 

generated by the 

proposed photovoltaic 

system would replace the 

energy consumption 

provided by burning of 

fossil fuels, thereby 

resulting in an indirect 

reduction of GHG 

emissions.

Alternative 4 would 

result in emissions of 

air pollutants during 

operations only, but 

in amounts 

considerably greater 

than for Alternative 

1. Decommissioning

and construction 

would not occur 

under this 

Alternative, which 

would result in some 

decrease in 

construction 

equipment and 

ultimately, to air 

emissions. Therefore, 

implementation of 

this action 

alternative would not 

result in significant 

impacts to air quality.

Visual 

Resources

No significant impacts 

associated with visual 

resources would occur.

Implementation of 

Alternative 1 would 

require the use of 

construction equipment, 

construction traffic, and 

stockpiled materials; 

Implementation of 

Alternative 2 would 

require the use of 

construction equipment, 

construction traffic, and 

Implementation of 

Alternative 3 would 

require the use of 

construction equipment, 

construction traffic, and 

Under Alternative 4, 

no new structures 

would be introduced 

in the area and the 

existing 
Naval Base San Diego Environmental Assessment September 2017

ES-4

Executive Summary

Table ES-1

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Operation of 

Existing 

Cogeneration Plant 

on Site 1

Visual

Resources 

(cont.)

however, due to the 

distance of the site from 

any surrounding areas 

outside of NBSD, as well as 

intervening development 

and landscaping, visual 

impacts are anticipated to 

be less than significant 

during construction. 

Alternative 1 would not 

result in a noticeable 

change to existing 

conditions on-Base from 

any of the landscape units. 

No significant impacts

associated with visual 

resources would occur.

stockpiled materials; 

however, due to the 

distance of the site from 

any surrounding areas 

outside of NBSD, as well as 

intervening development 

and landscaping, visual 

impacts are anticipated to 

be less than significant 

during construction. 

Alternative 2 would not 

result in a noticeable 

change to existing 

conditions on-Base from 

any of the landscape units. 

No significant impacts 

associated with visual 

resource would occur.

stockpiled materials; 

however, due to the 

distance of the site from 

any surrounding areas 

outside of NBSD, as well as 

intervening development 

and landscaping, visual 

impacts are anticipated to 

be less than significant 

during construction. 

Alternative 3 would not 

result in a noticeable 

change to existing 

conditions on-Base from 

any of the landscape units. 

No significant impacts 

associated with visual 

resources would occur.

infrastructure would 

remain beyond the 

existing lease and no 

significant impacts 

associated with 

visual resources 

would occur.
Naval Base San Diego Environmental Assessment September 2017

ES-5

Executive Summary

Table ES-1

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Operation of 

Existing 

Cogeneration Plant 

on Site 1

Noise There would be no 

substantial change to 

baseline noise levels, 

although there would 

be some noise 

associated with the 

decommissioning of 

the existing steam 

plant. Therefore, no 

significant impacts due 

to the noise 

environment would 

occur 

Construction and 

operation of the 

Alternative 1 would result 

in periodic and temporary 

generation of noise 

associated with 

construction equipment 

and operation of the 

peaker plant equipment; 

however, no significant 

noise impacts would 

occur.

Construction and 

operation of the 

Alternative 2 would result 

in periodic and temporary 

generation of noise 

associated with 

construction equipment 

and operation of the 

peaker plant equipment; 

however, no significant 

noise impacts would 

occur.

Construction and 

operation of Alternative 3 

would generate low levels 

of construction noise, as 

installation of the 

integrated batteries and 

small photovoltaic system 

would not involve the use

of heavy-duty equipment. 

Operation would largely 

involve passive operation, 

without the use of 

motorized or other noisegenerating equipment. 

Noise impacts would not 

be significant.

There would be no 

construction 

associated with 

Alternative 4 and no 

decommissioning of 

the existing 

cogeneration plant. 

No significant 

increases in short- or 

long-term noise are 

anticipated.

Infrastructure The existing water, 

wastewater, and solid 

waste services would 

remain unchanged. 

Therefore, no impacts 

are anticipated 

Existing water, 

wastewater, solid waste, 

and energy services would 

remain unchanged under 

Alternative 1; therefore, 

there would be no 

significant impacts to 

these services and 

utilities. In addition, with 

the expansion of energy 

produced on the Base, 

implementation of 

Alternative 1 would have a 

positive impact, and 

Existing water, 

wastewater, solid waste, 

and energy services would 

remain unchanged under 

Alternative 2; therefore, 

there would be no 

significant impacts to 

these services and 

utilities. In addition, with 

the expansion of energy 

produced on the Base, 

implementation of 

Alternative 2 would have a 

positive impact, and 

Existing water, 

wastewater, solid waste, 

and energy services would 

remain unchanged under 

the Alternative 3; 

therefore, there would be 

no significant impacts to 

these services and 

utilities. In addition, with 

the expansion of energy 

produced on the Base, 

implementation of 

Alternative 3 would have a 

positive impact, and 

The existing water, 

wastewater, and 

solid waste services 

would remain 

unchanged. 

Therefore, no 

impacts are 

anticipated.
Naval Base San Diego Environmental Assessment September 2017

ES-6

Executive Summary

Table ES-1

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Operation of 

Existing 

Cogeneration Plant 

on Site 1

Infrastructure 

(cont.)

electricity distribution 

would experience no 

significant impact. No 

significant impacts would 

occur to infrastructure.

electricity distribution 

would experience no 

significant impact. No 

significant impacts would 

occur to infrastructure.

electricity distribution 

would experience no 

significant impact. No 

significant impacts would 

occur to infrastructure.

Transportation No new construction 

would occur; however, 

a small amount of 

truck traffic associated 

with the 

decommissioning of 

the existing steam 

plant would be 

assigned to the 

network. Therefore, no 

significant impacts 

would occur.

The addition of up to 50 

trips per day on a 

temporary basis during 

construction would not 

result in a significant 

impact on any of the 

surrounding roadways 

during construction. To 

minimize potential 

temporary construction 

and demolition traffic 

impacts, a separate Traffic 

Control Plan would be 

prepared by the private 

partner's construction 

contractor and approved 

by the Navy prior to the 

beginning of trucking 

activities. No significant 

impacts would occur to 

transportation.

The addition of up to 50 

trips per day on a 

temporary basis during 

construction would not 

result in a significant 

impact on any of the 

surrounding roadways 

during construction. To 

minimize potential 

temporary construction 

and demolition traffic 

impacts, a separate Traffic 

Control Plan would be 

prepared by the private 

partner's construction 

contractor and approved 

by the Navy prior to the 

beginning of trucking 

activities. No significant 

impacts would occur to 

transportation.

The addition of up to 50 

trips per day on a 

temporary basis during 

construction would not 

result in a significant 

impact on any of the 

surrounding roadways 

during construction. To 

minimize potential 

temporary construction 

and demolition traffic 

impacts, a separate Traffic 

Control Plan would be 

prepared by the private 

partner's construction 

contractor and approved 

by the Navy prior to the 

beginning of trucking 

activities. No significant 

impacts would occur to 

transportation.

No new construction 

would occur; 

however, operations 

would continue 

beyond the current 

lease and periodic 

trips associated with 

ongoing maintenance 

would continue. No 

significant impacts 

would occur to 

transportation.
Naval Base San Diego Environmental Assessment September 2017

ES-7

Executive Summary

Table ES-1

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Operation of 

Existing 

Cogeneration Plant 

on Site 1

Public Health 

and Safety

The Proposed Action 

would not occur and 

there would be no 

change to public health 

and safety, including 

hazardous materials 

and hazardous wastes. 

The existing 40-MW 

cogeneration plant 

would be 

decommissioned 

under the No Action 

Alternative, and public 

health and safety 

issues have been 

addressed in a 

separate NEPA 

Categorical 

Alternative 1 would result 

in the temporary increase 

of the use of hazardous 

wastes related to 

conversion and 

construction activities and 

would involve debris that 

would be removed and 

disposed of in compliance 

with the Navy's 

Sustainability and 

Environmental 

Management Policy 

Statement and 

sustainability goals. 

Ongoing use of other 

hazardous materials would 

occur with operations;

however, contractors 

would be 

Similar to Alternative 1, a 

temporary increase in the 

use of hazardous 

materials would occur 

related to construction of 

a natural gas peaker plant 

on Site 2. However, 

because Site 2 consists of 

paved areas with no 

structures, construction 

would create a minimal 

amount of construction 

debris that would be 

removed and disposed of 

in compliance with the 

Navy's Sustainability and 

Environmental 

Management Policy 

Statement and 

sustainability goals. 

During construction, 

safety measures related to 

the overlap of Site 2 with 

IPR Site 4 would be 

addressed in the Health 

and Safety Plan to 

minimize worker exposure 

and risks associated with 

potential soil 

contamination. The Health 

and Safety Plan, along 

with the Hazardous Waste 

Management Plan, would 

be implemented to 

address risks to 

construction workers and 

surrounding sensitive 

receptors during 

operations, including 

children at the CDC 

facility. 

No new construction 

would occur; 

however, operations 

would continue 

beyond the current 

lease and ongoing 

use of other 

hazardous materials 

would occur with 

operations, however, 

contractors would be 

required to properly 

store, transport, and 

dispose of their 

hazardous waste, 

and therefore, would 

pose minimal risk to 

the human 

environment. 

Therefore, there 
Naval Base San Diego Environmental Assessment September 2017

ES-8

Executive Summary

Table ES-1

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Operation of 

Existing 

Cogeneration Plant 

on Site 1

Public Health 

and Safety 

(cont.)

Exclusion for the 

existing plant and were 

considered not 

significant based on 

the protective 

measures outlined in 

Categorical Exclusion. 

Therefore, no 

significant impacts 

would occur.

required to properly store, 

transport, and dispose of 

their hazardous waste, and 

therefore, would pose 

minimal risk to the human 

environment. Therefore, 

there would be no 

significant public health 

and safety impacts.

Ongoing use of other 

hazardous materials 

would occur with 

operations; however, 

contractors would be 

required to properly store, 

transport, and dispose of 

their hazardous waste, 

and therefore, would pose 

minimal risk to the human 

environment. Therefore, 

there would be no 

significant public health 

and safety impacts.

As a result, impacts 

related to hazards and 

public health and safety 

would not be significant.

would be no 

significant public 

health and safety 

impacts.
Naval Base San Diego Environmental Assessment September 2017

i

Table of Contents

Environmental Assessment

Naval Base San Diego, San Diego California

TABLE OF CONTENTS

ABBREVIATIONS AND ACRONYMS ....................................................................................................... v

EXECUTIVE SUMMARY .................................................................................................................... ES-1

ES.1 Proposed Action............................................................................................................. ES-1

ES.2 Purpose of and Need for the Proposed Action.............................................................. ES-1

ES.3 Alternatives Considered................................................................................................. ES-1

ES.4 Summary of Environmental Resources Evaluated in the EA ......................................... ES-2

ES.5 Summary of Potential Environmental Consequences of the Action Alternatives 

and Major Mitigating Actions........................................................................................ ES-2

ES.6 Public Involvement ........................................................................................................ ES-2

1 PURPOSE OF AND NEED FOR THE PROPOSED ACTION........................................................... 1-1

1.1 Introduction ..................................................................................................................... 1-1

1.2 Background ...................................................................................................................... 1-1

1.3 Location............................................................................................................................ 1-2

1.4 Purpose of and Need for the Proposed Action................................................................1-2

1.5 Scope of Environmental Analysis..................................................................................... 1-2

1.6 Key Documents................................................................................................................ 1-4

1.7 Relevant Laws and Regulations ....................................................................................... 1-4

1.8 Public and Agency Participation and Intergovernmental Coordination..........................1-5

2 PROPOSED ACTION AND ALTERNATIVES ............................................................................... 2-1

2.1 Proposed Action............................................................................................................... 2-1

2.2 Screening Factors............................................................................................................. 2-1

2.3 Alternatives Carried Forward for Analysis.......................................................................2-3

2.3.1 No Action Alternative........................................................................................ 2-3

2.3.2 Alternative 1 – Convert Existing 40-MW Cogeneration Plant on Site 1............2-3

2.3.3 Alternative 2 – Natural Gas Peaker Plant on Site 2...........................................2-4

2.3.4 Alternative 3 – Large Integrated Batteries with Photovoltaic System 

on Site 2............................................................................................................. 2-5

2.3.5 Alternative 4 – Full Time Operation of Existing 40-MW Cogeneration 

Plant on Site 1 ................................................................................................... 2-5

2.4 Alternatives Considered but not Carried Forward for Detailed Analysis ........................2-5

2.4.1 Large Integrated Batteries on Site 1 .................................................................2-6

2.4.2 Photovoltaic at Sites 1 and/or 2........................................................................2-6
Naval Base San Diego Environmental Assessment September 2017

ii

Table of Contents

2.5 Best Management Practices Included in Proposed Action..............................................2-6

3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ..................................... 3-1

3.1 Air Quality ........................................................................................................................ 3-3

3.1.1 Regulatory Setting............................................................................................. 3-3

3.1.2 Affected Environment.....................................................................................3-12

3.1.3 Environmental Consequences.........................................................................3-12

3.2 Visual Resources............................................................................................................ 3-16

3.2.1 Regulatory Setting...........................................................................................3-16

3.2.2 Affected Environment.....................................................................................3-19

3.2.3 Environmental Consequences.........................................................................3-22

3.3 Noise .............................................................................................................................. 3-26

3.3.1 Basics of Sound and A-Weighted Sound Level................................................3-27

3.3.2 Noise Metrics .................................................................................................. 3-28

3.3.3 Noise Effects.................................................................................................... 3-30

3.3.4 Nonauditory Health Effects.............................................................................3-31

3.3.5 Noise Modeling ............................................................................................... 3-32

3.3.6 Regulatory Setting...........................................................................................3-33

3.3.7 Affected Environment.....................................................................................3-35

3.3.8 Environmental Consequences.........................................................................3-36

3.4 Infrastructure................................................................................................................. 3-42

3.4.1 Regulatory Setting...........................................................................................3-42

3.4.2 Affected Environment.....................................................................................3-43

3.4.3 Environmental Consequences.........................................................................3-45

3.5 Transportation ............................................................................................................... 3-46

3.5.1 Regulatory Setting...........................................................................................3-46

3.5.2 Affected Environment.....................................................................................3-46

3.5.3 Environmental Consequences.........................................................................3-47

3.6 Public Health and Safety ................................................................................................ 3-49

3.6.1 Regulatory Setting...........................................................................................3-49

3.6.2 Affected Environment.....................................................................................3-50

3.6.3 Environmental Consequences.........................................................................3-54

3.7 Summary of Potential Impacts to Resources and Impact Avoidance and 

Minimization.................................................................................................................. 3-56

4 CUMULATIVE IMPACTS......................................................................................................... 4-1

4.1 Definition of Cumulative Impacts.................................................................................... 4-1

4.2 Scope of Cumulative Impacts Analysis.............................................................................4-2
Naval Base San Diego Environmental Assessment September 2017

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Table of Contents

4.3 Past, Present, and Reasonably Foreseeable Actions.......................................................4-2

4.3.1 Past Actions....................................................................................................... 4-3

4.3.2 Present and Reasonably Foreseeable Actions ..................................................4-3

4.4 Cumulative Impact Analysis............................................................................................. 4-4

4.4.1 Air Quality ......................................................................................................... 4-4

4.4.2 Visual Resources................................................................................................ 4-5

4.4.3 Noise.................................................................................................................. 4-6

4.4.4 Infrastructure .................................................................................................... 4-7

4.4.5 Transportation................................................................................................... 4-7

4.4.6 Public Health and Safety ................................................................................... 4-8

5 OTHER CONSIDERATIONS REQUIRED BY NEPA...................................................................... 5-1

5.1 Consistency with Other Federal, State, and Local Laws, Plans, Policies, and 

Regulations ...................................................................................................................... 5-1

5.2 Relationship between Short-Term Use of the Environment and Long-Term 

Productivity...................................................................................................................... 5-2

6 REFERENCES .........................................................................................................................6-1

7 LIST OF PREPARERS............................................................................................................... 7-1

List of Figures

Figure 1-1 Location Map ......................................................................................................................1-3

Figure 2-1 Site Locations for Energy Security and Resilience Facility ..................................................2-2

Figure 3-1 Vehicular Routes for Focal Points at NBSD .......................................................................3-18

Figure 3-2 A-Weighted Sound Levels from Typical Sources...............................................................3-29

Figure 3-3 IRP Sites.............................................................................................................................3-52
Naval Base San Diego Environmental Assessment September 2017

iv

Table of Contents

List of Tables

Table ES-1 Summary of Potential Impacts to Resource Areas............................................................ ES-3

Table 2-1 Best Management Practices ...............................................................................................2-7

Table 3-1 Ambient Air Quality Standards ...........................................................................................3-6

Table 3-2 San Diego Air Basin Attainment Status...............................................................................3-7

Table 3-3 General Conformity de minimis Levels...............................................................................3-8

Table 3-4 San Diego County Air Emissions Inventory (2011)............................................................3-12

Table 3-5 Estimated Emissions (tons per year) at NBSD and Comparison to General 

Conformity Under No Action Alternative..........................................................................3-13

Table 3-6 Estimated Emissions (tons per year) at NBSD and Comparison to General 

Conformity Under Alternative 1........................................................................................3-14

Table 3-7 Subjective Responses to Changes in A-Weighted Decibels ..............................................3-27

Table 3-8 Representative Sound Level Data for Peaker Plant ..........................................................3-33

Table 3-9 City of San Diego Exterior Noise Limits.............................................................................3-34

Table 3-10 City of National City Exterior Noise Limits ........................................................................3-35

Table 3-11 Noise-Sensitive Receptor Distances from Alternative Site Locations...............................3-36

Table 3-12 Construction Equipment Noise Levels..............................................................................3-37

Table 3-13 Construction Equipment Noise Levels for Alternative 1...................................................3-38

Table 3-14 Estimated Peaker Plant Noise Levels for Alternative 1.....................................................3-39

Table 3-15 Construction Equipment Noise Levels for Alternative 2...................................................3-40

Table 3-16 Estimated Peaker Plant Noise Levels for Alternative 2.....................................................3-41

Table 3-17 Summary of Potential Impacts to Resource Areas............................................................3-57

Table 4-1 Cumulative Action Evaluation.............................................................................................4-2

Table 5-1 Principal Federal and State Laws Applicable to the Proposed Action ................................5-1

Appendices

Appendix A Record of Non-Applicability

Appendix B Potential to Emit and Permitting Implications for the Development of an Energy Security 

and Resilience Project at Naval Base San Diego

Appendix C Air Quality Methodology and Calculations

Appendix D Noise Calculations
Naval Base San Diego Environmental Assessment September 2017

v

Abbreviations and Acronyms

Abbreviations and Acronyms

Acronym Definition

ACM asbestos-containing material

AICUZ Air Installation Compatible 

Use Zone

AE LLC Applied Energy, LLC

APZ Accident Potential Zone

AQCR Air Quality Control Region

ATFP Antiterrorism Force 

Protection

BMP best management practice

CAA Clean Air Act

CDC Child Development Center

CEQ Council on Environmental 

Quality

CFR Code of Federal Regulations

CNEL Community Noise Equivalent 

Level

CO carbon monoxide

CO2 carbon dioxide

CO2e carbon dioxide equivalent

SDAPCD County of San Diego Air 

Pollution Control District

CZMA Coastal Zone Management 

Act

dB decibel

dBA A-weighted sound level

DERP Defense Environmental 

Restoration Program

DNL day-night average sound 

level

DoD United States Department of 

Defense

DON United States Department of 

the Navy

EA Environmental Assessment

EIS Environmental Impact 

Statement

EO Executive Order

FAR Federal Aviation Regulations

FHWA Federal Highway 

Administration

Acronym Definition

GHG greenhouse gas

HAPs hazardous air pollutants

Hz Hertz

IAP Installation Appearance Plan

IRP Installation Restoration 

Program

km kilometer

LBP Lead-based paint

LCS Littoral Combat Ship

LEQ Equivalent Noise Level

MLLW mean low level water

MW megawatt

NAAQS National Ambient Air Quality 

Standards

NBSD Naval Base San Diego

NEPA National Environmental 

Policy Act

NIOSH National Institute for 

Occupational Safety and 

Health

NIPTS Noise Induced Permanent 

Threshold Shift

NO2 nitrogen dioxide

NOX nitrogen oxide

NPDES National Pollutant Discharge 

Elimination System

NRSW Navy Region Southwest

NSR new source review

OPNAV Office of the Chief of Naval 

Operations

OPNAVINST Office of the Chief of Naval 

Operations Instruction

OSHA Occupational Safety and 

Health Administration

Pb lead

PCB polychlorinated biphenyl

PM10 particulate matter less than 

or equal to 10 microns in 

diameter
Naval Base San Diego Environmental Assessment September 2017

vi

Abbreviations and Acronyms

Acronym Definition

PM2.5 particulate matter less than 

or equal to 2.5 microns in 

diameter

PSD Prevention of Significant 

Deterioration

RCNM Roadway Construction Noise 

Model

RCRA Resource Conservation and 

Recovery Act

REPO Resilient Energy Program 

Office

ROI Region of Influence

SCR Selective Catalytic Reduction

SECNAV Secretary of the Navy

SDG&E San Diego Gas & Electric

SIP State Implementation Plan

SO2 sulfur dioxide

SR State Route

SWMU Solid Waste Management 

Unit

Acronym Definition

SWPPP Storm Water Pollution 

Prevention Plan

tpy tons per year

TSCA Toxic Substances Control Act

U.S.C. United States Code

USEPA U.S. Environmental 

Protection Agency

VOC volatile organic compound

μg/m3 microgram per cubic meter
Naval Base San Diego Environmental Assessment September 2017

1-1

Purpose of and Need for the Proposed Action

1 Purpose of and Need for the Proposed Action

1.1 Introduction

The United States Department of the Navy (hereinafter, referred to as the Navy or DON) would enter 

into agreement with an energy provider (private partner) to construct, operate and maintain energy 

asset(s) to enhance energy security and resilience at Naval Base San Diego (NBSD) with a contract 

duration of up to 37 years, with 35 years of system(s) service, approximately one year for construction 

and approximately one year for decommissioning. The agreement would ensure in-kind consideration 

for the use of Navy lands where such energy assets would be located, as well as help the Navy diversify 

its energy portfolio and supply safe, reliable, and affordable power at NBSD during grid outages. 

The Navy has prepared this Environmental Assessment (EA) in accordance with the National 

Environmental Policy Act (NEPA), as implemented by the Council on Environmental Quality Regulations 

and Navy regulations for implementing NEPA.

1.2 Background

To meet the energy security and energy reliability standards put forth by the Energy Policy Act of 2005, 

and the Secretary of the Navy’s (SECNAV) goals and priorities for national energy resilience, the 

Assistant SECNAV (Energy, Installations & Environment) has established a Resilient Energy Program 

Office (REPO) to help meet the SECNAV goals. The REPO and NBSD are proposing to implement a 

Model 2 out-grant, which provides on-Base generation and/or energy storage for off-Base consumption 

using the public utility grid, while enabling the Navy to receive direct energy benefits.

Under a Model 2 acquisition strategy, the Navy and a private partner would enter into a lease 

agreement (or other real estate outgrant) to allow the private partner to use Navy land to construct, 

operate, maintain and own the resilient energy system. The private partner would sell the generated 

power to customers outside of the Navy. The approximate contract duration would be 37 years, with 

35 years of operations, approximately one year for construction, and one year for decommissioning 

returning the land to pre-construction condition. The acquisition strategy maximizes the total capacity 

(size) of the system based on available land and is not limited by NBSD’s electrical load.

In support of the SECNAV energy goals, the Navy would use the real estate action in accordance with 

10 United States Code (U.S.C.) §2667 to ensure fair compensation for the use of Navy lands. The lease 

terms would enable the Navy to enhance NBSD’s capability and energy security by providing for the 

following:

• Legal access to power during regional grid outage

• No capital cost to the Navy to install the specified on-site energy source that would support 

secure/resilient and/or renewable energy

• No fees to access the power during emergency conditions (standard rates apply)

• A foundation to develop an on-base micro-grid

In keeping with the authority of U.S.C. §2667, outgrants under Model 2 shall provide for consideration 

(rent) to be paid in cash or in-kind, in an amount not less than fair market value of the lease. Potential 

projects provided by the private partner to apply towards rents as in-kind consideration would meet 

necessary environmental regulations and requirements under separate reporting.
Naval Base San Diego Environmental Assessment September 2017

1-2

Purpose of and Need for the Proposed Action

NBSD currently has an approximately 40-megawatt (MW) cogeneration plant on one of the sites that is 

being considered for the Proposed Action. The plant is owned and operated by Applied Energy, LLC 

(AE LLC) and their 30-year contract with the Navy expires in 2018. In 2013, a Categorical Exclusion from 

NEPA was prepared with respect to the proposed removal and demolition of the centralized steam plant 

and replacement with a decentralized steam distribution system. The associated decentralized steam 

project would support the steam requirements at the Base.

1.3 Location

NBSD is situated approximately five kilometers (km) (three miles) to the southeast of the City of San 

Diego’s Central Business District and 16 km (10 miles) to the north of the U.S./Mexico border on the 

eastern edge of San Diego Bay (Figure 1-1). East Harbor Drive divides NBSD into two main parts: the 

mainly industrial bay front area to the west of East Harbor Drive and the community support complex to 

the east of East Harbor Drive. There are approximately 395.4 hectares (977 acres) of land and 

131.9 hectares (326 acres) of water that extend to the U.S. pier headline in San Diego Bay.

1.4 Purpose of and Need for the Proposed Action

The purpose of the Proposed Action is to increase Navy installation energy security, operational 

capability, strategic flexibility, and resource availability through the development of energy generating 

systems that would support secure resilient and/or renewable energy.

The need for the Proposed Action is to:

• Ensure security and energy resilience at NBSD by providing an enhanced back-up power supply 

distribution system, to ensure sufficient power is available to support key functions;

• Ensure sufficient power is available to support key installation missions/facilities in a power 

outage or emergency situations affecting power supply and distribution; and 

• Meet the energy security and energy reliability standards put forth by the Energy Policy of 2005, 

and SECNAV’s goals and priorities for national energy resilience.

1.5 Scope of Environmental Analysis

This EA includes an analysis of potential environmental impacts associated with the four action 

alternatives and the No Action Alternative. The environmental resource areas analyzed in this EA 

include: air quality/climate change, visual resources, noise, transportation, public health and safety, and

infrastructure. 

Eight additional resource areas were considered, but were not carried forward for detailed analysis in 

this EA because there would be no impacts (or only negligible impacts) on these resources from 

implementation of the alternatives. The introduction to Chapter 3 contains brief descriptions of these 

resource areas, their relationship to the action alternatives, and the basis for eliminating them from 

detailed analysis.
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Figure 1-1

NAVAL BASE SAN DIEGO

Location Map

Naval Base San Diego (NBSD) Boundary

Major Road

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National

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Naval Base San Diego Environmental Assessment September 2017

1-4

Purpose of and Need for the Proposed Action

1.6 Key Documents

Key documents are sources of information incorporated into this EA. Documents are considered to be 

key because of similar actions, analyses, or impacts that may apply to this Proposed Action. The Council 

on Environmental Quality (CEQ) guidance encourages incorporating documents by reference. 

Documents incorporated by reference in part or in whole include:

• Categorical Exclusion for the Decentralization of Steam Distribution System at Naval Base San 

Diego, September 30, 2013. Under the proposed action discussed therein, the existing plant 

owner/operator would demolish the existing cogeneration plant after the lease expires in 2018. 

All existing components associated with the cogeneration plant would be removed or 

abandoned. Refer to Section 1.2, Background. (Please note: the decommissioning and 

demolition of the existing plant is included as a cumulative project for analysis of cumulative 

impacts in Chapter 4 of this EA. Please see the 2013 Categorical Exclusion for analysis of the 

impacts to various resource areas associated with demolition of the existing cogeneration 

plant.)

Documents incorporated herein by reference are available upon request during the public review period 

by the Navy via the information provided in the Abstract.

1.7 Relevant Laws and Regulations

The Navy has prepared this EA based upon federal and state laws, statutes, regulations, and policies 

pertinent to the implementation of the Proposed Action, including the following:

• National Environmental Policy Act (NEPA) (42 U.S.C. sections 4321–4370h), which requires an 

environmental analysis for major federal actions that have the potential to significantly impact 

the quality of the human environment

• Council on Environmental Quality Regulations for Implementing the Procedural Provisions of 

NEPA (40 Code of Federal Regulations [CFR] parts 1500–1508)

• Navy regulations for implementing NEPA (32 CFR part 775), which provides Navy policy for 

implementing Council on Environmental Quality regulations and NEPA

• Clean Air Act (42 U.S.C. section 7401 et seq.)

• Clean Water Act (33 U.S.C. section 1251 et seq.)

• Coastal Zone Management Act (16 U.S.C. section 1451 et seq.)

• National Historic Preservation Act (54 U.S.C. section 306108 et seq.)

• EO 12088, Federal Compliance with Pollution Control Standards

• EO 12898, Federal Actions to Address Environmental Justice in Minority Populations and Lowincome Populations

• EO 13045, Protection of Children from Environmental Health Risks and Safety Risks

• EO 13175, Consultation and Coordination with Indian Tribal Governments

• EO 13514, Federal leadership in Environmental, Energy, and Economic Performances

• EO 13693, Planning for Federal Sustainability in the Next Decade
Naval Base San Diego Environmental Assessment September 2017

1-5

Purpose of and Need for the Proposed Action

A description of the Proposed Action’s consistency with these laws, policies and regulations, as well as 

the names of regulatory agencies responsible for their implementation, is presented in Chapter 5 

(Table 5-1).

1.8 Public and Agency Participation and Intergovernmental Coordination 

The Navy has made this Draft EA available to inform the public of the Proposed Action and to allow the 

opportunity for public review and comment. The Draft EA review period begins with a public notice 

published in the San Diego Union Tribune indicating the availability of the Draft EA and the locations 

where public review copies are available. The Draft EA will also be made available on the Navy Region 

Southwest website (http://cnic.navy.mil/regions/cnrsw.html).

The Navy published a Notice of Availability of the Draft EA for two consecutive days in the San Diego 

Union Tribune on the dates of September 30 and October 1, 2017. The notice described the Proposed

Action, solicited public comments on the Draft EA, provided dates of the public comment period, and 

announced that a copy of the EA would be available for review at the San Diego Central Library and 

posted on the Navy Region Southwest website.
Naval Base San Diego Environmental Assessment September 2017

1-6

Purpose of and Need for the Proposed Action

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Naval Base San Diego Environmental Assessment September 2017

2-1

Proposed Action and Alternatives

2 Proposed Action and Alternatives

2.1 Proposed Action

The Proposed Action would include the construction and operation of an energy security and resilience 

project that may include a natural gas peaker plant, installation of grid-integrated battery storage or 

other energy assets at NBSD. The Navy would enter into an agreement with a private partner to 

construct and operate energy asset(s), or maintenance of the existing cogeneration plant at NBSD with a 

contract duration of up to 37 years, with 35 years of system(s) service and one year for construction and 

approximately one year for decommissioning. The agreement would be done in accordance with 

10 United States Code (U.S.C.) §2667 lease authority (real estate outgrant) and would ensure fair 

compensation for the use of Navy lands where the proposed activities related to security/resilience 

and/or renewability would take place. 

2.2 Screening Factors

The National Environmental Policy Act’s (NEPA) implementing regulations provide guidance on the 

consideration of alternatives to a federally proposed action and require rigorous exploration and 

objective evaluation of reasonable alternatives. Only those alternatives determined to be reasonable 

and to meet the purpose and need require detailed analysis.

Potential alternatives that meet the purpose and need were evaluated against the following screening 

factors:

• Consistent with current land use as identified in the Installation Master Plan

• Proximity to distribution substation, building switchgear or distribution lines

• Must not interfere with NBSD mission or create unsafe conditions

• Location and/or design capable of providing electricity at or below the current cost of traditional 

power

• Energy providing facility that provides best overall value to the Navy with regard to both power 

distribution and in-kind consideration

• Meet the Secretary of the Navy’s timeline for energy resilience

Various alternatives were evaluated against the screening factors. Two parcels of land were identified at 

NBSD for potential siting of an energy security and resilience project (Figure 2-1). Site 1 is 0.8 hectare 

(2.1 acres) and houses the existing 40-MW steam cogeneration plant and is located immediately west of 

Surface Navy Boulevard and north of Vesta Road. Site 2 is 1.2 hectares (3.0 acres) and is located east of 

Harbor Drive.

The alternatives considered include:

• No Action Alternative

• Alternative 1 – Convert Existing 40-MW Cogeneration Plant on Site 1

• Alternative 2 – Natural Gas Peaker Plant on Site 2

• Alternative 3 – Large Integrated Batteries with Photovoltaic System on Site 2

• Alternative 4 –Operation of Existing Cogeneration Plant on Site 1
Harbor Drive

Ward Road

Mole Road

8th Street

Main Street

Woden Street

Brinser Street

Kalbfus Street

Civic Center Drive

4th Street

Taft Avenue

Knowlton Williams

Southall Street

Cleveland Avenue

Cum

min

gs

Road

Vesta Street

Mckinley Avenue

Wilson

Avenue

Harrison

Avenue

Yama

Street

Mc

Candless Road

Bainbridge Road

12th Street

Craven Street

4th Street

Cummings Road

Vesta Street

Vesta Street

Woden Street

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I:\PROJECTS\N\NAV\NAV-03.10_EnergySecurity\Map\EA_NBSD\Fig2_1_Sites.mxd NAV-03.10 11/22/16 -EV

Figure 2-1

NAVAL BASE SAN DIEGO

Site Locations for Energy Security and Resilience Facility

50' Utility Corridor

Site 1 (Existing Steam Plant)

Site 2

SDG&E Interconnection Station and NBSD Cummings Road Substation

Naval Base San Diego (NBSD) Boundary

City Boundary

KEY MAP

0 250

Meters N

0 750

Feet
Naval Base San Diego Environmental Assessment September 2017

2-3

Proposed Action and Alternatives

2.3 Alternatives Carried Forward for Analysis

Based on the reasonable alternative screening factors and meeting the purpose and need for the 

Proposed Action, four action alternatives were identified and will be analyzed within this EA.

2.3.1 No Action Alternative

Under the No Action Alternative, the Proposed Action would not occur. The No Action alternative would 

involve letting the lease expire for the existing 40-MW steam cogeneration plant. Per an existing 

contract action, the existing co-generation facility on Site 1 would be decommissioned and removed by 

the owner/operator. Site 2 would retain its current uses as parking. The No Action Alternative would not 

meet the purpose and need for the Proposed Action; however, as required by NEPA, the No Action 

Alternative is carried forward for analysis in this EA. The No Action Alternative will be used to analyze 

the consequences of not undertaking the Proposed Action and will serve to establish a comparative 

baseline for analysis. As a practical matter, decommissioning of the existing cogeneration plant would 

occur under Alternatives 2 and 3 as well as the No Action Alternative.

2.3.2 Alternative 1 – Convert Existing 40-MW Cogeneration Plant on Site 1

Under Alternative 1, the existing 40-MW steam cogeneration plant located on Site 1 would be converted 

to a natural gas peaker plant under a Model 2 acquisition strategy (see Section 1.2). As discussed in 

Section 1.2, the plant is currently operated by Applied Energy, LLC (AE LLC), and their 43-year contract 

with the Navy expires in 2018. A Categorical Exclusion from NEPA was prepared and approved in 2013. 

Under this alternative, the centralized steam distribution system would be eliminated; however, the 

existing cogeneration plant would remain and be converted into a natural gas peaker plant. A peaker 

plant generally runs only when there is a high demand, known as peak demand, for electricity. For the 

proposed peaker plant, the following assumptions were included: 120 startups and 120 shut downs per 

year, 11 operating hours per day and 1,416 operating hours per year (these assumptions were based on 

a similarly sized peaker facility where demand would be comparable for Southern California Edison). In 

addition, it is assumed that the existing underground utility lines to the San Diego Gas and Electric 

(SDG&E) interconnection substation would be utilized, and some upgrades may be necessary. A utility 

corridor location from the SDG&E interconnection station to Site 1, shown on Figure 2-1, is located 

within the Base. The exact location of the utility corridor would be subject to change during the design 

process; however, the corridor would be located within an existing paved area within the Base 

boundaries, probably within Cummings Road.

The Navy would enter into an agreement with a private partner to upgrade the existing facility and 

operate a natural gas peaker plant (up to 50 MW) on the 0.8-hectare (2.1 acre) site at NBSD. The lease 

would support on-Base generation of energy for off-Base consumption via a private partner in 

accordance with 10 United States Code (U.S.C.) §2667 (i.e., utility purchase or private off taker). At this 

time, the Navy does not intend to purchase energy from a proposed project.

In lieu of cash rents for a potential lease, the Navy may seek in-kind consideration in the form of 

emergency/back-up generation from the proposed project, for use only in the case of a utility grid 

outage. Legal and physical access to the energy asset positions the Navy as an off taker only

during times of grid outage, at mutual benefit to both the Navy and the developer.

The natural gas peaker plant would be upgraded in accordance with industry standards and all 

applicable local, state and federal design standards commonly used in the design of peaking generation 

facilities. These standards would include specific criteria as they apply to the International Building Code 
Naval Base San Diego Environmental Assessment September 2017

2-4

Proposed Action and Alternatives

(ICC, 2015), and will encompass seismic design standards as they pertain to the project site. The peaker 

plant would not exceed 15.2 meter (50 feet) in height. The facility would be designed in accordance with 

the Naval Base San Diego Installation Appearance Plan (January 2008) that specifies the look of buildings 

as well as vegetation. The private partner would be required to comply with federal, state and local 

regulations, policies, and/or permits required to operate the facility.

The retrofit of the existing facility to a natural gas peaker plant would take up to six months and would 

be operational no later than August 2018.

In October 2006, the Department of Defense (DoD) issued Instruction number 2000.16, "DoD 

Antiterrorism Standards," requiring all DoD Components to adopt and adhere to common criteria and 

minimum construction standards to mitigate antiterrorism vulnerabilities and terrorist threats. The 

intent of these building standards is to integrate greater resistance to a terrorist attack into all inhabited 

buildings. That philosophy affects the general practice of designing inhabited buildings. Anti-terrorism

Force Protection (ATFP) standards consist of restrictions for onsite planning, including standoff 

distances, building separation, unobstructed space, drive-up and drop-off areas, access roads, and 

parking; structural design; structural isolation; and electrical and mechanical design. ATFP standards 

would be incorporated into the design of the new administrative space, where applicable.

Construction projects would incorporate Leadership in Energy and Environmental Design, commonly 

referred to as LEED, and sustainable development concepts to achieve optimum resource efficiency, 

sustainability, and energy conservation.

2.3.3 Alternative 2 – Natural Gas Peaker Plant on Site 2

Under Alternative 2, a natural gas peaker plant (up to 50 MW) would be constructed and operated on 

Site 2 under a Model 2 acquisition strategy (see Section 1.2). For the proposed peaker plant, the 

following assumptions were included: 120 startups and 120 shut downs per year, 11 operating hours per 

day and 1,416 operating hours per year. In addition, an underground utility corridor to the SDG&E 

interconnection substation would be constructed. A probable utility corridor location from the SDG&E 

interconnection station to Site 2, shown on Figure 2-1, is located within Cummings Road and 4th Street. 

However, the exact location of the utility corridor would be subject to change during the design process. 

In any case, the corridor would be located within an existing paved area and coordination would occur 

with the City of National City for any portion of the utility corridor that is located within the City’s

jurisdiction.

Site 2 is currently unpaved and used for equipment open storage or staging. There are no existing 

structures. The peaker plant would be housed in a facility that would not exceed 15.2 meter (50 feet) in 

height and the facility would be painted in earth-tone colors to blend in with the surrounding 

environment.

The Navy would enter into an agreement with a private partner to construct and operate the up to 

50 MW natural gas peaker plant on the approximately 1.2-hectare (3-acre) site at NBSD. The lease 

would support on-Base generation of energy for off-Base consumption via a private partner in 

accordance with 10 U.S.C. §2667 as outlined in Alternative 1 above.

Similar to Alternative 1, the natural gas peaker plant would be constructed in accordance with industry 

standards and applicable local, state and federal design standards commonly used in the design of 

peaking generation facilities. These standards would include specific criteria as they apply to the 

International Building Code (ICC, 2015), and would encompass seismic design standards as they pertain 
Naval Base San Diego Environmental Assessment September 2017

2-5

Proposed Action and Alternatives

to the project site. ATFP standards will be incorporated into the design of the new administrative space, 

where applicable. The private partner would be required to comply with federal, state and local 

regulations, policies, and/or permits required to operate the facility.

2.3.4 Alternative 3 – Large Integrated Batteries with Photovoltaic System on Site 2

Under Alternative 3, a battery energy storage system would be constructed and operated on Site 2 

under a Model 2 acquisition strategy (see Section 1.2). A small photovoltaic system might also be 

constructed to provide power for the battery energy storage system, and an energy inverter might also 

be constructed. The battery storage system may be comprised of technologies such as lithium-ion cell 

chemistries and/or low flow battery chemistries utilizing proprietary solutions such as vanadium sulfate 

chloride, zinc-bromine, zinc-chloride, or other electrolytes. Acid-based batteries would not be utilized. 

The batteries would be housed in large containers to protect them from the elements. The battery 

energy storage facility would not exceed 15.2 meters (50 feet) in height. Construction on the site would 

comply with all installation and safety requirements. Each container would be painted in earth-tone 

colors to blend in with the surrounding environment. In addition, an underground utility corridor to the 

SDG&E interconnection substation would be constructed. A potential utility corridor location from the 

SDG&E interconnection station to Site 2, shown on Figure 2-1, is located within Cummings Road and 

4th Street. However, the exact location of the utility corridor may be subject to change during the 

design process. In any case, the corridor would be located within an existing paved area and 

coordination would occur with the City of National City for any portion of the utility corridor that is 

located within the City’s jurisdiction.

The Navy would enter into an agreement with a private partner to construct and operate the battery 

energy storage system on the approximately 1.2-hectare (3-acre) site at NBSD. The lease would support 

on-Base storage of energy for off-Base consumption via a private partner in accordance with 10 U.S.C. 

§2667 as outlined in Alt 1 above.

2.3.5 Alternative 4 – Full Time Operation of Existing Cogeneration Plant on Site 1

Under Alternative 4, the lease at the existing 40-MW steam cogeneration plant on Site 1 would be 

renewed and decommissioning and removal by the owner/operator would not occur. The existing 

cogeneration plant could operate full time (up to 8,760 hours per year). Minor retooling of the existing 

plant may occur; however, no major upgrades to the facility would be anticipated. 

As discussed in Section 1.2, the plant is currently operated by Applied Energy, LLC (AE LLC), and their 

40-year contract with the Navy expires in 2018. Under this alternative, the Navy would enter into a new 

the agreement with AE LLC for the existing facility to operate and maintain the existing plant (up to 

50 MW) on the 0.8-hectare (2.1-acre) site at NBSD. The lease would support on-Base generation of 

energy for off-Base consumption via a private partner in accordance with 10 U.S.C. §2667 as outlined in 

Alternative 1 above.

2.4 Alternatives Considered but not Carried Forward for Detailed Analysis

The following alternatives were considered, but not carried forward for detailed analysis in this EA as it 

was determined that they did not meet the purpose and need for the project and did not satisfy the 

reasonable alternative screening factors presented in Section 2.2.
Naval Base San Diego Environmental Assessment September 2017

2-6

Proposed Action and Alternatives

2.4.1 Large Integrated Batteries on Site 1

Under this alternative, the existing cogeneration facility on Site 1 would need to be decommissioned 

and demolished prior to the construction of a battery energy storage system. Similar to Alternative 3, 

the battery energy storage system would be operated under a Model 2 acquisition strategy (see 

Sections 2.3.4 and 2.3.6, respectively). This alternative was considered but is not being carried forward 

for detailed analysis in the EA because Site 1 is currently encumbered with the existing 40-MW 

cogeneration facility and the decommissioning and demolition are the responsibility of the current 

operator. The lease is not set to expire until February 2018, and there is no current schedule for 

decommissioning and demolition. Due to the unavailability of such a schedule at this time, an 

alternative involving battery storage and photovoltaic systems at Site 1 would not meet the timeline set 

forth under SECNAV's goals and priorities for national energy resilience and would not meet the purpose 

and need of the Proposed Action.

2.4.2 Photovoltaic Systems Only at Sites 1 and/or 2

Under this alternative, a ground-mounted photovoltaic system would be constructed and operated at 

Sites 1 or 2 (or both) under a Model 2 acquisition strategy. This alternative was considered but is not 

being carried forward for detailed analysis in the EA because based on the small size of the two parcels 

(2.1 hectares [5.1 acres] total for both sites) they would generate approximately 0.5 MW. In general, 

4 hectares (10 acres) of photovoltaic are required to produce one MW of power. NBSD is served by San 

Diego Gas and Electric. The Base load is approximately 35 MW, the Ship load is approximately 19.3 MW, 

and the peak load is approximately 40 MW. Therefore, the 0.5 MW provided by the proposed 

photovoltaic system would not meet critical load. Absent a storage component (such as batteries), a 

ground-mounted photovoltaic-only alternative would not be chosen since it would not provide sufficient 

energy resiliency and security and would not the purpose and need of the Proposed Action.

2.5 Best Management Practices Included in Proposed Action 

This section presents an overview of the best management practices (BMPs) that are incorporated into 

the Proposed Action in this document. BMPs are existing policies, practices, and measures that the Navy 

would adopt to reduce the environmental impacts of designated activities, functions, or processes. 

Although BMPs mitigate potential impacts by avoiding, minimizing or reducing/eliminating impacts, 

BMPs are distinguished from potential mitigation measures because BMPs are (1) existing requirements 

for the Proposed Action, (2) ongoing, regularly occurring practices, or (3) not unique to this Proposed 

Action. In other words, the BMPs identified in this document are inherently part of the Proposed Action 

and are not potential mitigation measures proposed as a function of the NEPA environmental review 

process for the Proposed Action. Table 2-1 includes a list of BMPs. Mitigation measures are discussed 

separately in Chapter 3.
Naval Base San Diego Environmental Assessment September 2017

2-7

Proposed Action and Alternatives

Table 2-1

Best Management Practices

BMP Description Impacts 

Reduced/Avoided

Compliance with 

regulatory and industry 

geotechnical standards 

and site-specific 

geotechnical 

investigation

The Proposed Action would comply with applicable 

regulatory and industry standards, as well as 

recommendations from site-specific geotechnical 

investigations. BMPs would potentially include the 

removal/recompaction or replacement of unsuitable 

materials (e.g., compressible or expansive soils) with 

properly engineered fill; use of appropriate slope 

design (e.g., grade limitations), drainage, and 

landscaping (e.g., native and drought-tolerant 

varieties) as applicable; use of appropriate 

foundation/footing pavement dimensions and 

reinforcing; provision of positive surface drainage 

and/or use of subdrains; incorporation of projected 

ground acceleration and International Building 

Code/California Building Code seismic parameters 

into the project design (e.g., seismic zone, subsurface 

profile types, seismic and near-source coefficients for 

acceleration and velocity, and seismic source); 

removal/replacement of unsuitable surficial materials; 

and slope stabilization if applicable.

Geology (soil 

compression/settlement;

manufactured slope 

stability/retaining wall 

design; foundation/

footing, building pad, and 

pavement design; fill 

composition/placement 

methodology; soil 

instability, shallow 

groundwater/drainage; 

and seismic issues from 

ground shaking and 

liquefaction)

Storm Water Pollution 

Prevention Plans 

(SWPPPs)

The Proposed Action would conform with applicable 

National Pollution Discharge Elimination System 

(NPDES) requirements including implementation of 

one or more SWPPPs and associated BMPs. BMPs may 

include erosion control blankets, soil stabilizers, 

temporary seeding, silt fencing, hay bales, sand bags, 

and storm drain inlet protection devices.

Soils (erosion and off-site 

sediment transport); 

Water Resources (water 

quality)

Low Impact 

Development

The Proposed Action would conform with applicable 

requirements related to Low Impact Development 

design and control of runoff rates/amounts. This may 

include site-specific measures such as minimizing 

impervious areas and preserving existing vegetation 

to the Maximum Extent Technically Feasible, the use 

of bioretention or infiltration facilities, diverting flow 

from impervious areas to vegetated/landscaped sites, 

use of pervious pavement and drainage facilities 

(e.g., swales/ channels) in applicable areas, and storm 

flow capture/reuse (e.g., via rain barrels).

Water Resources (surface 

water and water quality)
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Proposed Action and Alternatives

Table 2-1

Best Management Practices

BMP Description Impacts 

Reduced/Avoided

Traffic Control Plan The Proposed Action would implement a Traffic 

Control Plan that would specify the following:

• Truck and worker trips associated with 

demolition and construction activities would be 

scheduled outside of the peak commuting 

periods of 7:00 to 9:00 a.m. and 4:00 to 

6:00 p.m. to the maximum extent practicable in 

order to minimize the potential for peak hour 

traffic congestion;

• No oversized construction vehicles would be 

used on public roadways (i.e., all vehicles will 

comply with the size and weight limits specified 

in the California Vehicle Code);

• Only designated truck routes would be used; and

• Specific traffic control measures would be 

developed for circumstances where trucks would 

be temporarily stacked in the right-of-way.

Traffic (Temporary 

construction and 

demolition traffic impacts)

Hazardous Waste 

Management Plan

The construction contractor for the private partner 

would implement a Hazardous Waste Management 

Plan to ensure appropriate procedures are in place if 

any contaminated soil is encountered during 

construction.

Public Health and Safety 

(Hazardous Waste)

Health and Safety Plan The construction contractor for the private partner 

would implement a Health and Safety Plan to ensure 

appropriate safety measures are implemented during 

construction.

Public Health and Safety 

(Safety)
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Affected Environment and Environmental Consequences

3 Affected Environment and Environmental Consequences

This chapter presents a description of the environmental resources and baseline conditions that could 

be affected from implementing any of the alternatives and an analysis of the potential direct and 

indirect effects of each alternative.

All potentially relevant environmental resource areas were initially considered for analysis in this 

Environmental Assessment (EA). In compliance with the National Environmental Policy Act (NEPA), the 

Council on Environmental Quality (CEQ), and Department of Navy guidelines; the discussion of the 

affected environment (i.e., existing conditions) focuses only on those resource areas potentially subject 

to impacts. Additionally, the level of detail used in describing a resource is commensurate with the 

anticipated level of potential environmental impact. 

“Significantly,” as used in NEPA, requires considerations of both context and intensity. Context means 

that the significance of an action must be analyzed in several contexts such as society as a whole 

(e.g., human, national), the affected region, the affected interests, and the locality. Significance varies 

with the setting of a proposed action. For instance, in the case of a site-specific action, significance 

would usually depend on the effects in the locale rather than in the world as a whole. Both short- and 

long-term effects are relevant. Intensity refers to the severity or extent of the potential environmental 

impact, which can be thought of in terms of the potential amount of the likely change. In general, the 

more sensitive the context, the less intense a potential impact needs to be in order to be considered 

significant. Likewise, the less sensitive the context, the more intense a potential impact would need to 

be to be expected to be significant.

This section includes air quality, visual resources, noise, infrastructure, transportation (construction 

only), and public health and safety.

The potential impacts to the following resource areas are considered to be negligible or non-existent so 

they were not analyzed in detail in this EA:

Water Resources: Since the project’s construction phase would disturb more than 1 acre (0.4 hectare), 

coverage under the National Pollution Discharge Elimination System (NPDES) General Permit for 

Discharges of Storm Water Associated with Construction Activity (“General Permit”) would be required 

prior to project construction. The General Permit is issued by the California Environmental Protection 

Agency’s State Water Resources Control Board for construction-related discharges as regulated by the 

Board pursuant to the Department of Water Quality Order 2009-009-DWQ. As part of the permit, a 

Storm Water Pollution Prevention Plan (SWPPP) incorporating best management practices (BMPs), 

outlined in Section 2.5, would be implemented by the private partner. All construction activities with the 

potential of affecting water quality due to runoff would be conducted in accordance with the SWPPP 

requirements. 

The private partner would be required to prepare a Notice of Intent for the SWPPP and pay appropriate 

NPDES fees and surcharges to the Regional Water Quality Control Board to obtain a waste discharge 

number for implementation of the Proposed Action. At the completion of work, the private partner 

would prepare and file a Notice of Termination.

The potential increase in storm water runoff as a result of the Proposed Action would be managed such 

that discharge exiting the site post-construction would be equal to or less than existing conditions 

through the use of appropriately designed conveyance structures and BMPs. Therefore, only negligible 

impacts on water resources would occur.
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Coastal Resources: The Coastal Zone Management Act (CMZA of 1972 (16 U.S.C. §1451)) encourages 

coastal states to be proactive in managing coastal zone uses and resources. CZMA established a 

voluntary coastal planning program where participating states submit a Coastal Zone Management Plan 

to the National Oceanic and Atmospheric administration for approval. California has an approved 

Coastal Management Plan. Each state defines its coastal zone in accordance with the CZMA. Excluded 

from any coastal zone are lands, the use of which by law is subject solely to the discretion of the federal 

government or which is held in trust by the federal government (16 U.S.C. §1453). The proposed project 

is entirely contained within the boundaries of NBSD and is federal government property, thus 

specifically excluded from the coastal zone. 

Under the CZMA, federal agency actions within or outside the coastal zone that may affect any land or 

water use or natural resource of the coastal zone shall be carried out in a manner that is consistent to 

the maximum extent practicable with the enforceable policies of the approved state management 

programs. The Navy conducted an effects analysis as part of its determination of the action’s effects to 

coastal uses or resources for purposes of federal consistency review under the CZMA. This was done to 

factually determine whether the action (even if conducted entirely within a federal enclave) would 

affect any coastal use or resource. None of the alternatives would have any effects on public access or 

public recreation since the sites are restricted from public access and there is no recreational use of the 

proposed sites. None of the alternatives would affect biological productivity, water quality, or sensitive 

biological species since the sites are devoid of endangered or threatened species and any sensitive 

habitats or species. None of the alternatives would increase human health risk or environmental 

exposure to hazardous materials or hazardous wastes. None of the alternatives would disturb 

archaeological sites or other cultural resources, substantially alter the visual character of the area, or 

generate regionally significant air emissions. Therefore, none of the alternatives would result in impacts 

to coastal uses and resources. 

Geological Resources: The alternative sites considered for the construction and operation of a new 

energy asset (such as a natural gas peaker plant or large grid-integrated batteries) on NBSD have been 

previously graded, paved, or otherwise disturbed. Only minimal additional grading might be required 

during construction. BMPs outlined in Section 2.5, including silt fencing, fiber rolls, and minimizing 

points of access to construction sites, would be implemented to minimize soil erosion potential. The 

private partner would adhere to all applicable state laws for erosion and sediment control and would 

monitor the effectiveness of temporary erosion control measures. Therefore, there would be no impacts 

on geological resources.

Cultural Resources: All four action alternative sites are located over former wetlands or former open 

bay and have been filled with imported material (fill); therefore, there would be no impacts to 

archaeological resources. In addition, none of the sites contain historical structures; therefore, there 

would be no effects on historic properties. All four sites would be covered by the Naval Base San Diego 

Programmatic Agreement dated May 2014.

Biological Resources: All of the action alternatives are located on previously disturbed or paved 

property and support no native vegetation communities or habitats. No wetlands or other Clean Water 

Act regulated waters occur on sites 1, 2 or 3. Therefore, only negligible impacts on biological resources 

would occur.

Land Use: None of the proposed action alternative sites, as described in Chapter 2, would affect land 

use. NBSD is owned and operated by the U.S. government and is under the jurisdiction of the Navy. The 
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Navy Region Southwest (NRSW) Regional Integrated Plan is intended to balance operational and shore 

investment requirements for achieving increased efficiency and to better align the shore establishment 

with the fleet (DON, 2010). The document contains overall land management guidelines for NRSW 

installations, including NBSD, which are designed to place operational activities in those areas where 

they are most suitable and compatible with land (or marine) conditions, other activities in the same 

areas, and adjacent operations. Therefore, no land use impacts would occur.

Socioeconomics: Construction and operation of a new energy asset (such as a natural gas peaker plant 

or large grid-integrated batteries) on NBSD would have no demonstrable long-term socioeconomic 

effect on the surrounding community. It would not attract a long-term worker population to the project 

vicinity nor affect the need for housing in the area. It is expected that the crews required for proposed 

construction activities would be comprised of local contractors in the surrounding area. Proposed 

operations would not require more than a minimal staff of on-Base workers (fewer than 10). 

Implementation of the Action alternatives would have short-term beneficial effects to the economy, as 

temporary construction jobs would be created. The overall effects on the local and regional economy

and socioeconomic environment would be negligible and no impacts would occur. 

Environmental Justice: Executive Order (EO) 12898 – Federal Actions to Address Environmental Justice 

in Minority Populations and Low-Income Populations – directs federal agencies to identify and address 

disproportionately high and adverse human health or environmental effects of their actions on minority 

and low-income populations, to the greatest extent practicable and permitted by law. The EO is also 

intended to promote nondiscrimination in federal programs that affect humans and the environment, as 

well as provide minority and low-income communities access to public information and public 

participation.

As all of the action alternatives would take place within NBSD property boundaries, and none of the 

alternatives would cause adverse human health or environmental effects, there would be no 

disproportionately high environmental or health impacts on low-income or minority populations. 

Therefore, EO 12898 impacts would not occur. 

3.1 Air Quality

This discussion of air quality includes criteria pollutants, standards, sources, permitting, and greenhouse 

gases. Air quality in a given location is defined by the concentration of various pollutants in the 

atmosphere. A region’s air quality is influenced by many factors, including the type and amount of 

pollutants emitted into the atmosphere, the size and topography of the air basin, and the prevailing 

meteorological conditions. 

Most air pollutants originate from human-made sources, including mobile sources (e.g., cars, trucks, 

buses) and stationary sources (e.g., factories, refineries, power plants), as well as indoor sources 

(e.g., some building materials and cleaning solvents). Air pollutants are also released from natural 

sources such as volcanic eruptions and forest fires.

3.1.1 Regulatory Setting

3.1.1.1 Criteria Pollutants and National Ambient Air Quality Standards

The principal pollutants defining the air quality, called “criteria pollutants,” include carbon monoxide 

(CO), sulfur dioxide (SO2), nitrogen dioxide (NO2), ozone, suspended particulate matter less than or 

equal to 10 microns in diameter (PM10), fine particulate matter less than or equal to 2.5 microns in 
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Affected Environment and Environmental Consequences

diameter (PM2.5), and lead (Pb). CO, SO2, Pb, and some particulates are emitted directly into the 

atmosphere from emissions sources. Ozone, NO2, and some particulates are formed through 

atmospheric chemical reactions that are influenced by weather, ultraviolet light, and other atmospheric 

processes.

Criteria pollutants are defined by state and federal law as a risk to the health and welfare of the general 

public. In general, air pollutants include the following compounds: 

• Ozone (O3)

• Volatile Organic Compounds (VOCs)

• Carbon Monoxide (CO)

• Nitrogen Dioxide (NO2)

• Respirable Particulate Matter and Fine Particulate Matter (PM10 and PM2.5)

• Sulfur dioxide (SO2)

• Lead (Pb)

The following specific descriptions of health effects for each of the air pollutants potentially associated 

with project construction and operation are based on information provided by the California Air 

Resources Board (CARB; 2009) and the U.S. Environmental Protection Agency (USEPA; 2017).

Ozone. Ozone is considered a photochemical oxidant, which is a chemical that is formed when VOCs and 

nitrogen oxides (NOX), both by-products of fuel combustion, react in the presence of ultraviolet light. 

Ozone is considered a respiratory irritant and prolonged exposure can reduce lung function, aggravate 

asthma, and increase susceptibility to respiratory infections. Children and those with existing respiratory 

diseases are at greatest risk from exposure to ozone. 

Volatile Organic Compounds. VOCs are compounds composed primarily of hydrogen and carbon atoms. 

Internal combustion associated with motor vehicle usage is the major source of VOCs. Other sources of 

VOCs include evaporative emissions from paints and solvents, the application of asphalt paving, and the 

use of household consumer products such as aerosols. Adverse effects on human health are not caused 

directly by VOCs, but rather by reactions of VOCs to form secondary pollutants such as ozone. 

Carbon Monoxide. CO is a by-product of fuel combustion. CO is an odorless, colorless gas. CO affects red 

blood cells in the body by binding to hemoglobin and reducing the amount of oxygen that can be carried 

to the body’s organs and tissues. CO can cause health effects to those with cardiovascular disease and 

can also affect mental alertness and vision. 

Nitrogen Dioxide. NO2 is also a by-product of fuel combustion and is formed both directly as a product 

of combustion and in the atmosphere through the reaction of nitrogen oxide (NO) with oxygen. NO2 is a 

respiratory irritant and may affect those with existing respiratory illness, including asthma. NO2 can also 

increase the risk of respiratory illness. 

Respirable Particulate Matter and Fine Particulate Matter. Respirable particulate matter, or PM10, 

refers to particulate matter with an aerodynamic diameter of 10 microns or less. Fine particulate matter, 

or PM2.5, refers to particulate matter with an aerodynamic diameter of 2.5 microns or less. Particulate 

matter in these size ranges have been determined to have the potential to lodge in the lungs and 

contribute to respiratory problems. PM10 and PM2.5 arise from a variety of sources, including road dust, 
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diesel exhaust, fuel combustion, tire and brake wear, construction operations, and windblown dust. 

PM10 and PM2.5 can increase susceptibility to respiratory infections and can aggravate existing 

respiratory diseases such as asthma and chronic bronchitis. PM2.5 is considered to have the potential to 

lodge deeper in the lungs. Diesel particulate matter is classified a carcinogen by CARB. 

Sulfur dioxide. SO2 is a colorless, reactive gas that is produced from the burning of sulfur-containing 

fuels such as coal and oil and by other industrial processes. Generally, the highest concentrations of SO2

are found near large industrial sources. SO2 is a respiratory irritant that can cause narrowing of the 

airways leading to wheezing and shortness of breath. Long-term exposure to SO2 can cause respiratory 

illness and aggravate existing cardiovascular disease. 

Lead. Lead in the atmosphere occurs as particulate matter. With the phase-out of leaded gasoline, large 

manufacturing facilities are the sources of the largest amounts of lead emissions. Lead has the potential 

to cause gastrointestinal, central nervous system, kidney and blood diseases upon prolonged exposure. 

Lead is also classified as a probable human carcinogen. Because emissions of lead are found only in 

projects that are permitted by the local air district, lead is not an air quality of concern for the proposed 

project.

Federal and State ambient air quality standards have been set to protect the most sensitive persons 

from illness or discomfort. Residential areas, schools, playgrounds, child care centers, athletic facilities, 

hospitals, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement 

homes are especially likely to include persons sensitive to air pollutants. Air quality is defined by 

ambient air concentrations of specific pollutants identified by the USEPA to be of concern with respect 

to health and welfare of the general public. The USEPA is responsible for enforcing the Federal Clean Air 

Act (CAA) of 1970 and its 1977 and 1990 Amendments. Under the CAA, the USEPA has established 

National Ambient Air Quality Standards (NAAQS) (40 Code of Federal Regulations [CFR] part 50) for 

these pollutants, which identify concentrations of pollutants in the ambient air below which no adverse 

effects on the public health and welfare are anticipated. NAAQS are classified as primary or secondary. 

Primary standards protect against adverse health effects; secondary standards protect against welfare 

effects, such as damage to farm crops and vegetation and damage to buildings. Some pollutants have 

long-term and short-term standards. Short-term standards are designed to protect against acute, or 

short-term, health effects, while long-term standards were established to protect against chronic health 

effects.

The CAA allows states to adopt ambient air quality standards and other regulations provided they are at 

least as stringent as federal standards. CARB has established the more stringent California Ambient Air 

Quality Standards (CAAQS) for the six criteria pollutants through the California Clean Air Act of 1988 

(CCAA), and also has established CAAQS for additional pollutants, including sulfates, hydrogen sulfide 

(H2S), vinyl chloride, and visibility-reducing particles. Table 3-1, Ambient Air Quality Standards, shows 

the federal and state ambient air quality standards for these pollutants.
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Table 3-1

Ambient Air Quality Standards

Pollutant Averaging 

Time

California

Standards

Federal Standards

Primary1 Secondary2

O3

1 Hour 0.09 ppm (180 μg/m3) – –

8 Hour 0.070 ppm 

(137 μg/m3) 0.070 ppm (137 μg/m3

) Same as Primary

PM10

24 Hour 50 μg/m3 150 μg/m3 Same as Primary

AAM 20 μg/m3 – Same as Primary

PM2.5

24 Hour – 35 μg/m3 Same as Primary

AAM 12 μg/m3 12.0 μg/m3 15.0 μg/m3

CO

1 Hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) –

8 Hour 9.0 ppm (10 mg/m3) 9 ppm (10 mg/m3) –

8 Hour

(Lake Tahoe) 6 ppm (7 mg/m3

) – –

NO2

1 Hour 0.18 ppm (339 μg/m3) 0.100 ppm (188 μg/m3) –

AAM 0.030 ppm (57 μg/m3) 0.053 ppm (100 μg/m3) Same as Primary

SO2

1 Hour 0.25 ppm (655 μg/m3) 0.075 ppm (196 μg/m3) –

3 Hour – – 0.5 ppm

(1,300 μg/m3)

24 Hour 0.04 ppm (105 μg/m3) – –

Lead

30-day Avg. 1.5 μg/m3 – –

Calendar 

Quarter – 1.5 μg/m3

Same as Primary Rolling

3-month Avg. – 0.15 μg/m3

Visibility 

Reducing 

Particles

8 Hour

Extinction coefficient 

of 0.23 per km –

visibility ≥ 10 miles

(0.07 per km – ≥30 

miles for Lake Tahoe)

No

Federal

Sulfates 24 Hour 25 μg/m Standards 3

Hydrogen 

Sulfide 1 Hour 0.03 ppm (42 μg/m3

)

Vinyl Chloride 24 Hour 0.01 ppm (26 μg/m3)

Source: CARB 2016 

1 National Primary Standards: The levels of air quality necessary, within an adequate margin of safety, to protect the 

public health. 2 National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or 

anticipated adverse effects of a pollutant.

O3: ozone; ppm: parts per million; μg/m3

: micrograms per cubic meter; PM10: large particulate matter; 

AAM: Annual Arithmetic Mean; PM2.5: fine particulate matter; CO: carbon monoxide; mg/m3: milligrams per cubic 

meter; NO2 nitrogen dioxide; SO2: sulfur dioxide; km: kilometer; –: No Standard.
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Areas that are and have historically been in compliance with the NAAQS are designated as attainment 

areas. Areas that violate a federal air quality standard are designated as nonattainment areas. Areas 

that have transitioned from nonattainment to attainment are designated as maintenance areas and are 

required to adhere to maintenance plans to ensure continued attainment. On December 19, 2019, the 

San Diego Air Basin (SDAB) was classified as a moderate nonattainment area for the 8-hour NAAQS for 

ozone. The SDAB is an attainment area under the NAAQS for all other criteria pollutants. The SDAB is 

currently classified as a nonattainment area under the CAAQS for ozone (serious nonattainment), PM10, 

and PM2.5.

The CAA requires states to develop a general plan to attain and maintain the NAAQS in all areas of the 

country and a specific plan to attain the standards for each area designated nonattainment for a NAAQS. 

These plans, known as State Implementation Plans (SIPs), are developed by state and local air quality 

management agencies and submitted to USEPA for approval.

The San Diego Air Pollution Control District (SDAPCD) is the local agency responsible for the 

administration and enforcement of air quality regulations for San Diego County (County). The SDAPCD 

and San Diego Association of Governments (SANDAG) are responsible for developing and implementing 

the clean air plan for attainment and maintenance of the ambient air quality standards in the SDAB. The 

County’s Regional Air Quality Strategies (RAQS) was initially adopted in 1991, and is updated on a 

triennial basis. The most recent version of the RAQS was adopted in 2016 (SDAPCD 2016). The local 

RAQS, in combination with those from all other California nonattainment areas with serious (or worse) 

air quality problems, is submitted to CARB, which develops the SIP. The SIP relies on the same 

information from SANDAG to develop emission inventories and emission reduction strategies that are 

included in the attainment demonstration for the air basin. The current federal and state attainment 

status for San Diego County is presented in Table 3-2, San Diego Air Basin Attainment Status.

Table 3-2

San Diego Air Basin Attainment Status

Criteria Pollutant Federal Designation State Designation

O3 (1-hour) (No federal standard) Nonattainment

O3 (8-hour) Marginal Nonattainment Nonattainment

CO Attainment Attainment

PM10 Unclassifiable Nonattainment

PM2.5 Attainment Nonattainment

NO2 Attainment Attainment

SO2 Attainment Attainment

Lead Attainment Attainment

Sulfates (No federal standard) Attainment

Hydrogen Sulfide (No federal standard) Unclassifiable

Visibility (No federal standard) Unclassifiable

Source: SDAPCD 2017

3.1.1.2 General Conformity

The USEPA General Conformity Rule applies to federal actions occurring in nonattainment or 

maintenance areas when the total direct and indirect emissions of nonattainment pollutants (or their 

precursors) exceed specified thresholds. The emissions thresholds that trigger requirements for a 

conformity analysis are called de minimis levels. De minimis levels (in tons per year [tpy]) vary by 
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Affected Environment and Environmental Consequences

pollutant and also depend on the severity of the nonattainment status for the air quality management 

area in question.

A conformity applicability analysis is the first step of a conformity evaluation and assesses if a federal 

action must be supported by a conformity determination. This is typically done by quantifying applicable 

direct and indirect emissions that are projected to result due to implementation of the federal action. 

Indirect emissions are those emissions caused by the federal action and originating in the region of 

interest, but which can occur at a later time or in a different location from the action itself and are 

reasonably foreseeable. The federal agency can control and will maintain control over the indirect action 

due to a continuing program responsibility of the federal agency. Reasonably foreseeable emissions are 

projected future direct and indirect emissions that are identified at the time the conformity evaluation is 

performed. The location of such emissions is known and the emissions are quantifiable, as described and 

documented by the federal agency based on its own information and after reviewing any information 

presented to the federal agency. If the results of the applicability analysis indicate that the total 

emissions would not exceed the de minimis emissions thresholds, then the conformity evaluation 

process is completed. De minimis threshold emissions are presented in Table 3-3.

Table 3-3

General Conformity de minimis Levels

Pollutant Area Type Tons per

Year

Ozone (VOC or NOX)

Serious nonattainment 50

Severe nonattainment 25

Extreme nonattainment 10

Other areas outside an ozone transport region 100

Ozone (NOX)

Marginal and moderate nonattainment inside 

an ozone transport region 100

Maintenance 100

Ozone (VOC)

Marginal and moderate nonattainment inside 

an ozone transport region 50

Maintenance within an ozone transport region 50

Maintenance outside an ozone transport region 100

Carbon monoxide, SO2 and NO2 All nonattainment & maintenance 100

PM10

Serious nonattainment 70

Moderate nonattainment and maintenance 100

PM2.5

Direct emissions, SO2, NOx (unless 

determined not to be a significant 

precursor), VOC or ammonia (if 

determined to be significant precursors)

All nonattainment & maintenance 100

Lead (Pb) All nonattainment & maintenance 25

Source: 40 CFR 93.153(b)

3.1.1.3 Permitting 

New Source Review (Preconstruction Permit) 

New major stationary sources and major modifications at existing major stationary sources are required 

by the CAA to obtain an air pollution permit before commencing construction. This permitting process 
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for major stationary sources is called New Source Review and is required whether the major source or 

major modification is planned for nonattainment areas or attainment and unclassifiable areas. New 

Source Review is governed in the County by SDAPCD Regulation II Rules 20.1, 20.2, 20.3, and 20.4. In 

general, permits for sources in attainment areas and for other pollutants regulated under the major 

source program are referred to as Prevention of Significant Deterioration (PSD) permits, while permits 

for major sources emitting nonattainment pollutants and located in nonattainment areas are referred to 

as nonattainment new source review permits. In addition, a proposed project may have to meet the 

requirements of nonattainment new source review for the pollutants for which the area is designated as 

nonattainment and PSD for the pollutants for which the area is attainment. Additional PSD permitting 

thresholds apply to increases in stationary source greenhouse gas (GHG) emissions. PSD permitting can 

also apply to a new major stationary source (or any net emissions increase associated with a 

modification to an existing major stationary source) that is constructed within 6.2 miles of a Class I area, 

and which would increase the 24-hour average concentration of any regulated pollutant in the Class I 

area by 1 microgram per cubic meter (μg/m3

) or more. Navy installations comply with applicable permit 

requirements under the PSD program per 40 CFR section 51.166. NSR permitting would be the 

responsibility of the private partner.

Title V (Operating Permit)

The Title V Operating Permit Program consolidates all CAA requirements applicable to the operation of a 

source, including requirements from the SIP, preconstruction permits, and the air toxics program. It 

applies to stationary sources of air pollution that exceed the major stationary source emission 

thresholds, as well as other non-major sources specified in a particular regulation. The program includes 

a requirement for payment of permit fees to finance the operating permit program whether 

implemented by USEPA or a state or local regulator. Title V permits is governed in the County by 

SDAPCD Regulation XIV. Navy installations subject to Title V permitting shall comply with the 

requirements of the Title V Operating Permit Program, which are detailed in 40 CFR Part 70 and all 

specific requirements contained in their individual permits. Title V permitting would be the 

responsibility of the private partner.

3.1.1.4 Hazardous Air Pollutants

Hazardous Air Pollutants (HAPs) are a category of air pollutants that have been shown to have an impact 

on human health but are not classified as criteria pollutants. Examples include certain aromatic and 

chlorinated hydrocarbons, certain metals, and asbestos. HAPs are generated by a number of sources, 

including stationary ones such as dry cleaners, gas stations, combustion sources, and laboratories; 

mobile ones such as automobiles; and area sources such as farms, landfills, construction sites, and 

residential areas. In addition to the NAAQS for criteria pollutants, national standards exist for hazardous 

air pollutants (HAPs), which are regulated under Section 112(b) of the 1990 CAA Amendments. The 

National Emission Standards for Hazardous Air Pollutants regulate HAP emissions from stationary 

sources (40 CFR part 61). A detailed health risk assessment would be required as part of the permitting 

processes to ensure the surrounding population is not exposed to unhealthful levels of HAPs. If 

potentially harmful levels may occur, the SDAPCD may impose limits and prescribe reduction measures, 

such as Toxics-Best Available Control Technologies (T-BACTs), to ensure the health of the surrounding 

area. Adverse health effects of HAPs can be carcinogenic (cancer-causing), short-term (acute) 

noncarcinogenic, and long-term (chronic) noncarcinogenic. Public exposure to HAPs is a significant 

environmental health issue in California.
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3.1.1.5 Greenhouse Gases

GHGs are greenhouse gas emissions that trap heat in the atmosphere. These emissions occur from 

natural processes and human activities. Scientific evidence indicates a trend of increasing global 

temperature over the past century due to an increase in GHG emissions from human activities. The 

climate change associated with this global warming is predicted to produce negative economic and 

social consequences across the globe. 

USEPA issued the Final Mandatory Reporting of Greenhouse Gases Rule on September 22, 2009. GHGs 

covered under the Final Mandatory Reporting of Greenhouse Gases Rule are carbon dioxide (CO2), 

methane, nitrogen oxide (NOX), hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and other 

fluorinated gases including nitrogen trifluoride and hydrofluorinated ethers. Each GHG is assigned a 

global warming potential. The global warming potential is the ability of a gas or aerosol to trap heat in 

the atmosphere. The global warming potential rating system is standardized to CO2, which has a value of 

one. The equivalent CO2 rate is calculated by multiplying the emissions of each GHG by its global 

warming potential and adding the results together to produce a single, combined emissions rate 

representing all GHGs. Under the rule, suppliers of fossil fuels or industrial GHGs, manufacturers of 

mobile sources and engines, and facilities that emit 25,000 metric tons or more per year of GHG 

emissions as CO2e are required to submit annual reports to USEPA.

GHG emissions are also regulated under PSD and Title V permitting programs, which was initiated by a 

USEPA rulemaking issued on June 3, 2010 known as the GHG Tailoring Rule (75 Federal Register 31514). 

GHG emissions thresholds for permitting of stationary sources are an increase of 75,000 tpy of CO2e at 

existing major sources and facility-wide emissions of 100,000 tpy of CO2e for a new source or a 

modification of an existing minor source. The 100,000 tpy of CO2e threshold defines a major GHG source 

for both construction (PSD) and operating (Title V) permitting, respectively. However, on June 23, 2014, 

the U.S. Supreme Court issued its decision in Utility Air Regulatory Group v. USEPA (No. 12-1146). As a 

result of the decision USEPA will no longer apply or enforce federal regulatory provisions or the USEPA 

approved PSD SIP provisions that require a stationary source to obtain a PSD permit if GHGs are the only 

pollutant that the source emits or has the potential to emit above the major source thresholds, or for 

which there is a significant emissions increase and a significant net emissions increase from a 

modification (e.g., 40 CFR section 52.21 (b)(49)(v)). Nor does USEPA intend to continue applying 

regulations that would require that states include in their SIP a requirement that such sources obtain 

PSD permits.

Similarly, USEPA will no longer apply or enforce federal regulatory provisions or provisions of the USEPA 

approved Title V programs that require a stationary source to obtain a Title V permit solely because the 

source emits or has the potential to emit GHGs above the major source thresholds (e.g., the regulatory 

provision relating to GHG subject to regulation in 40 CFR section 71.2). USEPA also does not intend to 

continue applying regulations that would require Title V programs submitted for approval by USEPA to 

require that such sources obtain Title V permits.

There are numerous State plans, policies, regulations, and laws related to GHGs and global climate 

change. The California Global Warming Solutions Act of 2006, widely known as AB 32, requires that the 

CARB develop and enforce regulations for the reporting and verification of statewide GHG emissions. 

CARB is directed to set a GHG emission limit, based on 1990 levels, to be achieved by 2020. The bill 

requires CARB to adopt rules and regulations in an open public process to achieve the maximum 

technologically feasible and cost-effective GHG reductions.
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On April 29, 2015, EO B-30-15 established a California GHG reduction target of 40 percent below 1990 

levels by 2030. The EO aligns California's GHG reduction targets with those of leading international 

governments, including the 28 nation European Union. California is on track to meet or exceed the 

target of reducing greenhouse gas emissions to 1990 levels by 2020, as established in AB 32. California's 

new emission reduction target of 40 percent below 1990 levels by 2030 will make it possible to reach 

the ultimate goal established by EO S-3-05 of reducing emissions 80 percent under 1990 levels by 2050.

As a follow-up to AB 32 and in response to EO-B-30-15, Senate Bill (SB) 32 was passed by the California 

legislature in August 2016 to codify the EO’s California GHG reduction target of 40 percent below 1990 

levels by 2030.

On December 11, 2008, CARB adopted the Scoping Plan (CARB 2008) as directed by AB 32. The Scoping 

Plan proposes a set of actions designed to reduce overall GHG emissions in California to the levels 

required by AB 32. Measures applicable to development projects include those related to energyefficiency building and appliance standards, the use of renewable sources for electricity generation, 

regional transportation targets, and green building strategy. Relative to transportation, the Scoping Plan 

includes nine measures or recommended actions related to reducing vehicle miles traveled and vehicle 

GHGs through fuel and efficiency measures. These measures would be implemented statewide rather 

than on a project by project basis. 

CARB released the First Update to the Climate Change Scoping Plan in May 2014 to provide information 

on the development of measure-specific regulations and to adjust projections in consideration of the 

economic recession (CARB 2014). To determine the amount of GHG emission reductions needed to 

achieve the goal of AB 32 (i.e., 1990 levels by 2020) CARB developed a forecast of the AB 32 Baseline 

2020 emissions, which is an estimate of the emissions expected to occur in the year 2020 if none of the 

foreseeable measures included in the Scoping Plan were implemented. CARB estimated the AB 32 

Baseline 2020 to be 509 million metric tons (MMT) of carbon dioxide equivalents (CO2e). The Scoping 

Plan’s current estimate of the necessary GHG emission reductions is 78 MMT CO2e (CARB 2014). This 

represents an approximately 15 percent reduction. CARB is forecasting that this would be achieved 

through the following reductions by sector: 25 MMT CO2e for energy, 23 MMT CO2e for transportation, 

5 MMT CO2e for high-global warming potential GHGs, and 2 MMT CO2e for waste. The remaining 

23 MMT CO2e would be achieved through Cap-and-Trade Program reductions. This reduction is 

flexible—if CARB receives new information and changes the other sectors’ reductions to be less than 

expected, the agency can increase the Cap-and-Trade reduction (and vice versa).

In response to EO B-30-15 and SB 32, all state agencies with jurisdiction over sources of GHG emissions 

were directed to implement measures to achieve reductions of GHG emissions to meet the 2030 and 

2050 targets. CARB was directed to update the Scoping Plan to reflect the 2030 target and, therefore, is 

moving forward with the update process. The mid-term target is critical to help frame the suite of policy 

measures, regulations, planning efforts, and investments in clean technologies and infrastructure 

needed to continue driving down emissions. CARB is moving forward with a second update to the 

Scoping Plan to reflect the 2030 target set by Executive Order B-30-15 and codified by SB 32. The 2017 

Climate Change Scoping Plan Update, Proposed Strategy for Achieving California’s 2030 Greenhouse Gas 

Target, was released in draft form on January 20, 2017.

In an effort to reduce energy consumption, reduce GHGs, reduce dependence on petroleum, and 

increase the use of renewable energy resources the Navy has implemented a number of renewable 

energy projects. The Navy has established Fiscal Year 2020 GHG emissions reduction targets of 
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34 percent from a FY 2008 baseline for direct GHG emissions and 13.5 percent for indirect emissions. 

Examples of Navy-wide GHG reduction projects include energy efficient construction, thermal and 

photovoltaic solar systems, geothermal power plants, and the generation of electricity with wind 

energy. The Navy continues to promote and install new renewable energy projects.

3.1.2 Affected Environment

Naval Base San Diego (NBSD) is located in San Diego County, which is within the San Diego Intrastate Air 

Quality Control Region (AQCR). The SDAPCD is responsible for implementing and enforcing state and 

federal air quality regulations in San Diego County. San Diego has been determined by the USEPA to be a 

nonattainment area for 8-hour ozone, with a classification of Moderate under the 2008 standard and 

Maintenance under the 1997 standard. San Diego is also on maintenance for CO. The County is classified 

by the USEPA as unclassified/ attainment for all other criteria pollutants. Because San Diego County is in 

nonattainment for ozone and on maintenance for CO, a General Conformity evaluation is required.

The most recent emissions inventory for San Diego County is shown in Table 3-4. VOC and NOx 

emissions are used to represent ozone generation because they are precursors of ozone.

Table 3-4

San Diego County Air Emissions Inventory (2011)

Location NOX

(tpy)

VOC

(tpy)

CO

(tpy)

SO2

(tpy)

PM10

(tpy)

PM2.5

(tpy)

San Diego 42,845 156,407 270,195 1,100 31,251 10,918

Source: EPA, 2013

Key: tpy = tons per year.

Emission sources associated with the existing use of NBSD include civilian and military personal vehicles, 

commercial and military vehicles, and small vessel and tug boat activity along Chollas Creek and the San 

Diego Bay. The existing cogeneration facility owned by Applied Energy operates under a Title V permit 

from the SDAPCD (APCD20089-PTO-960391). Permitted sources include a combustion turbine, duct 

burner, electrical generator, an emergency engine fire pump, and two boilers.

3.1.3 Environmental Consequences

Effects on air quality are based on estimated direct and indirect emissions associated with the action 

alternatives. The Region of Influence (ROI) for assessing air quality impacts is the air basin in which the 

project is located, the San Diego Air Basin.

Estimated emissions from a proposed federal action are typically compared with the relevant national 

and state standards to assess the potential for increases in pollutant concentrations. 

Based on the discussion provided in Section 3.1.1, Regulatory Setting, this analysis is aimed at 

demonstrating the selected Alternative’s potential to interfere with the State’s ability to attain the 

NAAQS.

3.1.3.1 No Action Alternative

Under the No Action Alternative, the Proposed Action would not occur and there would be no near-term 

change to baseline air quality. However, the existing 40-MW cogeneration plant would be 

decommissioned in accordance with the plant’s existing decommissioning plan resulting in minor, 
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localized, short-term effects on air quality. Emission estimates as analyzed in the Categorical Exclusion 

for the Decentralization of the Steam System at Naval Base San Diego are provided in Table 3-5, below. 

(For more information on emissions associated with demolition of the existing cogeneration plant, 

please see the 2013 Categorical Exclusion for the Decentralization of Steam Distribution System at Naval 

Base San Diego.) As shown therein, emissions of pollutants subject to General Conformity are below 

their respective de minimis values. Therefore, no significant impacts to air quality or air resources would 

occur with implementation of the No Action Alternative.

Table 3-5

Estimated Emissions (tons per year) at NBSD and Comparison to General Conformity 

Under No Action Alternative 

Year VOC CO NOX SO2 PM10 PM2.5

2017 0.05 0.43 0.88 0.03 0.05 0.05

2018 0.4 2.03 3.67 0.16 0.44 0.43

General Conformity de minimis 

Threshold 100 100 100 100 100 100

Source: DON, 2013

3.1.3.2 Alternative 1 – Convert Existing 40-MW Cogeneration Plant on Site 1

Potential Impacts

Implementation of Alternative 1 would result in conversion of an existing steam cogeneration plant to a 

natural gas peaker plant at Site 1 at NBSD (refer to Figure 2-1). The retrofit of the existing facility to a 

peaker plant would take up to six months and would be operational no later than August 2018. 

Alternative 1 would result in emissions of air pollutants during both construction and operations. 

Criteria Pollutants

Construction emissions would include emissions associated with off-road and on-road construction 

equipment and worker vehicles. Construction is assumed to begin in 2017 and last approximately six 

months. The main source of operational emissions associated with Alternative 1 would include exhaust 

emissions associated with the natural gas turbine already in use at the existing cogeneration plant. 

However, as stated in 40 CFR 93.153 - Applicability Subsection (d)(1), a conformity determination is not 

required for "The portion of an action that includes major or minor new or modified stationary sources 

that require a permit under the new source review (NSR) program." This is because emissions of all 

permitted sources are, by definition, consistent with the SIP. Therefore, permitted emissions do not 

interfere with the State’s ability to attain the NAAQS and are not considered as contributing to a 

significant air quality impact under NEPA. The stationary sources at the new peaker plant would be 

required to obtain a permit to operate under the USEPA and SDAPCD's New Source Review 

requirements. Emissions associated with the turbine are therefore not subject to the requirements of 

general conformity. Therefore, operational emissions estimated and presented below do not include 

turbine emissions. Additional potential to emit calculations and implications to the permitting process 

have been included in Appendix B to provide both (i) a complete background of the current situation 

and (ii) the emissions information needed to inform the decision(s) to be made.

Table 3-6 shows the estimated construction and operational emissions generated under Alternative 1

that would be subject to General Conformity. Emissions of pollutants subject to General Conformity are 
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below their respective de minimis values; therefore, a Record of Non-Applicability has been prepared 

and is included in Appendix A. Detailed construction and operational assumptions and emissions 

calculations are provided in Appendix C.

Table 3-6

Estimated Emissions (tons per year) at NBSD and Comparison to General Conformity 

Under Alternative 1

Year VOC CO NOX SO2 PM10 PM2.5

Construction – 2017 0.09 0.48 0.74 <0.01 0.05 0.05

Operations – 2018 0.01 0.02 0.01 <0.01 0.01 <0.01

General Conformity 

de minimis Threshold 100 100 100 100 100 100

Source: DON, 2014a

Implementation of Alternative 1 would result in emissions of air pollutants during both construction and 

operations. As shown in Table 3-6 emissions not previously analyzed and/or accounted for via permit

would be below de minimis levels. Therefore, implementation of Alternative 1 would not result in an 

adverse effect related to air quality. 

Hazardous Air Pollutants

Implementation of Alternative 1 would contribute directly to emissions of HAPs from the combustion of 

fossil fuels.

Construction activities would result in short-term, Project-generated emissions of diesel particulate 

matter (DPM) from the exhaust of off-road, heavy-duty diesel equipment. DPM contains gaseous 

hazardous air pollutants including acetaldehyde, acrolein, benzene, 1,3-butadiene, formaldehyde and 

polycyclic aromatic hydrocarbons. The dose to which receptors are exposed is the primary factor used to 

determine health risk. Dose is a function of the concentration of a substance or substances in the 

environment and the duration of exposure to the substance. Thus, the risks estimated for a maximally 

exposed individual (MEI) are higher if a fixed exposure occurs over a longer time period. Health risk 

assessments, which determine the exposure of sensitive receptors to HAP emissions, are typically based 

on a 70-year exposure period; however, such assessments should be limited to the period/duration of 

activities associated with the Project.

There are no sensitive receptors within one-half mile of Site 1. Additionally, as presented earlier in Table 

3-6, maximum daily particulate emissions, which include DPM, would be relatively low when compared 

to the threshold. Furthermore, the construction period would be relatively short (approximately six

months), especially when compared to 70 years. Combined with the highly dispersive properties of 

DPM, construction-related emissions of HAPs would not expose sensitive receptors to substantial 

emissions of HAPs. 

As with criteria pollutants, the main source of operational emissions associated with Alternative 1 would 

include exhaust emissions associated with the natural gas turbine. Details required to accurately 

quantify turbine emissions are not known at this time. Turbine emissions vary based on the efficiency, 

energy output, and annual operating hours. A detailed health risk assessment would be required as part 

of the permitting processes to ensure the surrounding population is not exposed to unhealthful levels of 

HAPs. If potentially harmful levels may occur, the SDAPCD may impose limits and prescribe reduction 
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measures, such as Toxics-Best Available Control Technologies (T-BACTs), to ensure the health of the 

surrounding area. Therefore, implementation of Alternative 1 would not result in an adverse effect

related to HAPs.

Greenhouse Gases

Implementation of Alternative 1 would contribute directly to emissions of GHGs from the combustion of 

fossil fuels. Construction activities would generate approximately 64 metric tons (MT) of CO2e if the 

proposed activities occurred during 2017. Once the facility is operational, the new peaker plant would 

be subject to the requirements of CARB’s Mandatory Reporting Regulation and the USEPA’s Greenhouse 

Gas Reporting Program. CARB’s regulation requires facilities emitting more than 10,000 MT CO2e to 

report their emissions and participate in the Cap-and-Trade program. USEPA’s program requires 

facilities emitting more than 25,000 MT CO2e to report their emissions. As with the Title V and NSR 

permits, reporting the peaker plant’s emissions would be the responsibility of the private partner. 

Details required to accurately quantify turbine emissions are not known at this time. Turbine GHG 

emissions vary based on the efficiency, energy output, and annual operating hours. Current technologies 

are reliably able to achieve an efficiency ranging from 30 to 40 percent. Turbines with efficiencies up to 

60 percent are expected to be commercially available in the next couple of years. Based on the 

assumptions described in Section 2.3, a 50 MW natural gas turbine operating 1,416 hours per year with 

an efficiency of 35 percent would generate approximately 35,000 MT CO2e per year. If the efficiency is 

increased to 60 percent, the emissions drop to approximately 20,000 MT CO2e per year. Likewise, if the 

operating hours or energy output were increased or decreased, so too would the emissions. The 

quantification of the peaker plant’s emissions would be refined by the private partner in the future and 

would be reported and minimized as required by the mandatory reporting regulations issued by CARB 

and the USEPA.

Implementation of Alternative 1 would not result in significant impacts to air quality.

3.1.3.3 Alternative 2 – Natural Gas Peaker Plant on Site 2 

Potential Impacts

Facilities developed under Alternative 2 would be the same as those discussed under Alternative 1; 

however, the proposed natural gas peaker plant would be constructed on an existing paved parking lot 

instead of converting an existing steam cogeneration plant. 

Alternative 2 would result in emissions of air pollutants during both construction and operations similar 

to those estimated for Alternative 1.

Therefore, implementation of this action alternative would not result in significant impacts to air quality.

3.1.3.4 Alternative 3 – Large Integrated Batteries with Photovoltaic System on Site 2

Potential Impacts

Facilities developed under Alternative 3 would involve a large integrated battery facility with a small 

photovoltaic system on Site 2.

Alternative 3 would result in emissions of air pollutants during construction only similar to those 

estimated for Alternative 1. The photovoltaic system would replace the natural gas turbine, thereby 

eliminating the primary source of operations-phase emissions described under Alternative 1.

Conversely, the energy generated by the proposed photovoltaic system would replace the energy 
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consumption provided by burning of fossil fuels, thereby resulting in an indirect reduction of GHG 

emissions.

Therefore, implementation of this action alternative would not result in significant impacts to air quality.

3.1.3.5 Alternative 4 – Full Time Operation of Existing Cogeneration Plant on Site 1

Potential Impacts

Facilities developed under Alternative 4 would involve the continued operation of the existing 40-MW 

cogeneration plant on Site 1. As with Alternative 1, the main source of operational emissions associated 

with Alternative 4 would include exhaust emissions associated with the natural gas turbine. The turbine 

would be required to operate under the requirements of a new, modified, or existing permit. As detailed 

for Alternative 1, emissions of all permitted sources are, by definition, consistent with the SIP. 

Therefore, permitted emissions do not interfere with the State’s ability to attain the NAAQS and are not 

considered as contributing to a significant air quality impact under NEPA. Additional potential to emit 

calculations and implications to the permitting process have been included in Appendix B to provide 

both (i) a complete background of the current situation and (ii) the emissions information needed to 

inform the decision(s) to be made. As shown therein, fulltime operation of the natural gas turbine could 

result in a more than six-fold increase to the emissions released from the turbine when compared to the 

part-time operation assumed under Alternative 1. Alternative 4 would result in emissions of air 

pollutants during operations only, similar to those described for Alternative 1. Decommissioning and 

construction would not occur under this Alternative, which would result in some decrease in 

construction equipment and ultimately, to air emissions. Therefore, implementation of Alternative 4 

would not result in significant impacts to air quality.

3.2 Visual Resources

This discussion of visual resources includes the natural and built features of the landscape visible from 

public views that contribute to an area’s visual quality. Visual perception is an important component of 

environmental quality that can be impacted through changes created by various projects. Visual impacts 

occur as a result of the relationship between people and the physical environment.

3.2.1 Regulatory Setting

3.2.1.1 Naval Base San Diego Installation Appearance Plan

The NBSD Installation Appearance Plan (IAP) provides guidance for the design, development, and review 

of all construction and renovation projects at NBSD. The purpose of the document is to direct new 

development and restoration, as well as protect natural and historic resources. The document also 

includes information related to wayfinding, visual assets and liabilities at NBSD, and recommends 

materials and construction elements be maintained by local resources when possible. The document 

describes NBSD as a coastal plain with relatively flat topography within a highly urbanized section of 

downtown San Diego with no remaining natural features. 

Figure 3-1 identifies vehicular routes and focal points throughout NBSD. The action alternatives are 

located just north of Vesta Street near Pier 6 (Site 1), and between Harbor Drive and the San Diego 

Trolley line, east of Pier 8 (Site 2). The nearest focal point to the action alternatives is at Building 116, 

just northeast of Site 1, which is identified as a “landmark building” in the IAP. The building is considered 

an example of utilitarian industrial building design and is a focal point due to its location at a bend in 
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Affected Environment and Environmental Consequences

Cummings Road and the distinctive twin water towers. The action alternatives are located within areas 

identified as a “visually poor area” and views are identified as poor in the vicinity of Site 1 due to 

intervening buildings. Overhead powerlines are identified in the IAP to the west and east of Site 2.

The following subsections discuss local municipal plans. Although not formally subject to such plans, the 

Navy attempts to substantively comply with them as a matter of policy to the maximum extent 

practicable.

3.2.1.2 State of California Streets and Highway Code

The action alternatives are about 3.2 km (2.0 miles) south of SR-75, which is designated as a scenic 

highway by the State of California. Scenic highways are regulated at the state level by Sections 260–284 

of the Streets and Highway Code State of California 2014. Section 261 of the code requires local 

agencies to take actions to protect the scenic appearance of the scenic corridor, which includes the land 

adjacent to the highway right-of-way. These actions may include (1) regulations of land use and intensity 

(density) of development; (2) detailed land and site planning; (3) control of outdoor advertising; 

(4) careful attention to and control of earthmoving and landscaping; and (5) the design and appearance 

of structures and equipment.
Vehicular Routes and Focal Points at NBSD

NAVAL BASE SAN DIEGO

Figure 3-1

I:\PROJECTS\N\NAV\NAV-03.10_EnergySecurity\Map\EA_NBSD\Fig3_1_VehicularRoutes.indd NAV-03.10 12/12/16 -EV

Source: Naval Base San Diego Installation Appearance Plan, 2008

0 750m

Site 1

Site 2
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3.2.1.3 City of National City General Plan 

The southern portion of NBSD is within the limits of the City of National City and is identified as part of 

the Harbor District. The City’s Land Use Element of the General Plan includes goals and policies to 

preserve scenic resources and important viewsheds. Policies encourage building placement, orientation, 

height, and mass to maintain and enhance views of San Diego Bay. Three visual “Major Gateways” are 

identified at the northern and southern City limit at Interstate 805 (I-805) and at Interstate 5 (I-5) at the 

western terminus of State Route 54 (SR-54). Each of these visual “Major Gateways” is more than 2.4 km 

(1.5 miles) from the action alternative sites.

3.2.1.4 City of San Diego General Plan

The northern portion of NBSD is within the limits of the City of San Diego. The City’s General Plan 

includes several elements that address or support the protection of scenic views and community 

character. The Land Use and Community Planning Element states that Open Space land uses are 

intended partly for the preservation of distinctive scenic features. The Mobility Element of the General 

Plan, which guides the future of the City’s transportation network, notes that scenic vistas of coastline, 

canyons, and other open spaces improve the traveling experience and can be protected by working with 

Caltrans to pursue official scenic highway designations. Scenic lookouts are encouraged to be protected 

by providing adequate rights-of-way and obtaining scenic easements to ensure the preservation of 

scenic views. Scenic viewing areas in the City are also found at recreational areas, including regional 

parks and along trails at outlook areas.

A component of the City’s General Plan is community plans for the various communities throughout the 

City. Site 1 is located partially within the Barrio Logan community. The Barrio Logan Community Plan 

does not include major vista points due to the community’s location on a low-lying coastal plain less 

than 18.3 meters (60 feet) in elevation. However, the community plan identifies critical view corridors to 

San Diego Bay, the nearest of which is about 1.6 km (1 mile) north of Site 1 along 32nd Street facing 

west at I-5.

3.2.1.5 Port of San Diego Master Plan

The proposed action alternatives are located in proximity to Port lands along the San Diego Bay and 

borders Planning District 5: National City Bayfront, located immediately south of the action alternatives. 

The Port of San Diego Master Plan identifies Vista Areas throughout the San Diego Bayfront, which are 

points of natural visual beauty intended to be preserved and enhanced. Designated Vista Areas within 

Planning District 5 near the Proposed Action include one Vista Area facing the San Diego Bay along the 

Sweetwater Channel from Tidelands Avenue, which is more than 3.2 km (2 miles) south of the proposed 

action alternatives.

3.2.2 Affected Environment

Project Viewshed

For the action alternatives, the visual resources ROI include the areas from which the proposed facilities 

could be readily viewed by the public. The ROI for visual resources of the Proposed Action includes 

viewsheds of NBSD, which are generally limited for both sites as they are within a military base that is 

mostly inaccessible to the general public. Areas west of Harbor Drive are not accessible to the public; 

however, Harbor Drive and areas east, which are part of NBSD, are accessible to the public. 
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Site 1 is located about 0.4 km (0.25 mile) west of Harbor Drive near the San Diego Bay within an area not 

accessible to the public. Due to the restricted access of Site 1, flat topography, and intervening 

development at NBSD, views of Site 1 are unavailable from public areas. Site 2 is located east of Harbor 

Drive, just east of the intersection with 4th Street and about 0.8 km (0.5 mile) south of Site 1. Due to the 

site’s proximity to Harbor Drive, a public roadway, Site 2 is visible to the public in eastern-facing views as 

they head north and south along Harbor Drive. Areas further east of Site 2 are not accessible to the 

public due to the elevated I-5 and public views of Site 2 occur primarily from along Harbor Drive.

3.2.2.1 Visual Environment

Existing Visual Character/Quality

Visual character is defined by descriptive attributes in the landscape. Natural and artificial landscape 

features contribute to the visual character of both regional areas and specific viewpoints. Visual 

character is influenced by geologic, hydrologic, botanical, wildlife, recreational, and urban features. 

Urban features include those associated with development such as structures, roads, utilities, 

earthworks, and the results of other human activities. The perception of visual character can vary 

seasonally, even hourly, as weather, light, shadow, and elements that compose the viewshed change. 

The basic elements used to describe visual character for most visual assessments are the form, line, 

color, and texture of landscape features. The appearance of the landscape is described in terms of 

dominance of these components.

Site 1 includes the existing 40-MW steam cogeneration plant and the area is dominated by several large 

parking lots and industrial development along the San Diego Bay. The character of the area is heavily 

industrial and is developed with various buildings (mostly single-story), outdoor storage areas, and 

paved parking lots. There is a large dry dock area immediately north of Site 1, and includes cranes and 

construction equipment associated with ship construction and maintenance. There is minimal 

landscaping, street trees, or natural areas near Site 1. 

Site 2 is located in a storage area for cars, trucks, and large metal shipping containers. The site is 

adjacent and west of existing railroad tracks and military sports fields (e.g., football and baseball fields) 

and is comprised of a large flat area used for parking that consists of dirt and gravel. In general, the 

surrounding area includes limited landscaping; however, the eastern edge of Harbor Drive is 

intermittently lined with street trees. Overhead powerlines, utility poles, and roadside billboards are 

also located around Site 2 and contribute to the industrial character of the area. Due to the location of 

Site 2 adjacent to a public roadway (Harbor Drive), some views from motorists along Harbor Drive are 

anticipated. Also, Harbor Drive as it passes by Site 2, is included as Segment 4 of the Bayshore Bikeway 

Plan, which was developed in 2006 as a 24-mile bikeway route around San Diego Bay. Bicyclists along 

the Bayshore Bikeway are anticipated to have some views of Site 2. As there are no other public viewing 

areas along Harbor Drive in the vicinity of Site 2, prolonged or extended views onto Site 2 are limited 

and would mostly be experienced briefly while moving along Harbor Boulevard by car or bicycle. Views 

from residential areas east of I-5 do not include views of Site 2 due to the elevated nature of I-5.

The discussion of viewer groups and viewer response is described below from the perspective of 

off-Base public viewers. Overall, off-Base views are either precluded by intervening landscaping and 

development or by distance as public areas are separated by I-5. 
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Viewer Groups

Development activity surrounding the two action alternative sites includes a mixture of public and 

private lands and streets; however, views of the Proposed Action from public areas are generally 

unavailable. Site 1 is generally not noticeable from public areas near the site due to the generally flat 

topography in the immediate and surrounding areas, distance, and intervening development. Because 

Site 1 and surrounding areas are flat, expansive views in the vicinity are generally unavailable with the 

exception of elevated portions of I-5, located about 1.2 km (0.75 mile) east of Site 1. Views of Site 1 are 

not available from elevated portions of I-5 due to distance and industrial development that interrupts 

views onto Site 1 and the San Diego Bay. Site 2 is located adjacent to a public roadway (Harbor Drive) 

and views are available for motorists and recreationalists (e.g., bicyclists). Based on the regulatory 

environment, this analysis focuses primarily on vehicular and recreational viewer groups as these 

viewers are likely to be composed of residents and tourists. 

Viewer Response

Existing Viewer Sensitivity

Viewer sensitivity is used as an evaluation term to discuss viewer concern for, and response to, changes 

in the visual landscape. The viewer’s individual association with the environment can help determine 

their sensitivity to change as can their activity while viewing, so it is important to determine whether 

their views are incidental or sought-after. Activities such as commuting in heavy traffic can distract an 

observer from many aspects of the visual environment. On the other hand, recreational driving can 

encourage the examination of a landscape at greater length, thereby increasing the observer’s attention 

to detail. For the purposes of this evaluation, sensitivity ratings have been based on viewer group 

activity and the levels of awareness typically associated with that group.

Existing Viewer Exposure

Viewer exposure is assessed by measuring the number of viewers experiencing potential changes in 

their visual environment. Those viewers are sorted by type of activity, duration of view, speed at which 

the viewer is travelling, and the resulting positions of the viewer relative to the proposed changes. 

Typically, viewer exposure would be characterized as low, if less than 100 viewers daily; moderate if 

between 100 and 1,000 viewers; or high when greater than 1,000 viewers daily. Applied to the highest 

frequency viewers outlined previously, viewer exposure for the Proposed Action at Site 1 would be low, 

as views of the area are generally unavailable from surrounding areas outside of the Base. Viewer 

exposure for the Proposed Action at Site 2 would be higher compared to Site 1 due to the location along 

a public roadway which is visible to more than 1,000 motorists and bicyclists each day as they pass along 

Harbor Drive.

Viewer Awareness

Anticipated viewer awareness is determined based on the degree to which a viewer group is receptive 

to the visual details, character, and quality of the surrounding landscape. A viewer’s ability to perceive 

the landscape is affected by their activity on the landscape. For example, non-local recreationists may 

take pleasure in sightseeing and observing the landscape; residents may be strongly attached to the 

view from their homes; and a commuter travelling through the area may not perceive any change, but 

may also be as perceptive to the landscape as a resident (ancillary exposure on a daily basis results in 

mixed reactions and perceptions).
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Landscape Units

National City Landscape Unit

Due to the flat topography of the area, views of NBSD from areas in National City are generally limited to 

elevated portions of I-5, directly east of NBSD, as well as along Harbor Drive, which is surrounded by 

NBSD in the vicinity of the action alternatives. Areas further east of I-5 include single-family residential 

neighborhoods with one- and two-story buildings that do not have views of NBSD due to the elevated 

I-5 freeway, which block views onto the Base and onto the action alternative sites. Distant views of 

NBSD are unavailable from SR-75, about 3.2 km (2 miles) north of the action alternatives. The dominant 

features from SR-75 include the San Diego Bay and views of Coronado and downtown San Diego. 

Barrio Logan Community Landscape Unit

NBSD is located partially in City of San Diego in the Barrio Logan community. The Barrio Logan 

Community Plan identifies view corridors towards the San Diego Bay along several east-west roadways; 

however, none of the designated view corridors are oriented towards the NBSD. The nearest designated 

view corridor is along Sicard Avenue, located more than 2.4 km (1.5 miles) from the action alternative 

sites. The nearest public roadway to the action alternatives in the Barrio Logan community is Harbor 

Drive; however, the action alternative sites are not visible along Harbor Drive within Barrio Logan. As 

such, views of the action alternatives are not available from Barrio Logan.

3.2.3 Environmental Consequences

The evaluation of visual resources in the context of environmental analysis typically addresses the 

contrast between visible landscape elements. Collectively, these elements comprise the aesthetic 

environment, or landscape character. The landscape character is compared to the Proposed Action’s 

visual qualities to determine the compatibility or contrast resulting from the buildout and demolition 

activities associated with the Proposed Action.

3.2.3.1 Approach to Analysis

The discussion of visual conditions was described using distance qualifiers; that is, elements observed in 

the visual environment are discussed relative to their placement in the view as being at a foreground, 

middleground, and background distance. For the purposes of this assessment, these distance categories 

were defined as follows:

• Foreground – less than 0.8 km (0.5 mile) from the viewer

• Middleground – between 0.8 km and 1.6 km (0.5 mile and 1 mile) from the viewer

• Background – more than 1.6 km (1 mile) from the viewer

To better understand existing conditions and potential viewer response, Key Views (Landscape Units) 

were selected based on a composite evaluation of the preceding project and corridor analyses. Two Key

Views were selected for their ability to simultaneously represent existing conditions and authentically 

depict the proposed effects of project implementation.

When considering potential visual impact, compatibility with surrounding visual character has the 

greatest influence on how the new element would be perceived by viewers in the landscape. The second 

primary factor is viewer sensitivity or the extent of viewer concern for, and the response to, changes in 

the visual landscape. The viewer’s individual association with the environment can help determine 

whether their views are incidental or sought-after. Activities such as commuting in heavy traffic can 
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distract an observer from many aspects of the visual environment while recreational driving can 

encourage the examination of a landscape at greater length. For the purposes of this evaluation, 

sensitivity ratings have been based on viewer group activity and the levels of awareness typically 

associated with that group.

Viewer sensitivity is influenced by the setting: viewers in recreational areas are considered to have high 

sensitivity to visual change; motorists along SR-75 are considered to have moderate to moderately high 

sensitivity to visual resources due to the scenic nature of SR-75, and its highway designation. Residential 

viewers are generally considered to have moderately high to high sensitivity when homes are located 

adjacent to a future development. However, because private views are generally not accessible to the 

public, residential viewers were considered as members of other viewer groups (e.g., motorists or 

recreationalists).

Existing operations at NBSD include training and support facilities, including an existing steam 

cogeneration plant and other industrial-related improvements (e.g., shipbuilding and related 

infrastructure). Viewers on-Base currently are, and are likely to remain, primarily military personnel 

associated with military activities and their support. Therefore, the visual characteristics of the proposed 

facilities would be consistent with the expectations of most on-Base viewers; no further discussion of 

on-Base viewers or viewsheds is included. 

3.2.3.2 No Action Alternative

Under the No Action Alternative, the Proposed Action would not occur and the existing steam 

cogeneration plant would be decommissioned and removed from Site 1. (For information on visual 

impacts associated with demolition of the existing cogeneration plant, please see the 2013 Categorical 

Exclusion for the Decentralization of Steam Distribution System at Naval Base San Diego.) Removal of 

the existing steam cogeneration plant would tend not to be visually noticeable from public areas and the 

existing visual character and quality of NBSD as an operating military base would remain similar to 

existing conditions. No significant impacts would occur with implementation of the No Action 

Alternative.

3.2.3.3 Alternative 1 – Upgrade Existing 40-MW Cogeneration Plant on Site 1

Proposed Visual Character/Quality

Implementation of Alternative 1 would result in upgrading the existing steam cogeneration plant to a 

natural gas peaker plant at Site 1. While specific development plans for the natural gas peaker plant are 

not currently developed, the proposed peaker plant would generally consist of a system of gas turbines 

that burn natural gas. Associated facilities would commonly include large tanks to store demineralized 

water and ammonia, an exhaust stack, equipment enclosures, transformers, and other associated 

equipment within about a 30-meter (100 foot) by 15-meter (50 foot) area. The tallest point of the 

proposed natural gas peaker plant is expected to not exceed 15 meters (50 feet) in height (e.g., the 

exhaust stack), which would be similar to the existing steam cogeneration plant, which is between 12.2 

and 15.2 meters (40-50 feet in height). The site and surrounding areas generally consist of large paved 

concrete areas with parking, roadways, the existing steam cogeneration plant, and several buildings at 

NBSD, each of which contribute to the military and industrial character and quality of Site 1. The 

proposed natural gas peaker plant would generally appear similar in size and scale to the existing steam 

cogeneration plant, and would continue to appear as an industrial development on NBSD, similar to the 

existing visual character. Also, the proposed peak plant would be designed in accordance with the IAP
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and would be earth-tone. No other improvements in the area are associated with Alternative 1. As there 

is limited off-Base visibility of the existing steam cogeneration plant, upgrading to a peaker plant would 

not substantially alter existing views from off-site areas. The profile and scale of the new facilities would 

generally be unnoticed from any of the landscape units described above as none of the landscape units 

are within 0.8 km (0.5 mile) of Site 1. Therefore, implementation of Alternative 1 would not result in 

significant impacts to visual resources.

Change to Visual Character/Quality and Anticipated Viewer Response

National City Landscape Unit

No views would be altered by the construction of the proposed upgrades to the existing steam 

cogeneration plant from views in the adjacent residential neighborhood in National City. Because views 

into NBSD from adjacent areas are mostly precluded by intervening development and the elevated I-5, 

viewer sensitivity, exposure, and awareness is anticipated to be low.

Barrio Logan Community Landscape Unit

The replacement of the existing steam cogeneration plant with natural gas peaker plant would not be 

visible from public areas within Barrio Logan, which are located over 1.6 km (1 mile) north of the action 

alternative sites. Foreground and middleground western-facing views from Barrio Logan are focused on 

the San Diego Bay, which would not be affected by construction and operation of Alternative 1. 

Background views from Barrio Logan are generally limited, and viewer sensitivity, exposure, and 

awareness is considered to be low and visual changes would not be noticed.

Conclusion

Implementation of Alternative 1 would require the use of construction equipment, construction traffic, 

and stockpiled materials; however, due to the distance of Site 1 from any surrounding areas outside of 

NBSD, as well as intervening development and landscaping, no appreciable visual impact would be

anticipated during construction. Viewers would not likely notice site changes during construction, and 

construction activities at Site 1 associated with Alternative 1 would not result in significant impacts to 

visual resources.

Alternative 1 would not result in a noticeable change to existing conditions on-Base from any of the 

landscape units described above, including the Barrio Logan community or City of National City. No 

significant impacts to visual resources would occur if Alternative 1 is implemented.

3.2.3.4 Alternative 2 – Natural Gas Peaker Plant on Site 2 

Facilities developed under Alternative 2 would be the same as those discussed under Alternative 1; 

however, the proposed natural gas peaker plant would be constructed on an existing parking lot instead 

of converting an existing cogeneration plant. Development layout, structure heights, color, and project 

scale would be similar to Alternative 1. Site 2 is located about 0.5 km (0.33 mile) south and east of Site 1. 

While views onto Site 2 would be more accessible to the public when compared to Alternative 1, 

implementation of Alternative 2 would not result in any significant impacts to visual resources. 

National City Landscape Unit

Similar to the discussion for Alternative 1, views of Site 2 are not available from residential areas in 

National City due to distance, intervening landscaping, and the elevated I-5. Views within National City 

along Harbor Drive do include views of Site 2 and construction and operation of the proposed natural 
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gas peaker plant would be briefly visible from motorists and bicyclists travelling along Harbor Drive. 

Views headed northbound along Harbor Drive do not offer expansive views due to the presence of 

mature street trees along the eastern edge of Harbor Drive. Views from motorists and passengers and 

bicyclists headed southbound on Harbor Drive would have views onto Site 2 within about 152 meters 

(500 feet) of approaching the site. Foreground views of construction equipment and vehicles would 

temporarily be visible within the 152 meters (500 feet) approaching Site 2. Once constructed, views 

would change from a parking lot in an industrial area to a natural gas peaker plant within an industrial 

area that would continue to be surrounded by parking areas for trucks and vehicles, overhead 

powerlines, and billboards. No middleground or background views of Site 2 are available, including from 

Harbor Drive. While foreground views would change with development of the proposed peaker plant 

under Alternative 2, impacts on visual character and quality would remain less than significant as viewer 

sensitivity is considered to be low and because the existing visual character and quality would continue 

similar to the existing condition. 

Barrio Logan Landscape Unit

Due to distance and the views of the San Diego Bay in the foreground and middleground, background 

views from the Barrio Logan Landscape Unit would not be available and would be similar to 

Alternative 1.

Conclusion

Similar to Alternative 1, implementation of Alternative 2 would require the use of construction 

equipment and other contractor vehicles; however, construction activities would not be visible from the 

landscape units discussed above. The completed project area would be cleaned up after construction; 

however, viewers would see construction activities from automobiles and/or bicycles as they pass by 

along Harbor Drive. While construction and operation of the facilities would be visible along portions of 

Harbor Drive, the existing visual character and quality of the surrounding industrial development would 

not be significantly changed and no significant impacts to visual resources would occur.

3.2.3.5 Alternative 3 – Large Integrated Batteries with Photovoltaic System on Site 2 

Facilities developed under Alternative 3 would involve a large integrated battery facility with a small 

photovoltaic system on Site 2. The development layout, scale, and structure heights would generally be 

similar or smaller than the development included in Alternatives 1 and 2. Each container housing the 

large integrated batteries would be painted with earth-tone colors to blend in with the surrounding 

environment. Similar to the discussion for Alternative 2, implementation of Alternative 3 would not 

result in any significant impacts to visual resources.

National City Landscape Unit

As discussed for Alternative 2, views of Site 2 are not available from residential areas in National City 

due to distance, the elevated I-5, and development. Foreground view of Site 2 are available from Harbor 

Drive, which would experience a noticeable change from an existing parking lot to a large integrated 

battery facility with photovoltaic panel; however, foreground views would continue to appear as an 

industrial area and changes would not represent a significant impact.

Barrio Logan Landscape Unit

Due to distance of public areas in Barrio Logan, views would not be substantially altered and would be 

similar to Alternative 2.
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Conclusion

Similar to Alternative 2, implementation of Alternative 3 would require the use of construction 

equipment and other contractor vehicles and construction activities would be visible in the foreground 

from Harbor Drive. Viewer sensitivity of motorists is expected to be low and visual changes would 

remain industrial in nature as a result of Alternative 3. Thus, visual resource impacts would remain less 

than significant.

3.2.3.6 Alternative 4 – Full Time Operation of Existing Cogeneration Plant on Site 1 

Implementation of Alternative 4 would result in maintaining the existing steam cogeneration plant at 

Site 1. The development layout, scale, and structure heights would be similar to existing conditions. 

Similar to the discussion for Alternative 1, implementation of Alternative 4 would not result in any 

significant impacts to visual resources.

National City Landscape Unit

No views would be altered by the continued use of the existing steam cogeneration plant from views in 

the adjacent residential neighborhood in National City. Because views into NBSD from adjacent areas 

are mostly precluded by intervening development and the elevated I-5, viewer sensitivity, exposure, and 

awareness is anticipated to be low.

Barrio Logan Community Landscape Unit

The continued use of the existing steam cogeneration plant would not be visible from public areas 

within Barrio Logan, which are located over 1.6 km (1 mile) north of the action alternative sites. 

Foreground and middleground western-facing views from Barrio Logan are focused on the San Diego 

Bay, which would not be affected by construction and operation of Alternative 4. Background views 

from Barrio Logan are generally limited, and viewer sensitivity, exposure, and awareness is considered 

to be low and visual changes would not be noticed.

Conclusion

Implementation of Alternative 4 would not require the use of construction equipment and other 

contractor vehicles as the existing cogeneration plant would continue similar to existing conditions. 

Viewshed modification would be less than Alternative 1 as there are no upgrades proposed under 

Alternative 4. Thus, no significant impacts to visual resources would occur under Alternative 4.

3.3 Noise

This section describes the existing and projected noise levels for the project area, and also analyzes

potential impacts to the ambient sound environment that may occur with implementation of the 

alternatives.

The following discussion is based on a review of relevant state and local regulations, current planning 

documents, and available literature for similar construction and operational activities, including the 

following:

• Acoustical Assessment Report for Calpeak Border (Pacific Noise Control, June 2001)

This discussion of noise includes the types or sources of noise and the associated sensitive receptors in 

the human environment. Noise in relation to biological resources and wildlife species is discussed in the 

Biological Resources section.
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Sound is a physical phenomenon consisting of minute vibrations that travel through a medium, such as 

air or water, and are sensed by the human ear. Sound is all around us. The perception and evaluation of 

sound involves three basic physical characteristics:

• Intensity – the acoustic energy, which is expressed in terms of sound pressure, in decibels (dB)

• Frequency – the number of cycles per second the air vibrates, in Hertz (Hz)

• Duration – the length of time the sound can be detected

Noise is defined as unwanted or annoying sound that interferes with or disrupts normal human 

activities. Although continuous and extended exposure to high noise levels (e.g., through occupational 

exposure) can cause hearing loss, the principal human response to noise is annoyance. The response of 

different individuals to similar noise events is diverse and is influenced by the type of noise, perceived 

importance of the noise, its appropriateness in the setting, time of day, type of activity during which the 

noise occurs, and sensitivity of the individual. While aircraft are not the only sources of noise in an urban 

or suburban environment, they are readily identified by their noise output and are given special 

attention in this EA.

3.3.1 Basics of Sound and A-Weighted Sound Level

The loudest sounds that can be detected comfortably by the human ear have intensities that are a 

trillion times higher than those of sounds that can barely be detected. This vast range means that using 

a linear scale to represent sound intensity is not feasible. The dB is a logarithmic unit used to represent 

the intensity of a sound, also referred to as the sound level. All sounds have a spectral content, which 

means their magnitude or level changes with frequency, where frequency is measured in cycles per 

second or Hz. To mimic the human ear’s non-linear sensitivity and perception of different frequencies of 

sound, the spectral content is weighted. For example, environmental noise measurements are usually 

on an “A-weighted” scale that filters out very low and very high frequencies in order to replicate human 

sensitivity. It is common to add the “A” to the measurement unit in order to identify that the 

measurement has been made with this filtering process (dBA). In this document, the dBA unit refers to 

A-weighted sound levels. Table 3-7 provides a comparison of how the human ear perceives changes in 

loudness on the logarithmic scale.

Table 3-7

Subjective Responses to Changes in A-Weighted Decibels

Change Change in Perceived Loudness

3 dBA Barely perceptible

5 dBA Quite noticeable

10 dBA Dramatic – twice or half as loud

20 dBA Striking – fourfold change

Figure 3-2 (Cowan, 1994) provides a chart of A-weighted sound levels from typical noise sources. Some 

noise sources (e.g., air conditioner, vacuum cleaner) are continuous sounds that maintain a constant 

sound level for some period of time. Other sources (e.g., automobile, heavy truck) are the maximum 

sound produced during an event like a vehicle pass-by. Other sounds (e.g., urban daytime, urban 

nighttime) are averages taken over extended periods of time. A variety of noise metrics have been 

developed to describe noise over different time periods, as discussed below.
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3.3.2 Noise Metrics

A metric is a system for measuring or quantifying a particular characteristic of a subject. Since noise is a 

complex physical phenomenon, different noise metrics help to quantify the noise environment. The 

noise metrics used in this EA are described below. While the Day-Night Average Sound Level (DNL) and 

Community Noise Equivalent Level (CNEL) noise metrics are the most commonly used tools for analyzing 

noise generated. These supplemental metrics and analysis tools provide more detailed noise exposure 

information for the decision process and improve the discussion regarding noise exposure.

3.3.2.1 Day-Night Average Sound Level

The DNL metric is the energy-averaged sound level measured over a 24-hour period, with a 10 dBA

penalty assigned to noise events occurring between 10 p.m. and 7 a.m. (acoustic night). DNL values are 

average quantities, mathematically representing the continuous sound level that would be present if all 

of the variations in sound level that occur over a 24-hour period were averaged to have the same total 

sound energy. The DNL metric quantifies the total sound energy received and is therefore a cumulative 

measure, but it does not provide specific information on the number of noise events or the individual 

sound levels that occur during the 24-hour day. DNL is the standard noise metric used by the U.S.

Department of Housing and Urban Development, FAA, USEPA, and DoD. Studies of community 

annoyance in response to numerous types of environmental noise show that DNL correlates well with 

impact assessments; there is a consistent relationship between DNL and the level of annoyance. Most 

people are exposed to sound levels of 50 to 55 DNL or higher on a daily basis.

Research has indicated that about 87 percent of the population is not highly annoyed by outdoor sound 

levels below 65 dBA DNL (Federal Interagency Committee on Urban Noise, 1980).
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Figure 3-2 A-Weighted Sound Levels from Typical Sources

3.3.2.2 Community Noise Equivalent Level

CNEL is a noise metric adopted as a standard by the state of California. The CNEL metric is similar to the 

DNL metric and is also an energy-averaged sound level measurement. DNL and CNEL provide average 

noise levels taking into consideration and applying penalties for annoyance from intrusive events that 

occur during evening and nighttime hours. Both DNL and CNEL are measures of cumulative noise 

exposure over a 24-hour period, with adjustments to reflect the added intrusiveness of noise during 

certain times of the day. However, while DNL considers one adjustment period, CNEL reflects two 

adjustment periods. DNL includes a single adjustment period for night, in which noise levels at night 

(defined as 10 p.m. to 7 a.m.) include an added weighting of 10 dBA. CNEL adds a second adjustment 

period where noise levels in the evening (defined as 7 p.m. to 10 p.m.) are given a weighting of 5 dBA.
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3.3.2.3 Equivalent Sound Level

A cumulative noise metric useful in describing noise is the Equivalent Sound Level (LEQ). LEQ is the 

continuous sound level that would be present if all of the variations in sound level occurring over a 

specified time period were smoothed out as to contain the same total sound energy. The same 

calculation for a daily average time period such as DNL or CNEL but without the penalties is a 24-hour 

equivalent sound level, abbreviated LEQ. Other typical time periods for LEQ are 1 hour and 8 hours.

3.3.2.4 Maximum Sound Level

The highest A-weighted sound level measured during a single event where the sound level changes 

value with time is called the maximum A-weighted sound level or LMAX. LMAX defines the maximum sound 

level occurring for a fraction of a second. 

3.3.2.5 Number of Events Above a Threshold Level

The “Number of Events Above a Threshold Level” metric provides the total number of noise events that 

exceed a selected noise level threshold during a specified period of time (DoD Noise Working Group, 

2009). Combined with the selected noise metric, LMAX or SEL, the Number of Events Above metric is 

symbolized as NAXX metric (NA = number of events above, XX = dBA level, metric = LMAX or SEL). For 

example, the LMAX and SEL Number of Events Above metrics are symbolized as NA75LMAX and NA75SEL, 

respectively, with 75 dBA as the example dBA level. In this EA, an LMAX threshold is selected to analyze 

speech interference and an SEL threshold is selected for analysis of sleep disturbance.

3.3.3 Noise Effects

An extensive amount of research has been conducted regarding noise effects including annoyance, 

speech interference, sleep disturbance, noise-induced hearing impairment, nonauditory health effects, 

performance effects, noise effects on children, effects on domestic animals and wildlife, property values, 

structures, terrain, and archaeological sites. These effects are summarized below.

3.3.3.1 Annoyance

As previously noted, the primary effect of noise on exposed communities is long-term annoyance, 

defined by USEPA as any negative subjective reaction on the part of an individual or group. The scientific 

community has adopted the use of long-term annoyance as a primary indicator of community response 

and there is a consistent relationship between DNL/CNEL and the level of community annoyance 

(Federal Interagency Committee on Noise, 1992).

3.3.3.2 Potential Hearing Loss

People living in high noise environments for an extended period of time (40 years) can be at risk for 

hearing loss called Noise Induced Permanent Threshold Shift (NIPTS). The NIPTS defines a permanent 

change in hearing level, or threshold, caused by exposure to noise (United States Environmental 

Protection Agency, 1982). According to USEPA (1974), changes in hearing level of less than 5 dBA are 

generally not considered noticeable. There is no known evidence that an NIPTS of less than 5 dBA is 

perceptible or has any practical significance for the individual affected. Furthermore, the variability in 

audiometric testing is generally assumed to be plus or minus 5 dBA. The preponderance of available 

information on hearing loss risk is from the workplace with continuous exposure throughout the day for 

many years.
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Based on a report by Ludlow and Sixsmith (1999), there were no major differences in audiometric test 

results between military personnel, who as children, had lived in or near installations where fast jet 

operations were based, and a similar group who had no such exposure as children. Hence, for the 

purposes of this EA, the limited data are considered applicable to the general population, including 

children, and are used to provide a conservative estimate of the risk of potential hearing loss.

DoD policy directive requires that hearing loss risk be estimated for the at-risk population, defined as 

the population exposed to DNL greater than or equal to 80 dBA (Department of Defense [DoD], 2009). 

However, it should be recognized that characterizing noise exposure in terms of DNL and CNEL 

overestimates hearing loss risk but suffices when nighttime operations are 5 percent or less than the 

total operations. When nighttime operations are greater than 5 percent, LEQ is recommended for 

calculating potential hearing loss since hearing loss is a physical phenomenon due to the sound level and 

independent of annoyance. Thus, the additional penalties applied by CNEL for evening and nighttime 

operations do not accurately portray the NIPTS.

3.3.3.3 Speech Interference

Speech interference can cause disruption of routine activities, such as enjoyment of radio or television 

programs, telephone use, or family conversation, giving rise to frustration or irritation. In extreme cases, 

speech interference may cause fatigue and vocal strain to individuals who try to communicate over the 

noise.

3.3.3.4 Classroom Criteria and Noise Effects on Children

Research suggests that environments with sustained high background noise can have variable effects, 

including effects on learning and cognitive abilities and various noise-related physiological changes. 

Analyses for school-aged children are similar to speech interference by using the indoor number of 

events exceeding 50 dBA LMAX, but also has the added restriction of using an outdoor equivalent noise 

level of 60 dBA LEQ. This represents a level that a person with normal hearing can clearly hear a speaker 

(teacher) speaking at a level of 50 dBA indoors in a classroom setting.

3.3.3.5 Sleep Disturbance

The disturbance of sleep is a major concern for communities exposed to nighttime noise.

3.3.3.6 Workplace Noise

In 1972, the National Institute for Occupational Safety and Health (NIOSH) published a criteria document 

with a recommended exposure limit of 85 dBA as an 8-hour time-weighted average. This exposure limit 

was reevaluated in 1998 when NIOSH made recommendations that went beyond conserving hearing by 

focusing on the prevention of occupational hearing loss. Following the reevaluation using a new risk 

assessment technique, NIOSH published another criteria document in 1998, which reaffirmed the 

85 dBA recommended exposure limit (NIOSH, 1998).

3.3.4 Nonauditory Health Effects

Studies have been conducted to examine the nonauditory health effects of noise exposure, focusing 

primarily on stress response, blood pressure, birth weight, mortality rates, and cardiovascular health. 

Exposure to noise levels higher than those normally produced in the community can elevate blood 
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pressure and also stress hormone levels. However, the response to such loud noise is typically short in 

duration: after the noise goes away, the physiological effects reverse and levels return to normal. 

3.3.4.1 Noise Effects on Children

Scientific literature suggests that environments with sustained high background noise can have variable 

effects, including effects on learning and cognitive abilities and various noise-related physiological 

changes. Research on the impacts of noise in general on the cognitive abilities of school-aged children 

has received more attention in recent years. 

3.3.4.2 Noise Effects on the Elderly

Based upon a study by the Harvard School of Public Health, older people exposed to noise, especially at 

higher levels, may experience an increased risk of hospitalization for cardiovascular disease (BMJ, 2013).

3.3.5 Noise Modeling

To evaluate potential noise impacts due to construction under the proposed alternatives, reference 

noise levels were obtained from the Federal Highway Administration (FHWA) Roadway Construction 

Noise Model (RCNM) User’s Guide, which provides a comprehensive assessment of noise level usage 

factors for construction equipment. Based on the list of equipment proposed for construction and

demolition, maximum noise emission levels were defined based on the reference values in the guide, 

and potential combined equipment levels at various distances were estimated. The algorithm in the 

model considers construction equipment noise specification data, usage factors, and the relative 

distances of the noise sensitive receptor to the source of noise.

Assumptions for construction equipment include the following for each phase:

• Demolition: 1 dozer, 1 concrete saw, 2 tractors/loaders/backhoes

• Site Preparation: 1 Grader, 1 tractor/loader/backhoe

• Grading: 1 dozer, 1 concrete saw, 2 tractors/loaders/backhoes

• Construction: 1 crane, 2 forklifts, 2 tractors/loaders/backhoes

• Coatings: 1 air compressor

• Paving: 1 Paver, 4 cement/mortar mixers, 1 roller, 1 tractor/loader/backhoe

To analyze potential effects from operation of the peaker plant, reference noise source data was used 

from a technical report for a similar facility (Pacific Noise Control 2001). The sound level data for the 

turbine and generator equipment are based on manufacturer’s design requirements for the equipment, 

based on a reference distance of 1 meter (3 feet). The noise source sound level and design specification 

data used in this analysis is provided in Table 3-8.
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Table 3-8

Representative Sound Level Data for Peaker Plant

Equipment

Sound Level at 

1 meter (3 feet)

(dBA)

Turbine/Generator/Lube Oil (with enclosure) 85

Hydraulic Start Pac (with enclosure) 85

Electric Generator Silencer 94

Transformer 75

Fuel Gas Compressor (with enclosure) 75

Selective Catalytic Reduction (SCR) Catalyst 

(with enclosure)

75

Stack and Silencer (stack and casing) 75

Dilution Fan (with silencer) 69

Air Compressor (with enclosure) 75

Source: Pacific Noise Control, 2001.

3.3.6 Regulatory Setting

Noise Control Act of 1972

Under the Noise Control Act of 1972, the Occupational Safety and Health Administration (OSHA) 

established workplace standards for noise. The minimum requirement states that constant noise 

exposure must not exceed 90 A-weighted decibels (dBA) over an 8-hour period. The highest allowable 

sound level to which workers can be consistently exposed is 115 dBA and exposure to this level must not 

exceed 15 minutes within an 8-hour period. The standards limit instantaneous exposure, such as impact 

noise, to 140 dBA. If noise levels exceed these standards, employers are required to provide hearing 

protection equipment that would reduce sound levels to acceptable limits. The Navy complies with 

applicable occupational health and safety legal requirements and policies.

Requirements and Practices for Sound Analysis at Military Installations

Current requirements and practices for sound analysis at military installations follow the procedures 

outlined in the following documents:

• Chief of Naval Operations Instruction (OPNAVINST) M-5090.1 contains guidance for considering 

time-averaged community sound levels in environmental evaluations (DON, 2014).

• U.S. Department of Defense planning guidelines in the noise environment provide compatibility 

criteria for various land uses. Separate evaluation criteria apply to impulsive sound events.

• The U.S. Army Public Health Command guidance for military operational noise, including 

environmental noise management for the Army.

Navy Occupational Health and Safety Regulations

The 2005 Navy Occupational Safety and Health Program Manual (OPNAVINST 5100-23G, 2005) provides 

directives to prevent occupational hearing loss and ensure auditory fitness for all Navy personnel. This 

manual establishes an occupational exposure level over an 8-hour time-weighted average in any 

24-hour period of 84 dBA. When noise exposure is likely to exceed this level, hearing-protective devices 

are required.
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The following subsections discuss local noise-related ordinances. Although not formally subject to such 

requirements, the Navy attempts to substantively comply with them as a matter of policy to the 

maximum extent practicable.

City of San Diego Noise Ordinance

The City of San Diego’s municipal code includes a noise ordinance that limits operational noise. It is 

unlawful for any person to cause noise by any means to the extent that the one-hour average sound 

level exceeds the applicable limit given in the following table (Table 3-9, City of San Diego Exterior Noise 

Limits), at any location in the City on or beyond the boundaries of the property on which the noise is 

produced. The sound level limit at a location on a boundary between two zoning districts is the 

arithmetic mean of the respective limits for the two districts.

Table 3-9

City of San Diego Exterior Noise Limits

Land Use Zone Time of Day

One-hour

Average Sound

Level (dBA)

Single Family Residential 

7:00 a.m. to 7:00 p.m. 50

7:00 p.m. to 10:00 p.m. 45

10:00 p.m. to 7:00 a.m. 40

Multi-Family Residential (up to a 

maximum density of 1/2000) 

7:00 a.m. to 7:00 p.m. 55

7:00 p.m. to 10:00 p.m. 50

10:00 p.m. to 7:00 a.m. 45

All other Residential 

7:00 a.m. to 7:00 p.m. 60

7:00 p.m. to 10:00 p.m. 55

10:00 p.m. to 7:00 a.m. 50

Commercial

7:00 a.m. to 7:00 p.m. 65

7:00 p.m. to 10:00 p.m. 60

10:00 p.m. to 7:00 a.m. 60

Industrial or Agricultural Anytime 75

Source: City of San Diego Municipal Code, Chapter 5, Article 9.5, Division 4, §59.5.0401, Sound Level Limits

The City of San Diego also limits construction noise, such as the effect of any construction noise 

generation that reaches any property which is zoned residential. This limit is an average sound level of 

75 dBA or less during the 12-hour period from 7:00 a.m. to 7:00 p.m. The ordinance also limits 

construction activity outside of these hours and during certain days where it may create an excessive 

impact on neighboring sites.

City of National City Noise Ordinance

Noise in National City is regulated by the City’s Noise Control Ordinance. National City standards indicate 

an allowable Day-Night Average Sound Level of 80 dBA in heavy industrial areas, including NBSD. Noise 

levels in commercial areas in National City are limited to 60 dBA, between 10:00 p.m. and 7:00 a.m., and 

limited to 65 dBA between 7:00 a.m. and 10:00 p.m. In single-family residential areas (Type I residential 

areas), allowable noise levels are 45 dBA between 10:00 p.m. and 7:00 a.m. and 55 dBA between 

7:00 a.m. and 10:00 p.m. Noise levels emanating off-site during construction in National City may not 

exceed 60 dBA on weekdays and 50 dBA on Sundays and holidays in residential zones at city boundaries, 

as shown in Table 3-10, City of National City Exterior Noise Limits.
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Table 3-10

City of National City Exterior Noise Limits1,2

Receiving Land Use Category Time of Day

One-hour

Average Sound

Level (dBA)

All Residential (less than 9 residential 

units)

7:00 a.m. to 10:00 p.m. 55

10:00 p.m. to 7:00 a.m. 45

Multi-unit Residential (consisting of 

9 dwelling units or more and public 

space) 

7:00 a.m. to 10:00 p.m. 60

10:00 p.m. to 7:00 a.m. 50

Commercial 7:00 a.m. to 10:00 p.m. 65

10:00 p.m. to 7:00 a.m. 60

Light Industry (Industry east of I-5) Anytime 70

Heavy Industry (Industry west of I-5) Anytime 80

Source: City of National Code of Ordinances, Title 12 Noise Control, Section 12.06.020. 1 Environmental Noise—shall be measured as LEQ in any hour (LEQ(h)). 2 Nuisance Noise—shall be measured as a decibel level not to be exceeded at any time.

3.3.7 Affected Environment

The federal government supports conditions free from noise that threaten human health and welfare 

and the environment. Response to noise varies, depending on the type and characteristics of the noise, 

distance between the noise source and whoever hears it (the receptor), receptor sensitivity, and time of 

day. Noise-sensitive land uses include development types where the occupants or users involved in 

indoor or outdoor activities may be subject to stress or considerable interference from noise. 

Residences, schools, hospitals, religious facilities, recreational facilities, open space, and some parks are 

considered noise-sensitive. Specific locations where individuals may be located within noise-sensitive 

land uses are referred to as noise-sensitive receptor sites. NBSD is divided into two sections, referred to 

as the “wet side” and “dry side.” Most noise-sensitive land uses are on the dry side of the installation, 

including residences and a child care center (i.e., NBSD Child Development Center), which are 

approximately 800 meters (0.5 miles) north of the existing steam plant (Site 1). The closest religious 

facility (i.e., NBSD Chapel), on the wet side of the installation, is approximately 480 meters (0.3 mile)

northwest of Site 1. There are several parks, picnic areas, and outdoor recreational facilities scattered 

throughout NBSD. Mariner Park, which includes an outdoor amphitheater, is approximately 

1,200 meters (0.75) to the north of Site 1. The nearest school, Balboa Elementary School, is 

approximately 1,290 meters (0.8 mile) northeast of Site 1, on the eastern side of Interstate 5. The Naval 

Station San Diego Historic District is approximately 480 meters (0.3 mile) to the northwest of Site 1. In 

addition, there are residences, hotels, parks, and recreational facilities in the vicinity. The closest 

residential and hotel uses to the project areas are located along Norman Scott Road, Main Street, and 

Roosevelt Avenue.

The specific distances from the Alternative site locations to the nearest noise-sensitive receptors are 

listed below in Table 3-11.
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Table 3-11

Noise-Sensitive Receptor Distances from Alternative Site Locations

Location Distance from 

Site 1

Distance from 

Site 2

NBSD Child Development Center

3653 Filbert Street 800 meters (0.5 mile) 800 meters (0.5 mile)

NBSD Chapel (Chaplain’s Office)

3670 Surface Navy Boulevard 480 meters (0.3 mile) 1,200 meters (0.7 mile)

Mariner Park

2260 Callagan Highway 1,200 meters (0.7 mile) 1,600 meters (1 mile)

Balboa Elementary

1844 South 40th Street 1,290 meters (0.8 mil) 970 meters (0.6 mile)

NBSD Historic District

Surface Navy Boulevard/S. 32nd Street 480 meters (0.3 mile) 1,200 meters (0.7 mile)

Pacific Beacon Apartments

3705 Norman Scott Road 870 meters (0.5 mile) 1,100 meters (0.7 mile)

Cassia Hotel

425 Roosevelt Avenue 1,200 meters (0.7 mile) 500 meters (0.3 mile)

3.3.7.1 Existing Noise Environment

NBSD can generally be characterized as an urban environment due to its location within and adjacent to 

the City of San Diego, City of National City, and Port of San Diego. The installation is surrounded by 

various noise sources, including marine terminals and industrial shipbuilding and repair facilities to the 

north and south; industrial, commercial, and residential uses to the east; and naval and Port of San 

Diego activities in San Diego Bay to the west. Harbor Drive (four-lane roadway) and railroad and light rail 

tracks traverse the installation. The ambient noise environment at the NBSD waterfront area is affected 

by a variety of activities, but the primary noise sources are ship repair equipment used on the piers; 

marine terminal operations; ship and vehicular traffic associated with NBSD and the surrounding port 

district; and air traffic associated with NASNI, the U.S. Coast Guard Air Station, and San Diego 

International Airport. Navy and civilian personnel at NBSD are exposed to a diverse range of sounds 

associated with support of the NBSD mission.

Ambient noise levels estimated for previous projects at NBSD (based on National Research Council 

methodology and the expected human activity in an urban area and population density per square mile 

in National City) were reported in the range of 58 to 59 dBA (DON, 2011a).

3.3.8 Environmental Consequences

3.3.8.1 No Action Alternative

Under the No Action Alternative, the Proposed Action would not occur and there would be no 

substantial change to baseline noise levels, although there would be some noise associated with the 

decommissioning of the existing steam plant. Therefore, no significant impacts due to the noise 

environment would occur with implementation of the No Action Alternative. (For information on noise 

impacts associated with demolition of the existing cogeneration plant, please see the 2013 Categorical 

Exclusion for the Decentralization of Steam Distribution System at Naval Base San Diego.)
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3.3.8.2 Alternative 1 – Convert Existing 40-MW Cogeneration Plant on Site 1 

Construction

The primary source of short-term noise associated with implementation of the Alternative 1 would be 

construction activities. Construction would involve several stages including grading, foundation 

construction, and finish construction. It is conservatively assumed that the retrofit on Site 1 may involve 

some demolition. Noise generated by construction equipment can vary in intensity and duration during 

each phase of construction. The potential noise levels associated with the construction equipment that 

may be used during construction of Alternative 1 are identified in Table 3-12, Construction Equipment 

Noise Levels. As shown in Table 3-12, construction noise levels at 15 meters (50 feet) from individual 

equipment would range from approximately 73 to 85 dBA LMAX, depending on the type of construction 

equipment.

Table 3-12

Construction Equipment Noise Levels

Equipment Usage per Day 

(%) 

Maximum Noise Level 

15 meters (50 feet) from 

Source (dBA)

Air compressor 40 80

Backhoe 40 74

Concrete Mixer Truck 40 85

Concrete Saw 20 83

Crane 16 85

Dozer 40 78

Dump Trucks 40 73

Excavator 40 77

Generator 50 78

Grader 40 85

Loader 40 75

Paver 40 80

Roller 20 85

Tractor 40 84

Source: RCNM 2006

Estimated equipment noise levels from the anticipated construction phases associated with 

Alternative 1 are shown in Table 3-13. The noise level is based on the distance to the nearest noisesensitive receptor, assumed to be the NBSD Chapel. Construction levels for noise-sensitive receptors at 

further distances would be lower.
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Table 3-13

Construction Equipment Noise Levels for Alternative 1

Phase Equipment 

(# units)

Percent

Operating Time LMAX

Combined dBA 

LEQ at Nearest 

Receptor1

Demolition Dozer (1) 

Concrete saw (2) 

Tractor/Loader/Backhoe2 (2)

40% (Dozer, Loader); 

20% (Concrete Saw) 60 57

Site Preparation Grader (1) 

Tractor/Loader/Backhoe2 (2) 40% 55 53

Grading Dozer (1)

Concrete saw (1)

Tractor/Loader/Backhoe2 (2)

40% (Dozer, Loader); 

20% (Concrete Saw) 60 55

Construction Crane (1)

Forklift3 (2)

Tractor/Loader/Backhoe2 (2)

40% (Forklift, 

Loader); 16% (Crane) 54 55

Coatings Air Compressor (1) 40% 48 44

Paving Paver (1)

Cement mixer trucks (4)

Roller (1)

Tractor/Loader/Backhoe2 (1)

50% (Paver); 

40% (Loader, Trucks); 

20% (Roller) 

50 53

Source: RCNM, 2006. See Appendix D for model outputs. 1 Assumed to be 480 meters (1,575 feet) at the NBSD Chapel. 2 Loaders were modeled instead of backhoes or tractors as the loaders would generate higher noise levels. 3 RCNM does not contain noise levels for a forklift; a tractor was modeled in place of a forklift as the pieces of equipment 

would be expected to generate similar noise levels.

Construction equipment would not all operate at the same time or location. For example, a dozer and a 

concrete saw may be working on the site simultaneously, but may not be working in close proximity to 

one another at a given time due to the nature of their respective operations. Furthermore, construction 

equipment would not be in constant use during the eight-hour operating day. 

As shown, noise levels would be lower than the limit provided in the City of San Diego noise ordinance, 

which addresses property zoned residential but is being used for the purposes of a conservative analysis. 

This limit is an average sound level of 75 dBA or less during the 12-hour period from 7:00 a.m. to 

7:00 p.m. The construction noise levels would also be within the limits specified in the City of National 

City noise ordinance, which limits construction noise to 60 dBA on weekdays. The City of National City 

includes a lower limit (50 dBA) if construction occurs on Sundays and holidays in residential zones.

To minimize the potential impacts of project related noise on the surrounding areas and in consideration 

of local ordinances, the Navy would limit installation and demolition to daylight hours (sunrise to 

sunset), when higher sound levels are more tolerable. Construction would not occur on Sundays or 

holidays. Further, noise levels from construction would be temporary and would cease upon 

completion. Therefore, anticipated noise impacts from construction noise would not be significant.

Operation

This alternative proposes to develop an electrical generation facility (peaker plant) for peak periods/

redundancy. Several pieces of mechanical equipment would generate noise at the site. Assumptions for 

the proposed peaker facility were based on the analysis conducted for a similar facility (Pacific Noise 
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Control, 2001). For example, it is assumed that the electric generation facility would be 49 MW in size 

and that it would utilize a natural gas-fired combustion turbine generator equipped with noise 

abatement features. The combustion turbine generator is assumed to include a gas turbine unit, a 

generator unit, and an electrical/control unit. The turbine/generator and electrical control units are 

assumed to be housed in steel enclosures, including lighting and electrical services. The primary noise 

generating equipment would include two turbines, a generator, two gas compressors, fans, air 

compressor, main transformer, selective catalytic reduction catalyst and exhaust stack, and a hydraulic 

start unit. Most of the equipment is assumed to be located within enclosures with exhaust and intake 

silencers.

When in use, it is assumed that the facility would operate a maximum of 24 hours per day. It would 

operate most summer days and less frequently in the winter.

Table 3-14 includes estimated noise levels for each unit of equipment at the nearest noise-sensitive 

receptor within NBSD (assumed to be at the NBSD Chapel approximately 480 meters (1,500 feet) to the 

northwest). Because noise generated from the peaker plant could potentially occur at night, the 

estimated noise level at the nearest residential property (the apartments located along Norman Scott 

Road along the boundary with the City of San Diego), approximately to be 870 meters (1,500 feet) to the 

northeast of Site 1 is also provided. The combined noise level, assuming that all pieces of equipment 

would be operating simultaneously, is provided at the bottom of the table. The noise levels assume a 

straight-line noise attenuation of 6 dBA with doubling of distance, not accounting for noise reduction 

provided by intervening structures.

Table 3-14

Estimated Peaker Plant Noise Levels for Alternative 1

Equipment

Reference 

Sound Level at 

3 feet (dBA)

Noise Level at 

Nearest Receptor1

(dBA LEQ)

Noise Level at 

Nearest Property 

Boundary2

(dBA LEQ)

Turbine/Generator/Lube Oil (with enclosure) 85 31 26

Hydraulic Start Pac (with enclosure) 85 31 26

Electric Generator Silencer 94 40 35

Transformer 75 21 16

Fuel Gas Compressor (with enclosure) 75 21 16

Selective Catalytic Reduction Catalyst 

(with enclosure) 75 21 16

Stack and Silencer (stack and casing) 75 21 16

Dilution Fan (with silencer) 69 15 10

Air Compressor (with enclosure) 75 21 16

Combined Noise Level 41 36

Source: Pacific Noise Control 2001 (for equipment noise reference levels).

1 Assumed to be 480 meters (1,500 feet) at the NBSD Chapel. 2 Assumed to be 870 meters (2,800 feet) to the northeast at the Pacific Beacon Apartments).

The proposed peaker plant would generate a one-hour average sound level of approximately 41 dBA at 

the NBSD Chapel. Noise levels from the peaker plant would not interfere with operations at the Chapel, 

and may not be audible over existing ambient noise levels that range between 58 to 59 dBA.
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The peaker plant would generate a one-hour average noise level of 36 dBA at the nearest residential 

property. The noise levels from the peaker plant would be lower than the strictest limit (40 dBA) for 

residential uses during nighttime hours, and therefore would be lower than the City’s noise ordinance 

limits.

Accordingly, implementation of Alternative 1 would not result in significant impacts to the noise 

environment.

3.3.8.3 Alternative 2 – Natural Gas Peaker Plant on Site 2

Construction

Similar to Alternative 1, the primary source of short-term noise associated with implementation of the 

Alternative 2 would be construction activities. Noise generated by construction equipment can vary in 

intensity and duration during each phase of construction. The potential noise levels associated with the 

construction equipment that may be used during construction of Alternative 2 are similar to 

Alternative 1.

Estimated equipment noise levels from the anticipated construction phases associated with 

Alternative 2 are shown in Table 3-15. The noise level is based on the distance to the nearest noisesensitive receptor, assumed to be the hotel along Roosevelt Way at a distance of 500 meters 

(1,640 feet). Construction levels for noise-sensitive receptors at further distances would be lower. 

Because the construction for Alternative 2 would not involve major demolition of buildings, this phase 

was excluded from the noise modeling.

Table 3-15

Construction Equipment Noise Levels for Alternative 2

Phase Equipment (# units) Percent

Operating Time LMAX

Combined 

dBA LEQ at 

Nearest Receptor1

Site Preparation Grader (1) 

Tractor/Loader/Backhoe2 (2) 40% 55 52

Grading

Dozer (1)

Concrete saw (1)

Tractor/Loader/Backhoe2 (2)

40% (Dozer, Loader); 

20% (Concrete Saw) 59 54

Construction

Crane (1)

Forklift3 (2)

Tractor/Loader/Backhoe2 (2)

16% (Crane); 

40% (Tractor, 

Loader)

54 54

Coatings Air Compressor (1) 40% 47 43

Paving

Paver (1)

Cement mixer trucks (4)

Roller (1)

Tractor/Loader/Backhoe2 (1)

50% (Paver); 

20% (Roller); 40% 

(Loader, Trucks)

50 53

Source: RCNM, 2006. See Appendix D for model outputs. 1 Assumed to be 500 meters (1,640 feet) at the Cassia Hotel. 2 Loaders were modeled instead of backhoes or tractors as the loaders would generate higher noise levels. 3 RCNM does not contain noise levels for a forklift; a tractor was modeled in place of a forklift as the pieces of equipment 

would be expected to generate similar noise levels.
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Construction equipment would not all operate at the same time or location. Furthermore, construction 

equipment would not be in constant use during the eight-hour operating day. The construction noise 

levels would be within the limits specified in the City of National City noise ordinance, which limits 

construction noise to 60 dBA on weekdays. In addition, construction noise is not likely to be audible at 

the hotel location over traffic noise emanating from I-5.

To minimize the potential impacts of project related noise on the surrounding areas and in consideration 

of local ordinances, the Navy would limit installation and demolition to daylight hours (sunrise to 

sunset), when higher sound levels are more tolerable. Construction would not occur on Sundays or 

holidays. Further, noise levels from construction would be temporary and would cease upon 

completion. Therefore, anticipated noise impacts from construction noise would not be significant.

Operation

This alternative proposes to develop an electrical generation facility (peaker plant) for peak periods/

redundancy on Site 2. Several pieces of mechanical equipment would generate noise at the site. Similar 

to the analysis included for Alternative 1, the assumptions for the proposed peaker facility were based 

on the analysis conducted for a similar facility (Pacific Noise Control, 2001).

Table 3-16 includes estimated noise levels for each unit of equipment at the nearest noise-sensitive 

receptor location. The combined noise level, assuming that all pieces of equipment would be operating 

simultaneously, is provided at the bottom of the table. The noise levels assume a straight-line noise 

attenuation of 6 dBA with doubling of distance, not accounting for noise reduction provided by 

intervening structures.

Table 3-16

Estimated Peaker Plant Noise Levels for Alternative 2

Equipment

Reference 

Sound Level at 3 

feet (dBA)

Noise Level at 

Nearest 

Receptor1

(dBA LEQ)

Turbine/Generator/Lube Oil (with enclosure) 85 30

Hydraulic Start Pac (with enclosure) 85 30

Electric Generator Silencer 94 39

Transformer 75 20

Fuel Gas Compressor (with enclosure) 75 20

Selective Catalytic Reduction (SCR) Catalyst

(with enclosure)

75 20

Stack and Silencer (stack and casing) 75 20

Dilution Fan (with silencer) 69 14

Air Compressor (with enclosure) 75 20

Combined Noise Level 40

Source: Pacific Noise Control 2001 (for reference equipment noise levels)

1 Assumed to be 500 meters (1,640 feet) to the east, at the Cassia Hotel along Roosevelt Avenue.

The peaker plant would generate a one-hour average noise level of 40 dBA at the nearest noise-sensitive 

receptor location, assumed to be 500 meters (1,640 feet) to the east, at the Cassia Hotel along 

Roosevelt Avenue within the City of National City. This area is within the City of National City’s 

Downtown Specific Plan zone, which allows a mix of uses, including residential and commercial. The 
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noise levels from the peaker plant would be lower than the strictest limit (45 dBA) for residential uses 

during nighttime hours, and therefore would be lower than the limits set in the City of National City’s 

noise ordinance limits. Further, noise from the peaker plant would not likely be audible over traffic noise 

emanating from I-5.

Therefore, implementation of Alternative 2 would not result in significant impacts to the noise 

environment.

3.3.8.4 Alternative 3 – Large Integrated Batteries with Photovoltaic System on Site 2

Construction

Construction activities associated with Alternative 3 would generate low levels of construction noise, as 

installation of the integrated batteries and small photovoltaic system would not involve the use of 

heavy-duty equipment. Construction noise levels would not result in a significant impact.

Operation

Operation of the integrated batteries and photovoltaic system would largely involve passive operation, 

without the use of motorized or other noise-generating equipment. Noise impacts associated with 

operation of Alternative 3 would not be significant.

3.3.8.5 Alternative 4 – Full Time Operation of Existing Cogeneration Plant on Site 1

Construction

Alternative 4 involves the continuation of the existing 40-MW cogeneration plant on Site 1 and 

construction activities associated with Alternative 4, apart from minor re-tooling. Thus, Alternative 4 

would not generate more than minimal construction noise. 

Operation

Continued operation of the existing 40-MW cogeneration plant on Site 1 would continue similar to 

existing conditions, and noise impacts associated with operation of Alternative 4 would not be 

significant.

3.4 Infrastructure

This section discusses infrastructure such as utilities (including drinking water production, storage, and 

distribution; wastewater collection treatment and disposal; storm water management, solid waste 

management, energy production, transmission, and distribution; and communications), and facilities 

(including airfields, buildings, ranges, training and testing areas, wharves, piers, housing, etc.) 

Transportation systems and traffic are addressed separately in Section 3.5.

3.4.1 Regulatory Setting

EO 13693, Planning for Federal Sustainability in the Next Decade, requires federal departments and 

agencies to enact specific actions and operations outlined within the EO to reduce agency direct 

greenhouse gas emissions by at least 40 percent over the next decade. Improved environmental 

performance and federal sustainability will be achieved by reducing energy use and cost. Pursuing clean 

sources of energy will improve energy and water security.

Chief of Naval Operation Instruction 4100.5E outlines the Secretary of the Navy’s vision for shore energy 

management. The focus of this instruction is establishing the energy goals and implementing strategy to 
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achieve energy efficiency. A key component of the Secretary of the Navy’s mission is energy security and 

includes on-base generation for on-base consumption.

Antiterrorism Force Protection Standards have been adopted by the DoD through Instruction number 

2000.16 of October 2006. The standards require all DoD Components to adopt and adhere to common 

criteria and minimum construction standards to mitigate antiterrorism vulnerabilities and terrorist 

threats.

3.4.2 Affected Environment

The following discussions provide a description of the existing conditions for each of the categories 

under infrastructure at NBSD.

3.4.2.1 Utilities

Potable Water 

NAVFAC Southwest operates and maintains internal water distribution systems for domestic use and fire 

protection at NBSD, including potable water distribution along most piers (DON, 2011b). The Navy 

purchases potable water from the City of San Diego, which is delivered to NBSD through several 

different connections (DON, 2011b). The City of San Diego, in turn receives water from the San Diego 

County Water Authority, a member agency of the Metropolitan Water District of Southern California. 

Potable water is supplied to the piers through service manifolds that include shut-off valves, meters, 

backflow preventers, and hose adapter fittings through a looped water distribution system 

(DON, 2011b).

Wastewater

Sewage effluent generated at NBSD is transported via pipelines to the Point Loma Wastewater 

Treatment Plant, and sanitary sewage is delivered via pipelines to the sewer system from a station 

system maintained and operated by NAVFAC Southwest Public Works (DON, 2011b). Most ships at NBSD 

are equipped with collection, holding, and transfer systems to offload waste into the wastewater system 

operated and maintained by NAVFAC Southwest Utilities. Several piers at NBSD have pump stations that 

transfer wastewater to sewer lines onshore (DON, 2011b). The treatment plant provides advanced 

primary treatment before discharging the effluent into a deep ocean outfall. The plant has a daily 

capacity of 240 million gallons (908,500 cubic meters) and over the last five years has averaged about 

152 million gallons (575,383 cubic meters) per day (City of San Diego, 2015).

Solid Waste Management

Non-hazardous solid waste and potentially recyclable materials generated by NBSD are separated on the 

bases by private contractors. NBSD solid waste and non-recyclable material is transported to the City of 

San Diego’s Miramar Landfill, while recyclable material is taken to recycling centers located on the bases 

(DON, 2014a). 

The Navy has partnered with the City of San Diego to assist in extending the life of landfills and to meet 

solid waste reduction and diversion goals. The Navy has implemented policies and procedures in the 

Navy’s Waste Management Plan, San Diego Metro Area, to maximize the diversion of materials entering 

the landfills, particularly construction and demolition debris. The Navy’s goal is a 40 percent reduction of 

municipal solid waste entering landfills. Additional Navy guidance on integrated solid waste 
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management plans and qualified recycling programs is provided under OPNAVINST M-5091.1

(DON, 2014).

Energy

San Diego Gas & Electric (SDG&E), a regulated public utility, operates and maintains the natural gas 

infrastructure throughout San Diego and Orange counties, including transportation of natural gas to 

NBSD. SDG&E provides energy service to approximately 3.6 million people in a 4,100-square-mile 

(10,619-square-km) service area (SDG&E, 2016). Power is supplied to NBSD through an agreement with 

SDG&E, and NAVFAC Southwest is responsible for electricity distribution once power is on the 

installation. Currently, the steam cogeneration plant at NBSD also supplies steam to produce electricity 

at the Navy steam turbine generators located on the installation. As discussed in Section 1.2 of this EA, 

the cogeneration plant is owned and operated by Applied Energy, LLC (AE LLC) and their 30-year 

contract with the Navy expires in 2018. In 2013, a NEPA Categorical Exclusion was prepared. The 

associated decentralized steam project would support the steam requirements at the Base. The 

Categorical Exclusion evaluated the removal and demolition of the centralized steam plant. 

SDG&E provides NBSD with electricity which is delivered primarily through the South Cummings 

Substation. Power is delivered at 69 kilovolts by SDG&E, stepped down to 12 kilovolts, and distributed to 

the base at 12 kilovolts. The base also maintains two SDG&E 12-kilovolt standby services at the Harbor 

Drive and Vesta switch stations. The recorded peak demand for NBSD is 68 MW, or 90 megavolt 

amperes at an assumed power factor of 75 percent. Ship-to-shore pier power distribution consists of 

four 12-kilovolt loop configured circuits serving several substations located on the pier decks. When 

demand for power exceeds the rating of the South Cummings transformers, NBSD must use one of the 

standby services to meet capacity (DON, 2006). NBSD uses about 350,000 MW hours of electricity 

annually. 

The AE LLC cogeneration plant located at NBSD also supplies steam to the 5-MW Navy steam turbine 

generator at NBSD. The Navy generator is designed to produce 5,000 kilowatts at a steam flow of 

82,650 pounds per hour at 125 pounds per square inch. The unit first generated power in June 2005. 

Since then, it has been run whenever steam has been available from the AE LLC natural gas turbine heat 

recovery steam generator (DON, 2014a). The additional steam load produced by the Navy generator is 

essential to maintaining the cogeneration plant’s status as a “qualifying facility” under the Public Utility 

Regulatory Policy Act of 1978. The Navy generator produces and supplies electrical power for NBSD, and 

a portion of the electricity generated at this plant, including 46.5 MW of firm capacity during peak hours 

in summer, is sold back to SDG&E for “credit.”

Natural Gas

The Navy purchases natural gas directly from SDG&E through the Defense Energy Support Center and 

SDG&E (DON, 2006).

Natural gas is used at NBSD for heating buildings, with some use for domestic hot water. Upgrades and 

expansion of the existing underground natural gas piping systems at NBSD would be needed to provide 

continued natural gas service. NBSD buildings receive natural gas through Navy-owned main and 

distribution lines, with the exception of some SDG&E owned lines that distribute natural gas to NBSD’s 

Bachelors Quarters. Meter/pressure reducing valve stations are located in proximity to Main Gate 6, 

Gate 7, and Building 225 (DON, 2006). NBSD currently burns the natural gas equivalent of about 

41,892,095 cubic feet annually (pers. comm. Frank Williamson, 2017). 
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3.4.3 Environmental Consequences

This section analyzes the magnitude of anticipated increases or decreases in public works infrastructure 

demands considering historic levels, existing management practices, and storage capacity, and evaluates 

potential impacts to public works infrastructure associated with implementation of the alternatives. 

Impacts are evaluated by whether they would result in the use of a substantial proportion of the 

remaining system capacity, reach or exceed the current capacity of the system, or require development 

of facilities and sources beyond those existing or currently planned.

3.4.3.1 No Action Alternative

Under the No Action Alternative, the existing water, wastewater, and solid waste services would remain 

unchanged. Therefore, no impacts are anticipated from this alternative to these public services. (For 

information on infrastructure-related impacts associated with demolition of the existing cogeneration 

plant, please see the 2013 Categorical Exclusion for the Decentralization of Steam Distribution System at 

Naval Base San Diego.)

3.4.3.2 Alternative 1 – Upgrade Existing 40-MW Cogeneration Plant on Site 1

Implementation of Alternative 1 would include expansion of the natural gas distribution system at 

NBSD. It is anticipated that existing underground utility lines to the SDG&E interconnection substation 

would be utilized, which could require some upgrades to connect Site 1 with the SDG&E Interconnection 

Station and NBSD Cummings Road Substation. A utility corridor would be located within a paved area 

within the Base, possibly within Cummings Road, to connect to the existing SDG&E Interconnection 

Substation and NBSD Cummings Road Substation. As a result, Alternative 1 would result in an increase in 

natural gas available for consumption. 

Under Alternative 1, existing water, wastewater, solid waste, and energy services would remain 

unchanged; therefore, there would be no significant impacts from Alternative 1 to these services and 

utilities. In addition, with the expansion of the natural gas distribution system, implementation of 

Alternative 1 would have a positive impact on utility services, and electricity distribution would 

experience no significant impact.

3.4.3.3 Alternative 2 – Natural Gas Peaker Plant on Site 2

Facilities developed under Alternative 2 would be the same as those discussed under Alternative 1; 

however, the proposed natural gas peaker plant would be constructed on an existing parking lot instead 

of converting an existing steam cogeneration plant. Similar to Alternative 1, a utility corridor would be 

located within a paved area within the Base on Cummings Road and off Base within 4th Street to connect 

to the existing SDG&E Interconnection Substation. However, the exact location of the utility corridor 

would be subject to change during the design process. In any case, the corridor located within a paved 

area and coordination would occur with the City of National City for any portion of the utility corridor 

that is located within the City’s jurisdiction. Expansion of the natural gas distribution system under 

Alternative 2 would have a positive impact on utility services, and electricity distribution would 

experience no significant impact.

With implementation of Alternative 2, existing water, wastewater, and solid waste services would 

remain unchanged. In addition, natural gas service would be expanded and electricity would remain 

largely unchanged with implementation of Alternative 2. Therefore, Alternative 2 would have no 

significant impacts on infrastructure.
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3.4.3.4 Alternative 3 – Large Integrated Batteries with Photovoltaic System on Site 2

Facilities developed under Alternative 3 would involve a large integrated battery facility with a small 

photovoltaic system on Site 2. Alternative 3 would involve construction of an underground utility 

corridor to the SDG&E interconnection substation, which may be located within Cummings Road and 

4th Street. The exact location of the utility corridor would be subject to change during the design 

process; In any case, the corridor would be located within a paved area and coordination would occur 

with the City of National City for any portion of the utility corridor that is located within the City’s 

jurisdiction. Existing water, wastewater, electricity, and solid waste services would remain unchanged. In 

addition, natural gas service would be expanded with implementation of Alternative 3. As a result, there 

would be no significant impacts on infrastructure under Alternative 3.

3.4.3.5 Alternative 4 – Operation of Existing Cogeneration Plant on Site 1

Alternative 4 would not involve new construction since the existing cogeneration plant would continue 

to be utilized. Existing water, wastewater, electricity, natural gas, and solid waste services would remain 

unchanged. As a result, there would be no significant impacts on infrastructure under Alternative 4.

3.5 Transportation

This discussion of transportation includes all of the air, land, and sea routes with the means of moving 

passengers and goods. A discussion of transportation would potentially include all of the following: 

roadways, bus routes, railways, subways, bikeways, trails, waterways, airports, and taxis, and can be 

looked at on a local or regional scale. The following discussion focuses on potential impacts related to 

construction traffic associated with the action alternatives. 

3.5.1 Regulatory Setting

EO 13693 encourages government entities to improve building efficiency, performance, and 

management by including in the planning for new buildings or leases, cost-effective strategies to 

optimize sustainable space usage and consideration of existing community transportation planning and 

infrastructure, including access to public transit. This EO encourages the coordination of federal real 

property discussions with local communities in an effort to encourage planned transportation 

investments that aim to support public transit access.

3.5.2 Affected Environment

Due to the proximity of the action alternative sites to I-5, which provides regional connections to the 

greater San Diego region, roadways anticipated to be used during construction associated with 

construction workers and deliveries/hauling trips to and from the action alternative sites in the cities of 

San Diego and National City are limited to Harbor Drive, which runs north and south between the action 

alternative sites. Harbor Drive divides NBSD into two main parts: the mainly industrial bay front area to 

the west of Harbor Drive and the community support complex to the east of Harbor Drive. In the City of 

National City Circulation Element, Harbor Drive is identified as a primary truck route that provides direct 

access to I-5. Harbor Drive as it occurs in the vicinity of the action alternative sites is a four-lane roadway 

with two travel lanes in either direction and a central median with turn lanes at some intersections and 

is also designated as part of the Bayshore Bikeway, a regional bicycle plan in the area.
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3.5.3 Environmental Consequences

Impacts to ground traffic and transportation are analyzed by considering the possible changes to 

existing traffic conditions and the capacity of area roadways from proposed increases in commuter and 

construction traffic.

3.5.3.1 Approach to Analysis

Traffic impacts were evaluated based on the addition of construction trips to the surrounding roadway 

network over a period of up to one year. It is anticipated that the maximum number of daily trips during 

construction would be about as much as 50 trips in a single workday based on similar types of projects 

and in consultation with the Navy.

3.5.3.2 No Action Alternative

Under the No Action Alternative, the Proposed Action would not occur and there would be a minimal 

change to transportation associated with decommissioning of the existing steam plant which would 

generate a small amount of truck traffic. (For information on transportation-related impacts associated 

with demolition of the existing cogeneration plant, please see the 2013 Categorical Exclusion for the 

Decentralization of Steam Distribution System at Naval Base San Diego.) Under no action conditions, the 

roadway network would remain as it does under existing conditions and there would be a small amount 

of construction truck traffic associated with decommissioning of the existing steam plant. No new 

construction would occur; however, a small amount of truck traffic associated with the 

decommissioning of the existing steam plant would be assigned to the network. Therefore, no 

significant impacts would occur with implementation of the No Action Alternative.

3.5.3.3 Alternative 1 – Upgrade Existing 40-MW Cogeneration on Site 1

Temporary increases in ground traffic would occur as a result of the proposed upgrades to the existing 

40-MW cogeneration plant at NBSD associated with truck haul trips and construction worker trips. 

Employee trips would likely be concentrated in the peak commuting periods (i.e., typically between the 

hours of 7:00 and 9:00 a.m. and 4:00 and 6:00 p.m.), while truck trips associated with deliveries and 

hauling materials would occur throughout the day. The amount of construction traffic was estimated 

based on similar types of projects and in consultation with Navy staff with experience in similar 

construction projects. As a result, it is anticipated that throughout the construction process, no single 

day would likely exceed 50 trips associated with construction workers, deliveries, and hauling activities 

to and from Site 1. These trips would be distributed throughout the course of a typical business day. 

Construction debris would be disposed of at the Miramar or Otay Landfills. Construction truck traffic 

travelling from the existing 40-MW cogeneration plant would move along internal roadways within 

NBSD, exit via Vesta Street, and proceed onto Harbor Drive and I-5 en route to either landfill. 

Construction employee trips would follow a similar route to I-5.

The City of San Diego Traffic Impact Study Manual is used to guide the analysis of traffic impacts within 

the City’s jurisdiction. Alternative 1’s temporary construction trip generation is below the thresholds 

specified in the Traffic Impact Study Manual that would warrant the preparation of a traffic study. 

Specifically, the construction trip generation of up to 50 trips is below the thresholds of 500 daily trips or 

50 peak hour trips that may require the preparation of a focused traffic study as described in the Traffic 

Impact Study Manual.
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To minimize potential temporary construction and demolition traffic impacts, a separate Traffic Control 

Plan would be prepared by the private partner’s construction contractor and approved by the Navy prior 

to the beginning of trucking activities. The Plan would specify the following:

• Truck and worker trips associated with demolition and construction activities would be 

scheduled outside of the peak commuting periods of 7:00 to 9:00 a.m. and 4:00 to 6:00 p.m. to 

the maximum extent practicable in order to minimize the potential for peak hour traffic 

congestion;

• No oversized construction vehicles would be used on public roadways (i.e., all vehicles would

comply with the size and weight limits specified in the California Vehicle Code);

• Only designated truck routes would be used; and

• Specific traffic control measures would be developed for circumstances where trucks would be 

temporarily stacked in the right-of-way.

Once constructed, operational traffic volumes would be minimal as operations would not require more 

than a minimal staff of on-Base workers throughout the life of the project. Infrequent trips would be 

made on an as-needed basis for emergencies and maintenance needs and are not anticipated to involve 

daily or regular trips to and from the Alternative 1 site.

In light of the relatively low number of projected trips per day during construction, traffic-related 

impacts would not be significant, and such impacts would be further minimized through implementation 

of the traffic control measures identified above.

3.5.3.4 Alternative 2 – Natural Gas Peaker Plant on Site 2 

Facilities developed under Alternative 2 would similar as those discussed under Alternative 1 and 

associated trips would be similar to those anticipated for Site 2; however, the estimated number of daily 

construction trips would be slightly less because there would be no construction trips associated with 

demolition (although demolition of the existing cogeneration plant, as previously analyzed in the 2013 

Categorical Exclusion (see Section 1.6) would go forward at some point). Operational trips would 

similarly be less than those anticipated during construction. Therefore, implementation of the 

Alternative 2 would not result in significant impacts to transportation.

3.5.3.5 Alternative 3 – Large Integrated Batteries with Photovoltaic System on Site 2 

Facilities developed under Alternative 3 would include battery storage that would be housed in large 

containers at Site 2. The estimated number of daily construction trips for the construction of a facility to 

house large integrated batteries with photovoltaic would be less than the 50 daily trips associated with 

construction of a peaker plant. Operational trips would similarly be less than those anticipated during 

construction. Due to the volume of daily trips that exist on the surrounding roadway to and from NBSD, 

the addition of less than 50 trips associated with the construction of Alternative 3 would not result in 

significant impacts to transportation.

3.5.3.6 Alternative 4 – Full Time Operation of Existing Cogeneration Plant on Site 1

No new facilities would be developed under Alternative 4 since the current plant would continue to be 

utilized. Construction truck trips would be slightly less as there would be no demolition and construction 

associated with this alternative. Operational trips may be slightly higher than those currently 

experienced with the existing facility since the plant would be run on a full-time basis versus part-time; 
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however, this increase would be nominal. Therefore, implementation of the Alternative 4 would not 

result in significant impacts to transportation.

3.6 Public Health and Safety 

This section discusses hazardous materials, hazardous waste, toxic substances, and contaminated sites, 

as well as public health and safety, which includes consideration for any activities, occurrences, or 

operations that have the potential to affect the safety, well-being, or health of members of the public. A 

safe environment is one in which there is either no potential for death, serious bodily injury or illness, or 

property damage, or such potential has been optimally reduced. The primary goal is to identify and 

prevent potential accidents or impacts on the general public. Public health and safety within this EA 

discusses information pertaining to: (1) hazardous materials and wastes, which includes hazardous 

materials, hazardous waste, toxic substances, and contaminated sites; and (2) other health and safety 

issues, which include community emergency services, construction activities, operations, and 

environmental health and safety risks to children.

Hazardous materials, hazardous waste, toxic substances, and contaminated sites are defined under 

Regulatory Setting. Other health and safety issues are defined below. Community emergency services 

are organizations which ensure public safety and health by addressing different emergencies. The three 

main emergency service functions include police, fire and rescue service, and emergency medical 

service. Public health and safety during construction, demolition, and renovation activities is generally 

associated with construction traffic, as well as the safety of personnel within or adjacent to the 

construction zones. Operational safety may refer to the actual use of the facility or built-out proposed 

project, or training or testing activities and potential risks to inhabitants or users of adjacent or nearby 

land and water parcels. Safety measures are often implemented through designated safety zones, 

warning areas, or other types of designations.

3.6.1 Regulatory Setting

3.6.1.1 Hazardous Materials and Wastes

Hazardous materials are defined by 49 CFR section 171.8 as “hazardous substances, hazardous wastes, 

marine pollutants, elevated temperature materials, materials designated as hazardous in the Hazardous 

Materials Table, and materials that meet the defining criteria for hazard classes and divisions in 49 CFR 

Part 173.” Transportation of hazardous materials is regulated by the U.S. Department of Transportation 

regulations. 

Hazardous wastes are defined by the Resource Conservation and Recovery Act (RCRA), as amended by 

the Hazardous and Solid Waste Amendments, as: “a solid waste, or combination of solid wastes, which 

because of its quantity, concentration, or physical, chemical, or infectious characteristics may (A) cause, 

or significantly contribute to, an increase in mortality or an increase in serious irreversible, or 

incapacitating reversible, illness; or (B) pose a substantial present or potential hazard to human health 

or the environment when improperly treated, stored, transported, or disposed of, or otherwise 

managed.” Certain types of hazardous wastes are subject to special management provisions intended to 

ease the management burden and facilitate the recycling of such materials. These are called universal 

wastes and their associated regulatory requirements are specified in 40 CFR part 273. Four types of 

waste are currently covered under the universal wastes regulations: hazardous waste batteries, 
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hazardous waste pesticides that are either recalled or collected in waste pesticide collection programs, 

hazardous waste thermostats, and hazardous waste lamps, such as fluorescent light bulbs.

Special hazards are those substances that might pose a risk to human health and are addressed 

separately from other hazardous substances. Special hazards include asbestos-containing material 

(ACM), polychlorinated biphenyls (PCBs), and lead-based paint (LBP). USEPA is given authority to 

regulate special hazard substances by the Toxic Substances Control Act (TSCA). Asbestos is also 

regulated by USEPA under the Clean Air Act, and the Comprehensive Environmental Response, 

Compensation, and Liability Act. 

The DoD established the Defense Environmental Restoration Program (DERP) to facilitate thorough 

investigation and cleanup of contaminated sites on military installations (active installations, 

installations subject to Base Realignment and Closure, and formerly used defense sites). The Installation 

Restoration Program and the Military Munitions Response Program are components of the DERP. The 

Installation Restoration Program requires each DoD installation to identify, investigate, and clean up 

hazardous waste disposal or release sites. The Military Munitions Response Program addresses 

nonoperational rangelands that are suspected or known to contain unexploded ordnance, discarded 

military munitions, or munitions constituent contamination. The Environmental Restoration Program is 

the Navy’s initiative to address DERP.

3.6.1.2 Public Health and Safety 

Executive Order 13045, Protection of Children from Environmental Health Risks and Safety Risks, 

requires federal agencies to “make it a high priority to identify and assess environmental health and 

safety risks that may disproportionately affect children and shall ensure that its policies, programs, 

activities, and standards address disproportionate risks to children that result from environmental 

health risks or safety risks.”

3.6.2 Affected Environment

3.6.2.1 Hazardous Materials and Hazardous Wastes

The Navy has implemented a Hazardous Material Control and Management Program and a Hazardous 

Waste Minimization Program for all activities. These programs are governed Navy-wide by applicable 

OPNAV instructions and at the installation by specific instructions issued by the Base Commander. The 

Navy continuously monitors its operations to find ways to minimize the use of hazardous materials and 

to reduce the generation of hazardous wastes.

Industrial activities at NBSD require the installation to use, handle, and store hazardous materials, 

including oils, lubricants, cleaners, hydraulic fluids, and fuels (i.e., gasoline and diesel) (DON, 2012). 

Universal wastes, a subset of hazardous wastes that includes even household types of items such as 

alkaline batteries, all lamps except incandescent lamps, mercury-containing devices such as 

thermostats, cathode ray tubes, consumer electronic devices, and aerosol containers, are also present 

and are currently being segregated, stored, managed, and properly disposed of in accordance with the 

current (2006) CNRSW Environmental Waste Management Plan (DON, 2011b).

Special Hazards (Asbestos Containing Materials, Lead Based Paint, Polychlorinated Biphenyls)

ACMs can be present in any age building, but are most likely to be found in buildings constructed prior 

to 1989. LBP can be present in buildings constructed prior to the 1978 ban. PCBs can be present in 
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products and equipment produced before the 1979 ban. Because the Navy has operated the various 

portions of NBSD for several decades, it is assumed that some buildings on NBSD contain ACMs, LBP, 

and PCBs (DON, 2014b). The existing steam cogeneration plant on Site 1 was constructed in 1989; 

therefore, ACM, PCBs, and LBP would not be present.

Defense Installation Restoration Program

The Navy Installation Restoration Program (IRP) is responsible for identifying contaminant releases, 

evaluating risk to human health and the environment, and developing and selecting response actions, as 

needed. As of 2011, 24 active IRP sites were identified at NBSD and Sites 4, 11, and 13 occur within or 

near the action alternative sites. Of these sites, Sites 11 and 13 have been closed and require no further 

action. The remaining IRP Site 4 continues under remedial action and will remain open until the nature 

and extent of contamination is fully characterized, or the necessary clean up actions completed. The 

Navy has also identified 30 SWMUs within NBSD; however, these sites have since been closed with 

regulatory concurrence (DON, 2014b). 

NBSD IRP Sites 4, 11, and 13

The action alternatives overlap or are located within IRP sites 4, 11, and 13 as identified in the NBSD 

Environmental Restoration Program, dated April 2015. Each of these sites is described below in context 

of its location to the action alternative sites.

IRP Site 4: Defense Reutilization Marketing Office Storage Yard. IRP Site 4 is bounded by railroad tracks 

on the west, the San Diego Trolley line on the east, a municipal sewage pump station on the north, and 

Paleta Creek on the south (see Figure 3-3). The northern portion of the IRP Site 4 is paved and is used for 

recycling, storage, warehousing, and resale of military property, while the Southern Area is occupied by 

the Defense Logistics Agency and used for boat storage. Site 2 of the action alternatives overlaps IRP 

Site 4 in the northern area (see Figure 3-3). The Navy used this site as a storage yard from 1943 to 1975. 

During this period, the yard was unpaved and waste oils were sprayed on the soil for dust control. Old 

batteries, containers of electrical insulating oil, paints, lubrication oils, and solvents were stored at IRP 

Site 4 during the 1970s. From 1975 to 1981, the site served as a Defense Property Disposal Office 

storage yard. Three warehouses were located in the northern portion; the largest warehouse, still 

present, stores nonhazardous materials associated with recycling activities. The other two warehouses 

were removed; these stored batteries and high-value scrap such as brass and copper. Since 1981, the 

southern subarea has been used mainly to store landing craft until it was paved in 2014 to serve as a 

parking lot. Several periods of field sampling were conducted at IRP Site 4. Petroleum, PCBs, and metals 

contamination in soil were reported. Analytical data suggest that some of the chemicals, including PAHs 

and metals, were present in the artificial fill material placed at the site.
Harbor Drive

Ward Road

Main Street

Woden Street

4th Street

Knowlton Williams

Southall Street

Cum

min

gs

Road

Vesta Street

Yama

Street

Mc

Candless Road

Craven Street

4th Street

Cummings Road

Vesta Street

Vesta Street

IRP Site 4

DPDO Storage Yard

IRP Site 13

Dry Dock

Sandblast Grit Area

IRP Site 11

French Drain

I:\PROJECTS\N\NAV\NAV-03.10_EnergySecurity\Map\EA_NBSD\Fig3_3_IRPSites.mxd NAV-03.10 11/22/16 -EV

Figure 3-3

NAVAL BASE SAN DIEGO

IRP Sites

Naval Base San Diego (NBSD) Boundary

IRP Site

Site 1 (Existing Steam Plant)

Site 2

SDG&E Interconnection Station and NBSD Cummings Road Substation

Gas Line

eConduit System Duct Bank

KEY MAP

0 150

Meters N

0 500

Feet
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IRP Site 11: French Drain. This site is within an asphalt-paved parking and storage area at the northwest 

corner of Building 3053, adjacent to Site 1 of the action alternatives (see Figure 3-3). The French drain is 

a corrugated vertical pipe about 0.9 meter (3 feet) in diameter, extending 3 meters (10 feet) into the 

ground, and filled with 0.75-inch crushed rock gravel. Previous investigation in 1996 determined that no 

contamination has occurred and closure documentation was completed and accepted by the regulatory 

agencies in 1999. Site 11 was closed by ROD in December 2004. There are no contaminants of concern 

at IRP Site 11.

IRP Site 13: Former Dry Dock Sand Blast Grit Area. The IRP Site 13 is in the west-central portion of NBSD, 

immediately east of Piers 5 and 6, and overlaps with Site 1 of the action alternatives (see Figure 3-3). 

The PWC ship maintenance/repair yard historically has been, and continues to be, used for the overhaul 

and maintenance of ships, repair of ship components, and contractor equipment storage. IRP Site 13 is 

part of an area used for uncovered sandblasting operations between 1942 and 1993. Copper abrasive 

blast material (grit) was used in the dry dock to remove paint from the hulls of Navy vessels. Anticorrosive and anti-fouling paints were used on vessels, which used to contain zinc and chromates, while 

anti-fouling paints currently are copper-based formulations. 

In October 1992, the Navy removed visible surface contamination consisting of overlying dark gray grit 

and dust to approximately 4 inches below grade in the northeastern portion of the sandblast grit area. 

The analytical results of samples taken following this removal led to additional work to address the 

presence of metals in the soil. A removal site evaluation report was prepared in 1999 and recommended 

no further action.

Based on requests from regulators, additional shallow soil samples were collected at IRP Site 13 in early 

2001. None of the sample results exceeded regulatory cleanup criteria. In fact, levels of contaminants 

were so low that the site qualifies for unrestricted land use. In addition, one 1-meter by 1-meter (3-foot 

by 3-foot) soil hot spot was excavated and removed in 2003. A revised removal site evaluation report 

was submitted in 2005 that recommended no further action for IRP Site 13. There are no contaminants 

of concern at IRP Site 13.

3.6.2.2 Public Health and Safety 

Community Emergency Services

The NBSD fire department provides fire suppression, fire prevention, emergency medical aid, and 

hazardous materials response. Fire stations are in Buildings 52 and 3359 on the wet side and the dry side 

of the installation, respectively. NBSD Force Protection personnel provide security measures for the 

protection of ships and their activities, facilities, materials, equipment, personnel, and documents. The 

Force Protection Headquarters is in Building 74 at NBSD, and central dispatch is off-installation at the 

Navy Region Southwest Pacific Highway Complex. The Navy Region Southwest Force Protection verifies 

the authorization of all personnel and vehicles entering onto the installation at each gate and at the 

head of each pier. The Office of Emergency Management provides emergency response training for 

NBSD. The installation Office of Emergency Management coordinates with the Region Office of 

Emergency Management; NBSD security; Navy fire department; medical agencies; and other federal, 

state, and local agencies to prepare for and mitigate threats or natural disasters that might impact the 

infrastructure at NBSD (NAVFAC, 2006). 
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Executive Order 13045, Protection of Children from Environmental Health Risks and Safety Risks

In 1997, Executive Order 13045, Protection of Children from Environmental Health Risks and Safety 

Risks, was issued. This order requires each federal agency to “...make it a high priority to identify and 

assess environmental health and safety risks that may disproportionately affect children and 

shall...ensure that its policies, programs, activities and standards address disproportionate risks to 

children...”

A Child Development Center (CDC) at NBSD provides on-Base child care services. The NBSD CDC is 

located at 3653 Filbert Street, about 0.8 km (0.5 mile) north of the action alternative sites. The closest 

public school is located about 1.0 km (0.66 mile) north and east of the action alternatives in the San 

Diego Unified School District.

3.6.3 Environmental Consequences

The safety and environmental health analysis contained in the respective sections addresses issues 

related to the health and well-being of military personnel and civilians living on or in the vicinity of 

NBSD. Specifically, this section provides information on hazards associated with the proposed energy 

security and resilience assets, potentially including a natural gas peaker plant, installation of gridintegrated battery storage or other energy assets at NBSD. The hazardous materials and wastes analysis 

contained in the respective sections addresses issues related to the use and management of hazardous 

materials and wastes as well as the presence and management of specific cleanup sites at NBSD. 

Additionally, this section addresses the environmental health and safety risks to children.

3.6.3.1 No Action Alternative

Under the No Action Alternative, the Proposed Action would not occur and there would be no change to 

public health and safety, including hazardous materials and hazardous wastes, associated with removal 

of the existing cogeneration plant on Site 1, or the development of Site 2 with a natural gas peaker plant 

or large integrated batteries with photovoltaic system. The existing 40-MW cogeneration plant would be 

decommissioned under the No Action Alternative, and public health and safety issues have been 

addressed in a separate NEPA Categorical Exclusion for the existing plant and were considered not 

significant based on the protective measures outlined in the Categorical Exclusion. (For information on 

public health and safety-related impacts associated with the demolition of the existing cogeneration 

plant, please see 2013 Categorical Exclusion for the Decentralization of the Steam Distribution System at 

Naval Base San Diego.) Therefore, no significant impacts would occur with implementation of the No 

Action Alternative.

3.6.3.2 Alternative 1 – Upgrade Existing 40-MW Cogeneration Plant on Site 1

Implementation of Alternative 1 would result in conversion of the existing steam cogeneration plant to a 

natural gas peaker plant at Site 1 at NBSD, near the intersection of Ward Road and Vesta Street (refer to 

Figure 2-1). The site and surrounding areas generally consist of large paved concrete areas with parking, 

roadways, the existing steam cogeneration plant, and several buildings. A dry dock area occurs adjacent 

and north of Site 1. Also, IRP Sites 11 and 13 are located within proximity to Site 1; however, these sites 

have been closed and there are no contaminants of concern at either site and there are no potential 

risks associated with either location.

Alternative 1 would result in the temporary increase of the use of hazardous wastes related to 

conversion and construction activities. Wastes from construction of Alternative 1 would involve debris 
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associated with the removal of the existing cogeneration plant; however, debris would be removed and 

disposed of in compliance with the Navy’s Sustainability and Environmental Management Policy 

Statement (date 16 September 2009) and sustainability goals (e.g., recycling approximately 50 percent 

of municipal trash and 40 percent of construction and demolition waste). Additionally, the private 

partner would coordinate with the Department of Toxic Substances Control. The construction contractor 

for the private partner would implement a Hazardous Waste Management Plan, detailed in Section 2.3, 

to ensure appropriate procedures are in place if contaminated soil is encountered during construction. 

As part of the Hazardous Waste Management Plan the contractor would be required to prepare a soil 

management plan to deal with contaminated soil. Part of the soil management plan would involve 

appropriate handling and disposal of any contaminated soil.

Once constructed, ongoing use of other hazardous materials would occur with operations, such as the 

use of turbine lubrication oil, hydraulic fluid, mineral oil, lube/valve seal oil, heat transfer oil, and 

aqueous ammonia; however, contractors would be required to properly store, transport, and dispose of 

their hazardous waste, and therefore, such ongoing use would pose minimal risk to the human 

environment. 

The NBSD CDC is located within 1.6 km (1 mile) of Alternative 1. Given the distance from the CDC facility, 

which is about 0.8 km (0.5 mile) north of the action of Alternative 1, there would be no environmental 

health and safety risks associated with the Proposed Action that would disproportionately affect 

children. Therefore, implementation of this action alternative would not result in significant impacts to 

public health and safety.

3.6.3.3 Alternative 2 – Natural Gas Peaker Plant on Site 2

Implementation of Alternative 2 would consist of installation of a natural gas peaker plant at Site 2 at 

NBSD, near the intersection of 4th Street and Harbor Drive (see Figure 2-1). The site generally consists of 

a partially paved concrete area with parking and surrounding areas include roadways, railroad tracks, 

the San Diego Trolley line, and several buildings. Site 2 overlaps with IRP Site 4, as shown on Figure 3-2. 

Similar to the discussion for Alternative 1, a temporary increase in the use of hazardous materials would 

occur related to construction of a natural gas peaker plant on Site 2. However, because Site 2 consists of 

paved areas with no structures, construction would create a minimal amount of construction debris that 

would be removed and disposed of in compliance with the Navy’s Sustainability and Environmental 

Management Policy Statement (date 16 September 2009) and sustainability goals (e.g., recycling 

approximately 50 percent of municipal trash and 40 percent of construction and demolition waste). 

During construction, safety measures would be implemented due to the proximity of Site 2 to IRP Site 4, 

which consists of a soil hot spot. A Health and Safety Plan and Hazardous Waste Management Plan

would include construction and operation details that would minimize worker exposure and potential 

soil contamination risks associated with the identification of a soil hot spot on the site. As part of the 

Hazardous Waste Management Plan the contractor would be required to prepare a soil management 

plan to deal with contaminated soil. Part of the soil management plan would involve appropriate 

handling and disposal of contaminated soil.

Once constructed, ongoing use of hazardous materials associated with a peaker plant would occur, and 

would involve turbine lubrication oil, hydraulic fluid, mineral oil, lube/valve seal oil, heat transfer oil, and 

aqueous ammonia; however, contractors would be required to properly store, transport, and dispose of 

their hazardous waste, and therefore, such ongoing use would pose minimal risk to the human 

environment. However, both a Hazardous Waste Management Plan and a Health and Safety Plan would 
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be required to address risks to construction workers and surrounding sensitive receptors during 

construction, including children at the CDC facility. As a result, impacts related to hazards and public 

health and safety would not be significant. 

3.6.3.4 Alternative 3 – Large Integrated Batteries with Photovoltaic System on Site 2

Alternative 3 would involve a large integrated battery facility with photovoltaic systems at Site 2. During 

construction, safety measures related to the overlap of Site 2 with IPR Site 4 would be addressed in the 

Health and Safety Plan to minimize worker exposure and risks associated with potential soil 

contamination. The Health and Safety Plan, along with the Hazardous Waste Management Plan, would 

be implemented to address risks to construction workers and surrounding sensitive receptors during 

operations, including children at the CDC facility. As a result, impacts related to hazards and public 

health and safety would not be significant.

3.6.3.5 Alternative 4 – Full Time Operation of Existing Cogeneration Plant on Site 1

Alternative 4 would involve the continuation of existing operations at Site 1. No construction or 

upgrades are involved in Alternative 4 and no appreciable changes in impacts related to public health 

and safety would be anticipated. As a result, impacts related to hazards and public health and safety 

would not be significant.

3.7 Summary of Potential Impacts to Resources and Impact Avoidance and Minimization

A summary of the potential impacts associated with each of the action alternatives and the No Action 

Alternative is presented in Table 3-17. No significant impacts were identified and therefore no 

mitigation measures to reduce any such impacts to less than significant would be required.
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Table 3-17

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Full Time Operation 

of Existing 

Cogeneration Plant 

on Site 1

Air Quality Under the No Action 

Alternative, the 

Proposed Action would 

not occur and there 

would be no near-term 

change to baseline air 

quality. Demolition of 

the existing plant was 

addressed under 

previous 

environmental 

documentation.

Alternative 1 would result 

in emissions of air 

pollutants during both 

construction and 

operations essentially 

identical to those estimate 

for Alternative 1. 

Emissions would be below 

de minimis levels. 

Therefore, 

implementation of 

Alternative 1 would not 

result in an adverse effect 

related to air quality. 

Alternative 2 would result 

in emissions of air 

pollutants during both 

construction and 

operations. Emissions 

would be below de 

minimis levels. Therefore, 

implementation of 

Alternative 2 would not 

result in an adverse effect 

related to air quality. 

Alternative 3 would result 

in emissions of air 

pollutants during 

construction comparable 

to the construction-related 

emissions estimated for 

Alternative 1. The 

photovoltaic system would 

replace the natural gas 

turbine, thereby 

eliminating the primary 

source of operationsphase emissions described 

under Alternative 1. 

Conversely, the energy 

generated by the 

proposed photovoltaic 

system would replace the 

energy consumption 

provided by burning of 

fossil fuels, thereby 

resulting in an indirect 

reduction of GHG 

emissions.

Alternative 4 would 

result in emissions of 

air pollutants during 

operations only, but 

in amounts 

considerably greater 

than for Alternative 

1. Decommissioning

and construction 

would not occur 

under this 

Alternative, which 

would result in some 

decrease in 

construction 

equipment and 

ultimately, to air 

emissions. Therefore, 

implementation of 

this action 

alternative would not 

result in significant 

impacts to air quality.

Visual 

Resources

No significant impacts 

associated with visual 

resources would occur.

Implementation of 

Alternative 1 would 

require the use of 

construction equipment, 

construction traffic, and 

stockpiled materials; 

Implementation of 

Alternative 2 would 

require the use of 

construction equipment, 

construction traffic, and 

stockpiled materials; 

Implementation of 

Alternative 3 would 

require the use of 

construction equipment, 

construction traffic, and 

stockpiled materials; 

Under Alternative 4, 

no new structures 

would be introduced 

in the area and the 

existing 

infrastructure would 
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Table 3-17

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Full Time Operation 

of Existing 

Cogeneration Plant 

on Site 1

Visual

Resources 

(cont.)

however, due to the 

distance of the site from 

any surrounding areas 

outside of NBSD, as well as 

intervening development 

and landscaping, visual 

impacts are anticipated to 

be less than significant 

during construction. 

Alternative 1 would not 

result in a noticeable 

change to existing 

conditions on-Base from 

any of the landscape units. 

No significant impacts

associated with visual 

resources would occur.

however, due to the 

distance of the site from 

any surrounding areas 

outside of NBSD, as well as 

intervening development 

and landscaping, visual 

impacts are anticipated to 

be less than significant 

during construction. 

Alternative 2 would not 

result in a noticeable 

change to existing 

conditions on-Base from 

any of the landscape units. 

No significant impacts 

associated with visual 

resources would occur.

however, due to the 

distance of the site from 

any surrounding areas 

outside of NBSD, as well as 

intervening development 

and landscaping, visual 

impacts are anticipated to 

be less than significant 

during construction. 

Alternative 3 would not 

result in a noticeable 

change to existing 

conditions on-Base from 

any of the landscape units. 

No significant impacts 

associated with visual 

resources would occur.

remain beyond the 

existing lease and no 

significant impacts 

associated with 

visual resources 

would occur.
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Table 3-17

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Full Time Operation 

of Existing 

Cogeneration Plant 

on Site 1

Noise There would be no 

substantial change to 

baseline noise levels, 

although there would 

be some noise 

associated with the 

decommissioning of 

the existing steam 

plant. Therefore, no 

significant impacts due 

to the noise 

environment would 

occur 

Construction and 

operation of the 

Alternative 1 would result 

in periodic and temporary 

generation of noise 

associated with 

construction equipment 

and, potentially, operation 

of the peaker plant 

equipment; however, no 

significant noise impacts 

would occur.

Construction and 

operation of the 

Alternative 2 would result 

in periodic and temporary 

generation of noise 

associated with 

construction equipment 

and, potentially, operation 

of the peaker plant 

equipment; however, no 

significant noise impacts 

would occur.

Construction and 

operation of Alternative 3 

would generate low levels 

of construction noise, as 

installation of the 

integrated batteries and 

small photovoltaic system 

would not involve the use 

of heavy-duty equipment. 

Operation would largely 

involve passive operation, 

without the use of 

motorized or other noisegenerating equipment. 

Noise impacts would not 

be significant.

There would be no 

construction 

associated with 

Alternative 4 and no 

decommissioning of 

the existing 

cogeneration plant. 

No significant 

increases in short- or 

long-term noise are 

anticipated.

Infrastructure The existing water, 

wastewater, and solid 

waste services would 

remain unchanged. 

Therefore, no impacts 

are anticipated 

Existing water, 

wastewater, solid waste, 

and energy services would 

remain unchanged under 

Alternative 1; therefore, 

there would be no 

significant impacts to 

these services and 

utilities. In addition, with 

the expansion of energy 

produced on the Base, 

implementation of 

Alternative 1 would have a 

positive impact, and 

electricity distribution 

Existing water, 

wastewater, solid waste, 

and energy services would 

remain unchanged under 

Alternative 2; therefore, 

there would be no 

significant impacts to 

these services and 

utilities. In addition, with 

the expansion of energy 

produced on the Base, 

implementation of 

Alternative 2 would have a 

positive impact, and 

electricity distribution 

Existing water, 

wastewater, solid waste, 

and energy services would 

remain unchanged under 

the Alternative 3; 

therefore, there would be 

no significant impacts to 

these services and 

utilities. In addition, with 

the expansion of energy 

produced on the Base, 

implementation of 

Alternative 3 would have a 

positive impact, and 

electricity distribution 

The existing water, 

wastewater, and 

solid waste services 

would remain 

unchanged. 

Therefore, no 

impacts are 

anticipated.
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Table 3-17

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Full Time Operation 

of Existing 

Cogeneration Plant 

on Site 1

Infrastructure

(cont.)

would experience no 

significant impact. No 

significant impacts would 

occur to infrastructure.

would experience no 

significant impact. No 

significant impacts would 

occur to infrastructure.

would experience no 

significant impact. No 

significant impacts would 

occur to infrastructure.

Transportation No new construction 

would occur; however, 

a small amount of 

truck traffic associated 

with the 

decommissioning of 

the existing steam 

plant would be 

assigned to the 

network. Therefore, no 

significant impacts 

would occur.

The addition of up to 50 

trips per day on a 

temporary basis during 

construction would not 

result in a significant 

impact on any of the 

surrounding roadways 

during construction. To 

minimize potential 

temporary construction 

and demolition traffic 

impacts, a separate Traffic 

Control Plan would be 

prepared by the private 

partner's construction 

contractor and approved 

by the Navy prior to the 

beginning of trucking 

activities. No significant 

impacts would occur to 

transportation.

The addition of up to 50 

trips per day on a 

temporary basis during 

construction would not 

result in a significant 

impact on any of the 

surrounding roadways 

during construction. To 

minimize potential 

temporary construction 

and demolition traffic 

impacts, a separate Traffic 

Control Plan would be 

prepared by the private 

partner's construction 

contractor and approved 

by the Navy prior to the 

beginning of trucking 

activities. No significant 

impacts would occur to 

transportation.

The addition of up to 50 

trips per day on a 

temporary basis during 

construction would not 

result in a significant 

impact on any of the 

surrounding roadways 

during construction. To 

minimize potential 

temporary construction 

and demolition traffic 

impacts, a separate Traffic 

Control Plan would be 

prepared by the private 

partner's construction 

contractor and approved 

by the Navy prior to the 

beginning of trucking 

activities. No significant 

impacts would occur to 

transportation.

No new construction 

would occur; 

however, operations 

would continue 

beyond the current 

lease and periodic 

trips associated with 

ongoing maintenance 

would continue. No 

significant impacts 

would occur to 

transportation.
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Table 3-17

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Full Time Operation 

of Existing 

Cogeneration Plant 

on Site 1

Public Health 

and Safety

The Proposed Action 

would not occur and 

there would be no 

change to public health 

and safety, including 

hazardous materials 

and hazardous wastes. 

The existing 40-MW 

cogeneration plant 

would be 

decommissioned 

under the No Action 

Alternative, and public 

health and safety 

issues have been 

addressed in a 

separate NEPA 

Categorical Exclusion 

for the existing plant 

and were considered 

not significant based 

on the protective 

measures outlined in 

Categorical Exclusion. 

Therefore, no

significant impacts 

would occur.

Alternative 1 would result 

in the temporary increase 

of the use of hazardous 

wastes related to 

conversion and 

construction activities and 

would involve debris that 

would be removed and 

disposed of in compliance 

with the Navy's 

Sustainability and 

Environmental 

Management Policy 

Statement and 

sustainability goals. 

Ongoing use of other 

hazardous materials would 

occur with operations;

however, contractors 

would be required to 

properly store, transport, 

and dispose of their 

hazardous waste, and 

therefore, would pose

minimal risk to the human 

environment. Therefore, 

there would be no 

significant public health 

and safety impacts.

Similar to Alternative 1, a 

temporary increase in the 

use of hazardous 

materials would occur 

related to construction of 

a natural gas peaker plant 

on Site 2. However, 

because Site 2 consists of 

paved areas with no 

structures, construction 

would create a minimal 

amount of construction 

debris that would be 

removed and disposed of 

in compliance with the 

Navy's Sustainability and 

Environmental 

Management Policy 

Statement and 

sustainability goals. 

Ongoing use of other 

hazardous materials 

would occur with

operations; however, 

contractors would be 

required to properly store,

transport, and dispose of 

their hazardous waste

During construction, 

safety measures related to 

the overlap of Site 2 with 

IPR Site 4 would be 

addressed in the Health 

and Safety Plan to 

minimize worker exposure 

and risks associated with 

potential soil 

contamination. The Health 

and Safety Plan, along 

with the Hazardous Waste 

Management Plan, would 

be implemented to 

address risks to 

construction workers and 

surrounding sensitive 

receptors during 

operations, including 

children at the CDC 

facility. As a result, 

impacts related to hazards 

and public health and 

safety would not be 

significant.

No new construction 

would occur; 

however, operations 

would continue 

beyond the current 

lease and ongoing 

use of other 

hazardous materials 

would occur with 

operations, however, 

contractors would be 

required to properly 

store, transport, and 

dispose of their 

hazardous waste, 

and therefore, would 

pose minimal risk to 

the human 

environment. 

Therefore, there 

would be no 

significant public 

health and safety 

impacts.
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Table 3-17

Summary of Potential Impacts to Resource Areas

Resource Area No Action Alternative

Alternative 1 –

Convert Existing 40-MW 

Cogeneration Plant 

on Site 1

Alternative 2 –

Natural Gas Peaker Plant 

on Site 2

Alternative 3 –

Large Integrated 

Batteries with 

Photovoltaic System on 

Site 2

Alternative 4 –

Full Time Operation 

of Existing 

Cogeneration Plant 

on Site 1

Public Health 

and Safety 

(cont.)

and, therefore, would 

pose minimal risk to the 

human environment. 

Therefore, there would be 

no significant public 

health and safety impacts.
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Cumulative Impacts

4 Cumulative Impacts

This section (1) defines cumulative impacts, (2) describes past, present, and reasonably foreseeable 

future actions relevant to cumulative impacts, (3) analyzes the incremental interaction the proposed 

action may have with other actions, and (4) evaluates cumulative impacts potentially resulting from 

these interactions.

4.1 Definition of Cumulative Impacts

The approach taken in the analysis of cumulative impacts follows the objectives of NEPA, CEQ 

regulations, and CEQ guidance. Cumulative impacts are defined in 40 CFR section 1508.7 as “the impact 

on the environment that results from the incremental impact of the action when added to the other 

past, present, and reasonably foreseeable future actions regardless of what agency (federal or nonfederal) or person undertakes such other actions. Cumulative impacts can result from individually minor 

but collectively significant actions taking place over a period of time.”

To determine the scope of environmental impact analyses, agencies shall consider cumulative actions, 

which when viewed with other proposed actions have cumulatively significant impacts and should 

therefore be discussed in the same impact analysis document.

In addition, CEQ and USEPA have published guidance addressing implementation of cumulative impact 

analyses—including Guidance on the Consideration of Past Actions in Cumulative Effects Analysis (CEQ,

2005) and Consideration of Cumulative Impacts in EPA Review of NEPA Documents (USEPA, 1999). CEQ 

guidance entitled Considering Cumulative Impacts Under NEPA (1997) states that cumulative impact 

analyses should

“...determine the magnitude and significance of the environmental consequences of the proposed 

action in the context of the cumulative impacts of other past, present, and future actions...identify 

significant cumulative impacts...[and]...focus on truly meaningful impacts.”

Cumulative impacts are most likely to arise when a relationship or synergism exists between a proposed 

action and other actions expected to occur in a similar location or during a similar time period. Actions 

overlapping with or in close proximity to the proposed action would be expected to have more potential 

for a relationship than those more geographically separated. Similarly, relatively concurrent actions 

would tend to offer a higher potential for cumulative impacts. To identify cumulative impacts, the 

analysis needs to address the following three fundamental questions.

• Does a relationship exist such that affected resource areas of the proposed action might interact 

to some appreciable extent with the affected resource areas of past, present, or reasonably 

foreseeable actions?

• If one or more of the affected resource areas of the proposed action and another action could 

be expected to appreciably interact, would the proposed action affect or be affected by impacts 

of the other action?

• If such a relationship exists, then does an assessment reveal any potentially significant impacts 

not identified when the proposed action is considered alone?
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Cumulative Impacts

4.2 Scope of Cumulative Impacts Analysis

The scope of the cumulative impacts analysis involves both the geographic extent of the effects and the 

time frame in which the effects could be expected to occur. For this EA, the study area delimits the 

geographic extent of the cumulative impacts analysis. In general, the study area will include those areas 

previously identified in Chapter 3 for the respective resource areas. The time frame for cumulative 

impacts centers on the timing of the proposed action. 

Another factor influencing the scope of cumulative impacts analysis involves identifying other actions to 

consider. Beyond determining that the geographic scope and time frame for the actions interrelate to 

the proposed action, the analysis employs the measure of “reasonably foreseeable” to include or 

exclude other actions. For the purposes of this analysis, public documents prepared by federal, state, 

and local government agencies form the primary sources of information regarding reasonably 

foreseeable actions. Documents used to identify other actions include notices of intent for 

Environmental Impact Statements (EISs) and EAs, management plans, land use plans, and other planning 

related studies.

4.3 Past, Present, and Reasonably Foreseeable Actions

This section will focus on past, present, and reasonably foreseeable future projects at and near the 

Proposed Action locale. In determining which projects to include in the cumulative impacts analysis, a 

preliminary determination was made regarding the past, present, or reasonably foreseeable action. 

Specifically, using the first fundamental question included in Section 4.1, it was determined if a 

relationship exists such that the affected resource areas of the Proposed Action (included in this EA) 

might interact with the affected resource area of a past, present, or reasonably foreseeable action. If no 

such potential relationship exists, the project was not carried forward into the cumulative impacts 

analysis. In accordance with CEQ guidance (CEQ, 2005), these actions considered but excluded from 

further cumulative effects analysis are not catalogued here as the intent is to focus the analysis on the 

meaningful actions relevant to informed decision-making. Projects included in this cumulative impacts 

analysis are listed in Table 4-1 and briefly described in the following subsections.

Table 4-1

Cumulative Action Evaluation

Action Level of NEPA

Analysis Completed

Past Actions

Construct Bachelor Housing (P-405) CatEx

Pier 12 Replacement (P-327) EA

Present and Reasonably Foreseeable Future Actions

Steam Decentralization Project, NBSD (P-800) CatEx

Littoral Combat Ship Training Facility (P-500) CatEx

Littoral Support Facility (P-499) CatEx

Pier 8 Replacement (P-440) EA

Littoral Combat Ship Mission Module Readiness Center (P-110) CatEx

Upgrade Pier 10 (P-440) CatEx

Construct NEX Gas Station and Mini-Mart EA
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4.3.1 Past Actions

Construct Bachelor Housing (P-405). The project included construction of a 25,993-square meter 

(279,785-square foot) parking structure and a 17,029-square meter (183,298 square foot) multi-story 

building to house 644 enlisted (E-1 through E-4). This project was completed in December 2013.

Pier 12 Replacement (P-327). The project included construction of a general purpose berthing pier feet 

to include electrical, telephone, cable television, fiber optic communications, SCADA system for energy 

monitoring and control, and fire alarm. The project supported the upgrade of shore-to-ship power of 

480V, 4,160 Volts and 12 kilovolts to meet power intensive fleet requirements. Fender system includes 

concrete and plastic piles with foam-filled fenders at the berths and plastic log camels. The project also 

included demolition of existing Pier 12. This project also included dredging to meet -37 mean low level

water (MLLW) requirement for deep draft vessels. The project was completed in July 2016.

4.3.2 Present and Reasonably Foreseeable Actions

Steam Decentralization Project, NBSD (P-800). In concert with the planned decommissioning of the 

existing 40-MW steam cogeneration plant discussed previously, the project would disconnect the 

existing centralized steam distribution system and provide for the construction of localized mechanical 

systems for approximately 45 buildings and ten piers. Mechanical systems include high efficiency natural 

gas water boilers, radiant gas heaters and other similar heating systems and associated piping to 

accommodate building and pier mechanical load requirements.

Littoral Combat Ship Training Facility (P-500). The project includes renovation of a portion of Building 

#3304 to provide a centralized training facility for the Littoral Combat Ship (LCS) simulators to house the 

newest Navy platforms coming to NBSD. 

Littoral Support Facility (P-499). This project includes the construction of a multi-story facility inside 

warehouse Building #3304 for LCS operations support to include personnel support, administrative, 

storage, and Secure Compartment Intelligence Facility/Special Access Program spaces. The project 

replaces and upgrades associated electrical, mechanical, plumbing, fire protection systems and upgrades 

the structural systems to meet current seismic codes. 

Pier 8 Replacement (P-440). The Navy prepared an EA for the construction of a general purpose berthing 

pier 36 meters (117 feet) by 488 meters (1,600 feet) to replace existing Pier 8. Utilities include potable 

water, sanitary sewer, compressed air, steam, oily waste and compensating water systems. Additional 

ship-to-shore utilities include electrical, telephone, cable television, fiber optic communications, SCADA 

system for energy monitoring and control, and fire alarm. Project will support upgrade of shore-to-ship 

power of 480V, 4,160 Volts and 13.8 kilovolts to meet power intensive fleet requirements. Fender 

system includes concrete and plastic piles with foam-filled fenders at the berths and plastic log camels. 

The project is in compliance with current seismic requirements. The project also included the demolition 

of existing Pier 8 and Facility # 358.

Littoral Combat Ship Mission Module Readiness Center (P-110). This project includes the 

Renovation/Modernization of an existing 5,070 square meter (54,572 square foot) facility into a mission 

module maintenance and storage building for the LCS mission.

Upgrade Pier 10 (P-312). This project would provide a 4160-volt skid type transformer at Pier 10. The 

scope of work includes providing a new concrete equipment slab with containment curbs. The new 

concrete slab would match existing slab elevation, and not extend past the fire lane. Removable bollards 
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Cumulative Impacts

in containment berm adjacent the fire lane would be installed. The new transformer and all new 

equipment and cabling will be provided as long as running power to and from and electrical station.

Construct NEX Gas Station and Mini-Mart. This project would include the construction of a gas station 

and mini-mart at Mariners Park.

4.4 Cumulative Impact Analysis

Where feasible, the cumulative impacts were assessed using quantifiable data; however, for many of the 

resources included for analysis, quantifiable data is not available and a qualitative analysis was 

undertaken. In addition, where an analysis of potential environmental effects for future actions has not 

been completed, assumptions were made regarding cumulative impacts related to this EA where 

possible. The analytical methodology presented in Chapter 3, which was used to determine potential 

impacts to the various resources analyzed in this document, was also used to determine cumulative 

impacts.

4.4.1 Air Quality

4.4.1.1 Description of Geographic Study Area

The geographic extent for cumulative effects on air quality is defined as the San Diego Air Basin. For 

purposes of air quality, the cumulative impact analysis looks beyond cumulative projects per se and 

instead focuses on the average cumulative air quality conditions within the San Diego Air Basin from day 

to day. The potential effects of proposed GHG emissions are by nature global and cumulative impacts, as 

individual sources of GHG emissions are typically not large enough to have an appreciable effect on 

climate change. Therefore, an appreciable impact to global climate change would only occur when 

proposed GHG emissions combine with other human-generated GHG emissions in such a way to 

appreciably and discernably affect climate change on a global scale.

4.4.1.2 Relevant Past, Present, and Future Actions

Emissions from the Proposed Action and the cumulative projects identified above in Section 4.3, Past, 

Present, and Reasonably Foreseeable Actions, would comply with San Diego County Air Pollution Control 

District rules and regulations, which would minimize the impact of project cumulative air quality 

impacts.

4.4.1.3 Cumulative Impact Analysis

As described in Section 3.1, Air Quality, construction and operational activities associated with the

Proposed Action would produce emissions that would remain below all emission thresholds for more 

in-depth analysis of potential significance with respect to criteria pollutants. Implementation of the 

Proposed Action would not exceed designated de minimis levels for criteria pollutants (40 CFR 

Part 51.853[b]). The Proposed Action would not contribute to any appreciable extent to the degradation 

of regional air quality or otherwise contribute to a significant cumulative effect on air quality. 

Consequently, proposed construction and operational activities would produce less than significant 

cumulative impacts to criteria pollutant levels. The previously-analyzed decommissioning and 

demolition of the existing cogeneration plant would proceed under the No Action Alternative and 

Alternatives 2 and 3, and would be located in close proximity to these action alternatives. However, it is 

unknown when demolition would ultimately occur and thus unknown whether emissions associated 

with demolition would overlap in time with the potential implementation of one of the above-
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Cumulative Impacts

referenced alternatives under the Proposed Action. However, even if demolition were to occur 

concurrently, demolition would generate emissions-related impacts only temporarily and would not 

exceed General Conformity de minimis threshold levels even if calculated together with Proposed Action 

emissions as analyzed in Section 3.1 above. (For more information on emissions associated with 

demolition of the existing cogeneration plant, please see the 2013 Categorical Exclusion for the 

Decentralization of Steam Distribution System at Naval Base San Diego.) Therefore, implementation of 

the Proposed Action, in addition to the effects from past, present, and reasonably foreseeable projects, 

would not result in significant cumulative impacts to air quality.

The potential effects of proposed GHG emissions are by nature global and cumulative impacts, as 

individual sources of GHG emissions are typically not large enough to have an appreciable effect on 

climate change. The GHG emissions contribute, on a cumulative basis, to the significant adverse 

environmental impacts of global climate change. Climate change impacts may include an increase in 

extreme heat days, higher concentrations of air pollutants, sea level rise, impacts to water supply and 

water quality, public health impacts, impacts to ecosystems, impacts to agriculture, and other 

environmental impacts. It is unlikely that any single project could generate enough GHG emissions to 

noticeably change the global average temperature. The combination of GHG emissions from past, 

present, and future projects contribute substantially to the phenomenon of global climate change and 

its associated environmental impacts. If a project would generate GHG emissions above the threshold 

level, it would be considered to contribute substantially to a cumulative impact and would be 

considered significant. Construction activities would generate approximately 64 metric tons (MT) of 

CO2e assuming the proposed activities occurred during 2017. Once the facility is operational, the new 

peaker plant would be subject to the requirements of CARB’s Mandatory Reporting Regulation and the 

USEPA’s Greenhouse Gas Reporting Program. The quantification of the peaker plant’s emissions would 

be refined by the private partner in the future and would be reported and minimized as required by the 

mandatory reporting regulations issued by CARB and the USEPA. As such, project emissions would not

have the potential to contribute meaningfully to global warming to any discernible extent. Therefore, 

based on the analysis in Section 3.1, the Project would not contribute to a cumulatively considerable 

impact.

4.4.2 Visual Resources

4.4.2.1 Description of Geographic Study Area

Cumulative impacts on aesthetics would consist of the aggregate effects of the NBSD Base and other 

projects, actions, and processes that could degrade the viewshed within the ROI. The ROI for aesthetics 

consists of NBSD and adjacent public areas in the cities of National City and San Diego. 

4.4.2.2 Relevant Past, Present, and Future Actions

Past actions have resulted in the redevelopment of an existing navy base that supports military actions 

along San Diego Bay. Present and future actions are anticipated to involve similar redevelopment of 

NBSD to support additional training and maintenance facilities. As a result of past, present, and future 

actions, the visual character and quality of the site will continue to have a military character at NBSD.

4.4.2.3 Cumulative Impact Analysis

The Proposed Action would result in the installation of a natural gas peaker plant or large battery 

storage with photovoltaic at NBSD. Visual changes would continue to be industrial in nature, similar to 
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Cumulative Impacts

the existing development at the action alternative sites and would not represent a change in existing 

visual character or quality. Further, the list of past, present, and future projects within the ROI would 

consist of similar improvements at NBSD dedicated to supporting military operations and would be of 

similar visual character and quality as the existing condition. Visibility from off-Base areas would be 

limited and views of the site are not anticipated to include visual changes associated with the action 

alternatives. Because the Proposed Action would not result in noticeable visual changes at NBSD, 

cumulative impacts considering other past, present, and future development would not be cumulatively 

significant. 

4.4.3 Noise

4.4.3.1 Description of Geographic Study Area

The geographic extent for cumulative effects on noise is defined as the project area plus the boundaries 

of NBSD. The area to be considered for the cumulative analysis would only be those projects within the 

immediate vicinity of the project area. Cumulative impacts to noise are not anticipated beyond this area. 

4.4.3.2 Relevant Past, Present, and Future Actions

Past actions have resulted in the redevelopment of an existing navy base that supports military actions 

along San Diego Bay. Present and future actions are anticipated to involve similar redevelopment of 

NBSD to support additional training and maintenance facilities.

4.4.3.3 Cumulative Impact Analysis

Noise, by definition, is a localized phenomenon and is progressively reduced as the distance from the 

source increases; specifically, point source-generated noise levels decrease by approximately 6 dBA for 

every doubling of distance.

Past and present projects that have already been constructed would have no cumulative effect on 

construction noise. Reasonably foreseeable projects are unlikely to have a cumulative effect on 

construction noise as they would need to occur simultaneously and in close proximity to the proposed 

project and nearby noise-sensitive receptors to have a combined effect.

For operational noise effects, past and present projects would have already been taken into account in 

the ambient noise levels in the area. The previously-analyzed decommissioning and demolition of the 

existing cogeneration plant would proceed under the No Action Alternative and Alternatives 2 and 3, 

and would be located in close proximity to these action alternatives. However, it is unknown when 

demolition would ultimately occur and thus unknown whether noise impacts associated with demolition 

would overlap in time with the potential implementation of one of the above-referenced alternatives 

under the Proposed Action. However, even if demolition were to occur concurrently, demolition would 

generate noise-related impacts only temporarily. Such impacts would themselves be relatively minor 

and would not necessarily overlap with noise impacts from the proposed action, even if demolition and 

the Proposed Action were to be going on at the same time. Also, demolition impacts would not occur at 

night, when lower noise levels are in effect in accordance with local noise ordinances, as discussed 

above at Section 3.3. (For more information on noise impacts associated with demolition of the existing 

cogeneration plant, please see the 2013 Categorical Exclusion for the Decentralization of Steam 

Distribution System at Naval Base San Diego.) Other reasonably foreseeable projects would be expected 

to be lower than local noise ordinance regulations. For example, the EA prepared for the Pier 8 

Replacement project indicated that the pier construction noise levels would be below the local noise 
Naval Base San Diego Environmental Assessment September 2017

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Cumulative Impacts

ordinance standards (DON, 2016). Therefore, the Proposed Action would not have a cumulatively 

significant effect with respect to noise impacts in conjunction with other cumulative projects.

4.4.4 Infrastructure

4.4.4.1 Description of Geographic Study Area

The geographic extent for cumulative effects on public services and utilities is defined as the project 

area at NBSD. Cumulative impacts to public services and utilities are not anticipated beyond this area.

4.4.4.2 Relevant Past, Present, and Future Actions

Relevant projects listed above in Table 4-1 generally include minor facilities improvements that have 

negligible to no associated impacts on infrastructure or that are intended to improve on-Base 

infrastructure. Therefore, in conjunction with the Proposed Action, there would be no significant 

cumulative impacts to infrastructure and cumulative impacts would remain less than significant.

4.4.4.3 Cumulative Impact Analysis

Implementation of the Proposed Action would include the construction and operation of an energy 

security and resilience project that may include a natural gas peaker plant, installation of grid-integrated 

battery storage or other energy assets at NBSD. With implementation of the Proposed Action, the 

existing water, wastewater, and solid waste services would remain almost entirely unchanged. 

Therefore, in conjunction with other past, present or reasonably foreseeable projects, there would be 

no potential to contribute meaningfully to any significant cumulative impacts to the public services and 

utilities from implementation of any of the action alternatives.

4.4.5 Transportation

4.4.5.1 Description of Geographic Study Area

The geographic extent for cumulative effects on traffic and circulation is defined as the streets and 

highways within 1.6 km (1 mile) of the project area at NBSD. This extent is fluid (i.e., it may change 

based upon the time of day or the day of the week); however, cumulative impacts are not anticipated in 

other areas at this time.

4.4.5.2 Relevant Past, Present, and Future Actions

All cumulative projects at NBSD (as listed in Table 4-1) have the potential to add operational trips within 

the geographic extent of cumulative effects for traffic and circulation. Past projects would not 

contribute construction trips while present and future projects could contribute to construction traffic, 

depending on the timing of these projects as they are constructed relative to the action alternatives. 

Relevant past, present, and future actions involved or would involve minor facilities improvement 

projects and would have negligible associated added construction and operational traffic trips within the 

cumulative geographic study area in conjunction with the Proposed Action. For example, the Pier 8 

Replacement would result temporary vehicle trip generation during demolition and construction

(comprising worker commute and truck trips and would be lower than the volumes that would

trigger a significant traffic impact according to City of San Diego minimum performance standards for

streets). Similar to the Proposed Action, the construction contractor would be required to

prepare and receive Navy approval of a separate Traffic Control Plan to address the estimated
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Cumulative Impacts

minimal temporary increases in traffic during the construction period (DON, 2016). In the event that

any of the current or future projects are constructed at the same time, the contribution of constructionrelated trips associated with the action alternatives would not result in a cumulatively considerable 

traffic impact.

4.4.5.3 Cumulative Impact Analysis

None of the action alternatives are anticipated to generate more than 50 daily trips during construction 

activities related to employee and truck trips. This relatively small, short-term increase of daily trips 

would be a fraction of the daily trips on the surrounding roadways. The previously-analyzed 

decommissioning and demolition of the existing cogeneration plant would proceed under the No Action 

Alternative and Alternatives 2 and 3, and would be located in close proximity to these action 

alternatives. However, it is unknown when demolition would ultimately occur and thus unknown 

whether transportation impacts associated with demolition would overlap in time with the potential 

implementation of one of the above-referenced alternatives under the Proposed Action. However, even 

if demolition were to occur concurrently, demolition of the existing plant would generate only small 

numbers of truck and personal vehicle trips, and would not appreciably alter the impacts associated 

with the Proposed Action, as discussed above at Section 3.5. (For more information on transportationrelated impacts associated with demolition of the existing cogeneration plant, please see the 2013 

Categorical Exclusion for the Decentralization of Steam Distribution System at Naval Base San Diego.) 

Therefore, in conjunction with other past, present, or reasonably foreseeable projects, there would be 

no significant cumulative impacts to traffic and circulation from implementation of the action 

alternatives.

4.4.6 Public Health and Safety

4.4.6.1 Description of Geographic Study Area

The geographic extent for cumulative effects on public health and safety is defined as the project area 

plus the boundaries of NBSD. Cumulative impacts to public health and safety are not anticipated beyond 

this area.

4.4.6.2 Relevant Past, Present, and Future Actions

Past actions have resulted in the development of an existing navy base that supports military actions 

along San Diego Bay. Present and future actions are anticipated to involve similar redevelopment of 

NBSD to support additional training and maintenance facilities. These past actions have likely used 

hazardous materials and were subject to the preparation and implementation of a project-specific 

Health and Safety Plan and a Hazardous Waste Management Plan. Similarly, present and future actions 

would also be required to prepare Health and Safety Plan and a Hazardous Waste Management Plans. 

As a result of past, present, and future actions, issues concerning public health and safety have been 

individually addressed with project-specific plans and impacts are not cumulatively considerable. 
Naval Base San Diego Environmental Assessment September 2017

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Cumulative Impacts

4.4.6.3 Cumulative Impact Analysis

Implementation of the action alternatives would involve the use of hazardous materials during 

construction. However, all actions in NBSD, including cumulative projects, were or would be required to 

prepare a Health and Safety Plan and a Hazardous Waste Management Plan. Because the past, present, 

and future actions, as well as the Proposed Action, either have been or would be required to prepare a 

Health and Safety Plan and a Hazardous Waste Management Plan, cumulative impacts from the 

Proposed Action in conjunction with other past, present, and future development would not be 

cumulatively significant.
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Cumulative Impacts

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Other Considerations Required by NEPA

5 Other Considerations Required by NEPA

5.1 Consistency with Other Federal, State, and Local Laws, Plans, Policies, and Regulations

In accordance with 40 CFR section 1502.16(c), analysis of environmental consequences shall include 

discussion of possible conflicts between the Proposed Action and the objectives of federal, regional, 

state and local land use plans, policies, and controls. Table 5-1 identifies the principal federal and state 

laws and regulations that are applicable to the Proposed Action, and describes briefly how compliance 

with these laws and regulations would be accomplished.

Table 5-1

Principal Federal and State Laws Applicable to the Proposed Action

Federal, State, Local, and 

Regional Land Use Plans, 

Policies, and Controls

Status of Compliance

National Environmental Policy 

Act (NEPA); CEQ NEPA 

implementing regulations; Navy 

procedures for Implementing 

NEPA

This EA has been prepared in accordance with CEQ Regulations 

implementing NEPA and United Stated (U.S. Navy NEPA Procedures)

Clean Air Act The Navy has determined that the potential emissions of the Proposed 

Action would not cause or contribute to a violation of any National Ambient 

Air Quality Standards or State Ambient Air Quality standards. Emissions 

would be below the applicable General Conformity de minimis thresholds or 

would be subject to a New Source Review. A formal Clean Air Act conformity

determination is not required.

Clean Water Act The action alternatives would not involve dredging or the release of

chemicals requiring a discharge permit and would be in compliance with the

Clean Water Act. The Proposed Action would conform with applicable 

National Pollution Discharge Elimination System (NPDES) requirements 

including implementation of one or more SWPPPs and associated BMPs. 

BMPs may include erosion control blankets, soil stabilizers, temporary 

seeding, silt fencing, hay bales, sand bags, and storm drain inlet protection 

devices.

Rivers and Harbors Act The action alternatives would not involve in-water demolition and 

construction activities, thus a Rivers and Harbors Act Section 10 permit from

the USACE would not be required.

Coastal Zone Management Act The Navy has determined that the Proposed Action would not affect coastal 

resources or uses; therefore, the federal consistency requirements of the 

Coastal Zone Management Act Section 307 do not apply.

National Historic Preservation 

Act

There are no historic properties located on Sites 1, 2 or 3; therefore, there 

are no historic properties that would be affected by the Proposed Action.

Endangered Species Act The proposed action would have no effect on any federally listed

endangered or threatened species or critical habitat since the action 

alternatives sites are developed and devoid of sensitive resources. Therefore, 

the proposed action would be in compliance with the federal Endangered

Species Act.
Naval Base San Diego Environmental Assessment September 2017

5-2

Other Considerations Required by NEPA

Table 5-1

Principal Federal and State Laws Applicable to the Proposed Action

Federal, State, Local, and 

Regional Land Use Plans, 

Policies, and Controls

Status of Compliance

Marine Mammal Protection Act The Navy has determined that the Proposed Action would not result in the 

reasonably foreseeable “take” of a marine mammal species by harassment, 

injury, or mortality as defined under the Marine Mammal Protection Act; 

therefore, an application for takings under the Marine Mammal Protection 

Act is not required.

Migratory Bird Treaty Act The Navy has determined that the Proposed Action would have no 

discernable effect on migratory birds.

Bald and Golden Eagle 

Protection Act 

The action alternatives would not have a measurable negative effect on bald 

and golden eagles and would be in compliance with the Bald and Golden 

Eagle Protection Act.

Emergency Planning and 

Community Right-to-Know Act

The Navy and/or private partner would inform Local Emergency Planning 

Committees of the action alternatives as required to assist them in 

developing plans to prepare for and respond to chemical emergencies.

Executive Order 12898, Federal 

Actions to Address 

Environmental Justice in 

Minority Populations and Lowincome Populations

There would be no disproportionately high and adverse human health or

environmental effects on minority populations and low-income populations.

The proposed action would be in compliance with EO 12898. 

Executive Order 13045, 

Protection of Children from 

Environmental Health Risks and 

Safety Risks

The Navy has determined that the proposed action would not

disproportionately expose children to environmental health risks or safety

risks and would be in compliance with EO 13045.

Executive Order 13089, Coral 

Reef Protection

The Navy has determined that U.S. coral reef ecosystems would not be 

degraded with the Proposed Action.

5.2 Relationship between Short-Term Use of the Environment and Long-Term Productivity

NEPA requires an analysis of the relationship between a project’s short-term impacts on the 

environment and the effects that these impacts may have on the maintenance and enhancement of the 

long-term productivity of the affected environment. Impacts that narrow the range of beneficial uses of 

the environment are of particular concern. This refers to the possibility that choosing one development 

site reduces future flexibility in pursuing other options, or that using a parcel of land or other resources 

often eliminates the possibility of other uses at that site.

In the short-term, effects to the human environment with implementation of the Proposed Action 

would primarily relate to the construction activity itself. Air quality and noise would be impacted in the 

short-term. In the long-term, the construction of the energy resilient facility and operation would not 

significantly impact the long-term natural resource productivity of the area. The Proposed Action would 

not result in any impacts that would significantly reduce environmental productivity or permanently 

narrow the range of beneficial uses of the environment.
Naval Base San Diego Environmental Assessment September 2017

6-1

References

6 References

BMJ. (2013). Residential Exposure to Aircraft Noise and Hospital Admissions for Cardiovascular Diseases; 

Multi-Airport Retrospective Study. BMJ, Correia, A.W, Peters, J.L., Levy, J.I., Melly, S., Dominici, 

F., 347:f5561.

City of National City. (2005, February). National City Downtown Specific Plan. National City, California.

City of National City. (2016, November 1). Code of Ordinances. Retrieved from 

https://www.municode.com/library/ca/national_city/codes/code_of_ordinances

City of National City. (n.d.). Official Zoning Map. Retrieved from 

http://www.nationalcityca.gov/home/showdocument?id=5515

City of San Diego. (2016, December). Municipal Code. Retrieved from https://www.sandiego.gov/cityclerk/officialdocs/legisdocs/muni

City of San Diego Public Utilities. (2015). 2015 Annual Reports and Summary: Point Loma Wastewater 

Treatment Plant & Ocean Outfall. Retrieved from 

https://www.sandiego.gov/sites/default/files/plwtp_annual_2015.pdf. Accessed: December 11, 

2016

City of San Diego. (n.d.). Zoning Grid Map. Retrieved from https://www.sandiego.gov/developmentservices/zoning/zoninggridmap

Council on Environmental Quality (CEQ). (1997). Considering Cumulative Effects Under the National 

Environmental Policy Act. Washington, DC.

Council on Environmental Quality (CEQ). (2005, June 24). Guidance on the Consideration of Past Actions 

in Cumulative Effects Analysis. Washington, D.C.

Cowan, J. P. (1994). Handbook of Environmental Acoustics. New York: John Wiley & Sons.

Department of Defense (DoD). (2009, June 16). Memorandum from the Under Secretary of Defense. 

Methodology for Assessing Hearing Loss Risk and Impacts in DoD Environmental Impact Analysis. 

Washington, DC.

Department of Defense (DoD). (2009, June 16). Memorandum from the Under Secretary of Defense. 

Methodology for Assessing Hearing Loss Risk and Impacts in DoD Environmental Impact Analysis. 

Washington, DC.

DoD Noise Working Group. (2009). Improving Aviation Noise Planning, Analysis and Public 

Communication with Supplemental Metrics - Guide to Using Supplemental Metrics.

Federal Highway Administration (FHWA). (2006). Roadway Construction Noise Model.

Federal Interagency Committee on Aviation Noise. (1997). Effects of Aviation Noise on Awakenings from 

Sleep.

Federal Interagency Committee on Noise. (1992). Federal Review of Selected Airport Noise Analysis 

Issues.
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References

Federal Interagency Committee on Urban Noise. (1980). Guidelines for Considering Noise in Land Use 

Planning and Control. Washington, DC.

Harris, C. (1979). Handbook of Noise Control. New York: McGraw-Hill.

International Code Council (ICC). (2015). International Building Code (IBC), 2015 Edition. Retrieved from 

http://codes.iccsafe.org/app/book/toc/2015/2015%20San%20Antonio/2015%20IBC%20HTML/

Ludlow, B., & Sixsmith, K. (1999). Long-term Effects of Military Jet Aircraft Noise Exposure during 

Childhood on Hearing Threshold Levels. Noise and Health, 33-39.

National Institute for Occupational Health and Safety. (1998). Criteria for a Recommended Standart 

Occupational Noise Exposure, Revised Criteria. Cincinnati: U.S. Department of Health and Human 

Services, Centers for Disease Control and Prevention.

Naval Base Coronado (NBC). (2014, May). Naval Base Coronado Programmatic Agreement.

Naval Facilities Engineering Command (NAVFAC). (2006, November). Naval Base San Diego Regional 

Shore Infrastructure Plan/Activity Overview Plan, Final Report.

Pacific Noise Control. (2001, June). Acoustical Assessment Report for Calpeak Border.

San Diego Gas and Electrict (SDG&E). (2016). San Diego Gas and Electric - Company Facts. Retrieved 

from http://www.sdge.com/aboutus

Shadpour Consulting Engineers, Inc. (2012). Steam Decentralization Study Final Submittal, Naval Base 

San Diego.

U.S. Department of the Navy (DON). (2006, December). Naval Base San Diego Activity Overview Plan 

(AOP).

U.S. Department of the Navy (DON). (2007, October 30). Environmental Readiness Program Manual. 

(OPNAV INSTRUCTION 5090.1C).

U.S. Department of the Navy (DON). (2010). Navy Region Southwest (NRSW) Regional Integrated Plan.

U.S. Department of the Navy (DON). (2011). Final Environmental Assessment for Helicopter Wings 

Realignment and MH-60R/S Helicopter Transition, Naval Base Coronado, California.

U.S. Department of the Navy (DON). (2011, July). P-327 Pier 12 Replacement and Dredging Naval Base 

San Diego (NBSD). Retrieved December 9, 2016, from 

http://www.cnic.navy.mil/content/dam/cnic/cnrsw/Environmental_Projects/NEPA_Projects/NB

SD/Pier%208%20Replacement%20EA/Draft_final_PP-SOU_0049.pdf

U.S. Department of the Navy (DON). (2012, April). Final Environmental Assessment for the Homeporting 

of the Littoral Combat Ship on the West Coast of the United States.

U.S. Department of the Navy (DON). (2014, June). Final Environmental Assessment Addressing the 

Integrated Natural Resources Management Plan for the Naval Base San Diego, California.

U.S. Department of the Navy (DON). (2014, April). Final Environmental Assessment for the 

Decentralization of Steam Systems at Naval Base Coronado.
Naval Base San Diego Environmental Assessment September 2017

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References

U.S. Environmental Protection Agency (USEPA). (1974). Information on Levels of Environmental Noise 

Requisite to Protect Public Health and Welfare with and Adequate Margin of Safety. EPA 550/9-

74-004. Washington, DC: Office of Noise Abatement and Control.

U.S. Environmental Protection Agency (USEPA). (1974). Information on Levels of Environmental Noise 

Requisite to Protect Public Health and Welfare with and Adequate Margin of Safety. EPA 550/9-

74-004. Washington, DC: Office of Noise Abatement and Control.

U.S. Environmental Protection Agency (USEPA). (1982). Guidelines for Noise Impact Analysis. EPA 550/9-

82-105. Washington, DC: Office of Noise Abatement and Control.

U.S. Environmental Protection Agency (USEPA). (1982). Guidelines for Noise Impact Analysis. EPA 550/9-

82-105. Washington, DC: Office of Noise Abatement and Control.

U.S. Environmental Protection Agency (USEPA). (1999, May). Consideration of Cumulative Impacts in EPA 

Review of NEPA Documents.

U.S. Environmental Protection Agency (USEPA). (2013). Air Emissions Where You Live, State and County 

Emission Summaries. Retrieved from http://www.epa.gov/air/emissions/where.htm

Williamson, Frank. Personal communication. March 6, 2017.
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References

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List of Preparers

7 List of Preparers

This EA was prepared collaboratively between the Navy and contractor preparers.

U.S. Department of the Navy

Sara Reed (Naval Facilities Engineering Command); MFA Historic Preservation BA History of Art and 

Architecture; Years of Experience: 6; Responsible for: NEPA

Rebecca Loomis (Naval Facilities Engineering Command); M.A. Organizational Management, B.S. 

Environmental Biology; Years of Experience: 17; Responsible for NEPA

Deb McKay, AICP (Navy Region Southwest); M.A. Political Science, emphasis on Environmental Policy; 

B.A. History of Public Policy; Years of Experience: 23; Responsible for: Land Use/Coastal Resources

Lori Megliola, (Naval Facilities Engineering Command) B.S. Earth Science, Environmental Studies; Years 

of Experience: 10; Responsible for: NEPA

Donna Ogilvie, (Naval Facilities Engineering Command, Naval Base Coronado), B.S. Civil Engineering; 

Years of experience; 36 in engineering, project management, marketing and product development with 

the last 6 in environmental engineering; Responsible for: Air Quality Program Naval Base Coronado.

Contractors

Julie McCall, (HELIX Environmental Planning Inc.)

B.A. Geography 

Years of Experience: 31

Section(s) person is responsible for: Chapters 1 and 2

Aaron Brownwood, (HELIX Environmental Planning Inc.)

B.S. City and Regional Planning

Years of Experience: 11

Section(s) person is responsible for: Visual Resources, Transportation, Public Health & Safety and 

Infrastructure

Victor Ortiz, (HELIX Environmental Planning Inc.)

B.S. Earth and Environmental Sciences

Years of Experience: 10

Section(s) person is responsible for: Air Quality/Greenhouse Gases

Joanne Dramko, AICP (HELIX Environmental Planning Inc.)

MESM Environmental Science and Management

Years of Experience: 17 

Section(s) person is responsible for: Noise
Naval Base San Diego Environmental Assessment September 2017

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List of Preparers

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A-1

Appendix A

Appendix A

Record of Non-Applicability
A-1

RECORD OF NON-APPLICABILITY (RONA)

FOR CLEAN AIR ACT CONFORMITY

SAN DIEGO COUNTY

This Proposed Action falls under the Record of Non-Applicability (RONA) category and is 

documented with this RONA.

The U.S. Environmental Protection Agency (USEPA) published Determining Conformity of 

General Federal Actions to State or Federal Implementation Plans; Final Rule, in the 30 

November 1993, Federal Register (40 CFR Parts 6, 51, and 93). The U.S. Navy published Clean 

Air Act Conformity Guidance in Appendix F, OPNAVINST 5090.1d, dated 30 July 2013. These 

publications provide implementing guidance to document Clean Air Act Conformity 

Determination requirements.

Federal regulations state that no department, agency, or instrumentality of the Federal 

Government shall engage in, support in any way or provide financial assistance for, license to 

permit, or approve any activity that does not conform to an applicable implementation plan. It is 

the responsibility of the Federal agency to determine whether a Federal action conforms to the 

applicable implementation plan, before the action is taken (40 CFR Part 1 51.850[a]).

Federal actions may be exempt from conformity determinations if they do not exceed designated 

de minimis levels for criteria pollutants (40 CFR Part 51.853[b]). De minimis levels (in tons/year) 

for the air basin potentially affected by the Proposed Action are listed in Table 1.

Table 1

De minimis Levels for Criteria Pollutants in San Diego County

Criteria Pollutant De minimis Level

(tons/year)

Volatile Organic Compounds (VOC)

Oxides of Nitrogen (NOx)

Carbon Monoxide (CO)

100

100

100
A-2

PROPOSED ACTION

Action Proponent: Naval Base San Diego

Location: Naval Base San Diego

Proposed Action Name: Development of an Energy Security and Resilience Project

Proposed Action and Emissions Summary: The Proposed Action would include the construction 

and operation of an energy security and resilience project that may include a natural gas peaker 

plant, installation of grid-integrated battery storage or other energy assets at Naval Base San 

Diego (NBSD) in San Diego and National City, California. The Navy would enter into an 

agreement with a private partner to construct, operate and maintain energy asset(s) at NBSD with 

a contract duration of 37 years, with 35 years of system(s) service and approximately one year 

for construction and one year for decommissioning. The agreement would ensure fair 

compensation for the use of Navy lands where energy security/resilience and/or renewability 

would take place. The U.S. Department of the Navy (Navy) is the lead agency for the Proposed 

Action.

Air Emissions Summary: Construction and operational emissions were calculated by using 

California Emissions Estimator Model (CalEEMod) version 2013.2.2. CalEEMod is a computer 

model developed by the South Coast Air Quality Management District (SCAQMD) with the 

input of several air quality management and pollution control districts to estimate anticipated 

emissions associated with land development projects in California. CalEEMod has separate 

databases for specific counties and air districts. The San Diego County database was used for the 

proposed Project. 

Specific inputs to CalEEMod include land uses and project site areas. Construction input data 

include, but are not limited to, (1) the anticipated start and finish dates of each Project 

construction activity; (2) inventories of construction equipment to be used during each activity; 

(3) areas to be excavated and graded; (4) volumes of materials to be exported from and imported 

to the Project area; and (5) areas to be paved. The input data and assumptions are based on 

information contained in Section 2, Proposed Action, of the EA and provided in detail in 

Appendix C. 

Table 2 summarizes the annual emissions associated with construction of the Proposed Action. 
A-3

Table 2

Annual Construction Emissions (Proposed Action)

Year Pollutant Emissions (tons/year)

VOC CO NOX SOX PM10 PM2.5

Construction – 2017 0.09 0.48 0.74 <0.01 0.05 0.05

Operations – 2018 0.01 0.02 0.01 <0.01 0.01 <0.01

de minimis Thresholdsa 100 100 100 - - -

Adverse Effect? No No No No No No

Source: CalEEMod (output data is provided in Appendix C) a De minimis threshold levels for conformity applicability analysis (Table 1).

Table 2 shows that annual construction and operational emissions generated by the Proposed 

Action are well below the San Diego Air Basin conformity de minimis levels. As a result, the 

Proposed Action would not produce adverse air quality impacts.

Date RONA Prepared: 10 February 2017.

EMISSIONS EVALUATION AND CONCLUSION

The Proposed Action would involve minor construction and operational emissions; all emissions 

are de minimis. 

The Navy concludes that de minimis thresholds for applicable criteria pollutants would not be 

exceeded nor would the projected emissions be regionally significant (i.e., greater than 10 

percent of the air basin’s emission budgets) as a result of implementation of the Proposed Action. 

Therefore, the Navy concludes that further formal Conformity Determination procedures are not 

required, resulting in this Record of Non-Applicability.

RONA APPROVAL

To the best of my knowledge, the information presented in this RONA is correct and accurate 

and I concur in the finding that the proposed action is not subject to the General Conformity 

Rule.

Date:

Signature:
A-4

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B-1

Appendix B

Appendix B

Potential to Emit and Permitting Implications for the 

Development of an Energy Security and Resilience 

Project at Naval Base San Diego
B-1

Appendix B

POTENTIAL TO EMIT AND PERMITTING IMPLICATIONS FOR THE 

DEVELOPMENT OF AN ENERGY SECURITY AND RESILIENCE 

PROJECT AT NAVAL BASE SAN DIEGO

Background

Gas turbines, also called “combustion turbines”, are used in a broad scope of applications 

including electric power generation, cogeneration, natural gas transmission, and various process 

applications. Gas turbines are available with power outputs ranging in size from 0.2 megawatt 

(MW) to over 200 MW, with an average size of 30 MW. The primary fuels used in gas turbines 

are natural gas and distillate fuel oil. 

A gas turbine is an internal combustion engine that operates with rotary rather than reciprocating 

motion. Gas turbines are essentially composed of three major components: compressor, 

combustor, and power turbine. In the compressor section, ambient air is drawn in and 

compressed up to 30 times ambient pressure and directed to the combustor section where fuel is 

introduced, ignited, and burned. Hot gases from the combustion section are then diluted with 

additional air from the compressor section and directed to the power turbine section at 

temperatures up to 2,600 degrees Fahrenheit (°F). Energy from the hot exhaust gases, which 

expand in the power turbine section, is recovered in the form of shaft power. 

The cycle thermal efficiency of a gas turbine is defined as the ratio of useful shaft energy to fuel 

energy input. The simple cycle is the most basic operating cycle of gas turbines with a thermal 

efficiency ranging from 15 to 42 percent. Current technologies are reliably able to achieve an 

efficiency ranging from 30 to 40 percent. Turbines with efficiencies up to 60 percent are 

expected to be commercially available in the next couple of years. Simple cycle gas turbines are 

typically used for shaft horsepower applications without recovery of exhaust heat and include 

uses such as generation of electricity during emergencies or peak demand periods. 

The primary pollutants from gas turbine engines are nitrogen oxides (NOX), carbon monoxide 

(CO), and to a lesser extent, volatile organic compounds (VOC), and particulate matter (PM). 

Trace to low amounts of hazardous air pollutants (HAP) and sulfur dioxide (SO2) are also 

emitted from gas turbines. Nitrogen oxide formation is strongly dependent on the high 

temperatures developed in the combustor. Carbon monoxide, VOC, HAP, and PM are primarily 

the result of incomplete combustion. 

Methodology and Assumptions

Criteria air pollutant emissions resulting from the gas turbine were quantified using emission 

factors available in the US Environmental Protection Agency’s (EPA) AP-42: Complication of 

Air Emission Factors 1 (US EPA 2000). Uncontrolled emission factors for natural gas fired 

 1 US EPA. 2000. AP-42: Complication of Air Emission Factors. Available: https://www.epa.gov/air-emissionsfactors-and-quantification/ap-42-compilation-air-emission-factors. April
B-2

turbines found in Tables 3.1-1 and 3.1-2a of Section 3.1, Stationary Gas Turbines were applied 

to the analysis. These emission factors, expressed in pounds (lbs) per million British thermal 

units (MMBTU), have been compiled and are presented in Table B-1, Uncontrolled Natural Gas 

Turbine Emission Factors. 

Table B-1

Uncontrolled Natural Gas Turbine Emission Factors

(lbs/MMBTU)

VOC CO NOX SO2 PM10 PM2.5

2.1 E-03 8.2 E-02 3.2 E-01 3.4 E-03 4.7 E-03 4.5 E-03

Source: US EPA AP-42: Complication of Air Emission Factors

Turbine emissions vary based on the efficiency, power output, and annual operating hours. As 

discussed above, current technologies are reliably able to achieve an efficiency ranging from 

30 to 40 percent. Emissions were estimated assuming a thermal efficiency of 35 percent. The 

analysis examined multiple power output and operating hour scenarios. Power outputs analyzed 

include 30, 40, and 50 MW options. Operating hours for each of three turbine power ratings 

includes the part-time operation of 1,416 hours per year and the full-time operation of 

8,760 hours per year. 

Results

Emission estimates for the part-time operation of the natural gas turbine are presented in 

Table B-2, Emissions for Part-Time Natural Gas Turbine Operations.

Table B-2

Emissions for Part-Time Natural Gas Turbine Operations

(tons per year)

Power Output VOC CO NOX SO2 PM10 PM2.5

30 MW 0.43 16.98 66.26 0.70 0.97 0.94

40 MW 0.58 22.64 88.35 0.94 1.30 1.25

50 MW 0.72 28.30 110.44 1.17 1.62 1.57

Assumptions: 1,416 hours per year with 35% thermal efficiency

Emission estimates for the full-time operation of the natural gas turbine are presented in 

Table B-3.
B-3

Table B-3

Emissions for Full-Time Natural Gas Turbine Operations

(tons per year)

Power Output VOC CO NOX SO2 PM10 PM2.5

30 MW 2.69 105.04 409.92 4.36 6.02 5.82

40 MW 3.59 140.06 546.57 5.81 8.03 7.76

50 MW 4.48 175.07 683.21 7.26 10.03 9.70

Assumptions: 8,760 hours per year with 35% thermal efficiency

Implications for the Permitting Process

While the estimates generated using AP-42 factors are sufficient to demonstrate general 

conformity, additional action will be necessary to meet local emission requirements. This is due 

to pollution control requirements being driven by those area’s federal attainment status and 

pertinent attainment strategies. Operators of facilities emitting criteria air pollutants in San Diego 

County must first obtain operating permits from the San Diego Air Pollution Control District 

before any construction is commenced. Permits for “major source” facilities will also include 

federal Title V requirements in addition to the local requirements. Emissions generated per these 

requirements will be used to determine the facility’s Title V status. A Title V major source status 

for this facility is possible, due to the quantity and type of emissions generated. For an operating 

permit, the Air District will require the applicant to certify that construction was completed 

according to the terms and conditions of the permit’s associated Authority to Construct (A/C), 

and that the facility will meet the district's regulations. Applicants for a facility subject to Title V 

requirements shall also certify that the facility will comply with any applicable federal 

requirements. 

As it is uncertain how much actual emissions will be reduced by these requirements, Table B-2 

and B-3 are being used for permitting and operating cost calculations.

The Air District will generally charge the applicant a permit fee equal to that paid for the 

Authority to Construct, not including the initial filing fee. If the Air District must collect samples 

to analyze the emission from any source, it will charge the applicant a fee to cover its expenses. 

The district may require an additional fee for facilities with Title V requirements. In Regulation 

III, Rule 40, the San Diego APCD sets a fee of $116 per ton for VOC, CO, NOX, SOX, and PM10, 

if the expected annual emissions exceed five tons. Based on the estimates provided in Table B-2, 

it is expected that part-time operation of the proposed natural gas turbine would incur fees 

ranging between $9,600 and $16,100 for excess CO and NOX emissions. Based on the estimates 

provided in Table B-3, it is expected that full-time operation of the proposed natural gas turbine 

would incur fees ranging between $60,400 and $101,600 for excess CO, NOX, SOX, and PM10

emissions.

The Air District evaluates applications for a Permit to Operate to determine whether the 

applicant constructed the facility according to the conditions of the Authority to Construct. The 

Air District also determines whether the applicant will comply with the district's rules and 

regulations when operating the facility. The air district will also determine compliance with 

applicable federal regulations in the case of facilities with Title V requirements. A compliance 
B-4

source test will be required. The test will be conducted by the district or by an approved 

independent source testing consultant. The Air District conducts, or directs the applicant to 

conduct, an inspection of the above facility to determine whether it meets the criteria described 

above. If the facility is acceptable, the Air Pollution Control Officer (APCO) issues the 

Operating Permit. This process generally takes from one to four months. Depending on the Air 

District, the Operating Permit is usually valid for one year. With respect to Title V requirements, 

if they apply, the permit is usually valid for five years.
C-1

Appendix C

Appendix C

Air Quality Methodology and Calculations
Project Characteristics - 

Land Use - 

Energy Mitigation - Manditory compiance with 2016 T24

Water Mitigation - Manditory compliance with 2016 CALGreen

Waste Mitigation - Manditory compliance with AB341

Stationary Sources - User Defined - 

1.1 Land Usage

Land Uses Size Metric Lot Acreage Floor Surface Area Population

General Light Industry 1.00 1000sqft 0.02 1,000.00 0

1.2 Other Project Characteristics

Urbanization

Climate Zone

Urban

13

Wind Speed (m/s) 2.6 Precipitation Freq (Days) 40

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics

Utility Company San Diego Gas & Electric

Operational Year 2019

CO2 Intensity 

(lb/MWhr)

720.49 CH4 Intensity 0.029

(lb/MWhr)

N2O Intensity 0.006

(lb/MWhr)

Table Name Column Name Default Value New Value

tblProjectCharacteristics OperationalYear 2018 2019

Energy Security and Resilience

San Diego County, Annual

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Energy Security and Resilience - San Diego County, Annual
2.0 Emissions Summary

2.1 Overall Construction

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Year tons/yr MT/yr

2017 0.0873 0.7370 0.4802 6.9000e0041.8800e0030.0496 0.0514 6.7000e0040.0458 0.0464 0.0000 63.7105 63.7105 0.0184 0.0000 64.1702

Maximum 0.0873 0.7370 0.4802 6.9000e0041.8800e0030.0496 0.0514 6.7000e0040.0458 0.0464 0.0000 63.7105 63.7105 0.0184 0.0000 64.1702

Unmitigated Construction

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Year tons/yr MT/yr

2017 0.0873 0.7370 0.4802 6.9000e0041.8800e0030.0496 0.0514 6.7000e0040.0458 0.0464 0.0000 63.7104 63.7104 0.0184 0.0000 64.1702

Maximum 0.0873 0.7370 0.4802 6.9000e0041.8800e0030.0496 0.0514 6.7000e0040.0458 0.0464 0.0000 63.7104 63.7104 0.0184 0.0000 64.1702

Mitigated Construction

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Energy Security and Resilience - San Diego County, Annual
2.2 Overall Operational

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Area 5.0700e0030.0000 1.0000e0050.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e0052.0000e0050.0000 0.0000 2.0000e005

Energy 6.0000e0055.7000e0044.8000e0040.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0000 3.3800 3.3800 1.2000e0043.0000e0053.3933

Mobile 1.9100e0038.5900e0030.0231 7.0000e0055.7900e0038.0000e0055.8700e0031.5500e0038.0000e0051.6300e0030.0000 6.5847 6.5847 3.7000e0040.0000 6.5940

Waste 0.0000 0.0000 0.0000 0.0000 0.2517 0.0000 0.2517 0.0149 0.0000 0.6236

Water 0.0000 0.0000 0.0000 0.0000 0.0734 0.9841 1.0574 7.5700e0031.9000e0041.3023

Total 7.0400e0039.1600e0030.0236 7.0000e0055.7900e0031.2000e0045.9100e0031.5500e0031.2000e0041.6700e0030.3251 10.9488 11.2739 0.0229 2.2000e00411.9132

Unmitigated Operational

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e

Percent 

Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter)

1 1-1-2017 3-31-2017 0.4365 0.4365

2 4-1-2017 6-30-2017 0.3868 0.3868

Highest 0.4365 0.4365

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Energy Security and Resilience - San Diego County, Annual
2.2 Overall Operational

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Area 5.0700e0030.0000 1.0000e0050.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e0052.0000e0050.0000 0.0000 2.0000e005

Energy 6.0000e0055.1000e0044.3000e0040.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0000 3.1990 3.1990 1.2000e0043.0000e0053.2115

Mobile 1.9100e0038.5900e0030.0231 7.0000e0055.7900e0038.0000e0055.8700e0031.5500e0038.0000e0051.6300e0030.0000 6.5847 6.5847 3.7000e0040.0000 6.5940

Waste 0.0000 0.0000 0.0000 0.0000 0.0629 0.0000 0.0629 3.7200e0030.0000 0.1559

Water 0.0000 0.0000 0.0000 0.0000 0.0587 0.7872 0.8459 6.0600e0031.5000e0041.0418

Total 7.0400e0039.1000e0030.0236 7.0000e0055.7900e0031.2000e0045.9100e0031.5500e0031.2000e0041.6700e0030.1216 10.5709 10.6926 0.0103 1.8000e00411.0032

Mitigated Operational

3.0 Construction Detail

Construction Phase

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e

Percent 

Reduction

0.00 0.66 0.21 0.00 0.00 0.00 0.00 0.00 0.00 0.00 62.59 3.45 5.16 55.23 18.18 7.64

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Energy Security and Resilience - San Diego County, Annual
Phase 

Number

Phase Name Phase Type Start Date End Date Num Days 

Week

Num Days Phase Description

1 Demolition Demolition 1/1/2017 1/13/2017 5 10

2 Site Preparation Site Preparation 1/14/2017 1/16/2017 5 1

3 Grading Grading 1/17/2017 1/18/2017 5 2

4 Building Construction Building Construction 1/19/2017 6/7/2017 5 100

5 Paving Paving 6/8/2017 6/14/2017 5 5

6 Architectural Coating Architectural Coating 6/15/2017 6/21/2017 5 5

OffRoad Equipment

Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 1,500; Non-Residential Outdoor: 500; Striped Parking Area: 0 

(Architectural Coating – sqft)

Acres of Grading (Site Preparation Phase): 0.5

Acres of Grading (Grading Phase): 0

Acres of Paving: 0

CalEEMod Version: CalEEMod.2016.3.1 Page 5 of 29 Date: 2/8/2017 5:03 PM

Energy Security and Resilience - San Diego County, Annual
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor

Architectural Coating Air Compressors 1 6.00 78 0.48

Building Construction Cranes 1 4.00 231 0.29

Building Construction Forklifts 2 6.00 89 0.20

Building Construction Tractors/Loaders/Backhoes 2 8.00 97 0.37

Demolition Concrete/Industrial Saws 1 8.00 81 0.73

Demolition Rubber Tired Dozers 1 1.00 247 0.40

Demolition Tractors/Loaders/Backhoes 2 6.00 97 0.37

Grading Concrete/Industrial Saws 1 8.00 81 0.73

Grading Rubber Tired Dozers 1 1.00 247 0.40

Grading Tractors/Loaders/Backhoes 2 6.00 97 0.37

Paving Cement and Mortar Mixers 4 6.00 9 0.56

Paving Pavers 1 7.00 130 0.42

Paving Rollers 1 7.00 80 0.38

Paving Tractors/Loaders/Backhoes 1 7.00 97 0.37

Site Preparation Graders 1 8.00 187 0.41

Site Preparation Tractors/Loaders/Backhoes 1 8.00 97 0.37

Trips and VMT

Phase Name Offroad Equipment 

Count

Worker Trip 

Number

Vendor Trip 

Number

Hauling Trip 

Number

Worker Trip 

Length

Vendor Trip 

Length

Hauling Trip 

Length

Worker Vehicle 

Class

Vendor 

Vehicle Class

Hauling 

Vehicle Class

Architectural Coating 1 0.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT

Building Construction 5 0.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT

Demolition 4 10.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT

Grading 4 10.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT

Paving 7 18.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT

Site Preparation 2 5.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT

CalEEMod Version: CalEEMod.2016.3.1 Page 6 of 29 Date: 2/8/2017 5:03 PM

Energy Security and Resilience - San Diego County, Annual
3.2 Demolition - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Off-Road 6.0500e0030.0525 0.0396 6.0000e0053.6600e0033.6600e0033.4900e0033.4900e0030.0000 5.3493 5.3493 1.0500e0030.0000 5.3755

Total 6.0500e0030.0525 0.0396 6.0000e0053.6600e0033.6600e0033.4900e0033.4900e0030.0000 5.3493 5.3493 1.0500e0030.0000 5.3755

Unmitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 2.4000e0041.9000e0041.8400e0030.0000 4.0000e0040.0000 4.0000e0041.1000e0040.0000 1.1000e0040.0000 0.3971 0.3971 1.0000e0050.0000 0.3974

Total 2.4000e0041.9000e0041.8400e0030.0000 4.0000e0040.0000 4.0000e0041.1000e0040.0000 1.1000e0040.0000 0.3971 0.3971 1.0000e0050.0000 0.3974

Unmitigated Construction Off-Site

3.1 Mitigation Measures Construction

CalEEMod Version: CalEEMod.2016.3.1 Page 7 of 29 Date: 2/8/2017 5:03 PM

Energy Security and Resilience - San Diego County, Annual
3.2 Demolition - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Off-Road 6.0500e0030.0525 0.0396 6.0000e0053.6600e0033.6600e0033.4900e0033.4900e0030.0000 5.3492 5.3492 1.0500e0030.0000 5.3755

Total 6.0500e0030.0525 0.0396 6.0000e0053.6600e0033.6600e0033.4900e0033.4900e0030.0000 5.3492 5.3492 1.0500e0030.0000 5.3755

Mitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 2.4000e0041.9000e0041.8400e0030.0000 4.0000e0040.0000 4.0000e0041.1000e0040.0000 1.1000e0040.0000 0.3971 0.3971 1.0000e0050.0000 0.3974

Total 2.4000e0041.9000e0041.8400e0030.0000 4.0000e0040.0000 4.0000e0041.1000e0040.0000 1.1000e0040.0000 0.3971 0.3971 1.0000e0050.0000 0.3974

Mitigated Construction Off-Site

CalEEMod Version: CalEEMod.2016.3.1 Page 8 of 29 Date: 2/8/2017 5:03 PM

Energy Security and Resilience - San Diego County, Annual
3.3 Site Preparation - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Fugitive Dust 2.7000e0040.0000 2.7000e0043.0000e0050.0000 3.0000e0050.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Off-Road 4.3000e0045.2600e0032.1800e0030.0000 2.4000e0042.4000e0042.2000e0042.2000e0040.0000 0.4534 0.4534 1.4000e0040.0000 0.4569

Total 4.3000e0045.2600e0032.1800e0030.0000 2.7000e0042.4000e0045.1000e0043.0000e0052.2000e0042.5000e0040.0000 0.4534 0.4534 1.4000e0040.0000 0.4569

Unmitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 1.0000e0051.0000e0059.0000e0050.0000 2.0000e0050.0000 2.0000e0051.0000e0050.0000 1.0000e0050.0000 0.0199 0.0199 0.0000 0.0000 0.0199

Total 1.0000e0051.0000e0059.0000e0050.0000 2.0000e0050.0000 2.0000e0051.0000e0050.0000 1.0000e0050.0000 0.0199 0.0199 0.0000 0.0000 0.0199

Unmitigated Construction Off-Site

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Energy Security and Resilience - San Diego County, Annual
3.3 Site Preparation - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Fugitive Dust 2.7000e0040.0000 2.7000e0043.0000e0050.0000 3.0000e0050.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Off-Road 4.3000e0045.2600e0032.1800e0030.0000 2.4000e0042.4000e0042.2000e0042.2000e0040.0000 0.4534 0.4534 1.4000e0040.0000 0.4569

Total 4.3000e0045.2600e0032.1800e0030.0000 2.7000e0042.4000e0045.1000e0043.0000e0052.2000e0042.5000e0040.0000 0.4534 0.4534 1.4000e0040.0000 0.4569

Mitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 1.0000e0051.0000e0059.0000e0050.0000 2.0000e0050.0000 2.0000e0051.0000e0050.0000 1.0000e0050.0000 0.0199 0.0199 0.0000 0.0000 0.0199

Total 1.0000e0051.0000e0059.0000e0050.0000 2.0000e0050.0000 2.0000e0051.0000e0050.0000 1.0000e0050.0000 0.0199 0.0199 0.0000 0.0000 0.0199

Mitigated Construction Off-Site

CalEEMod Version: CalEEMod.2016.3.1 Page 10 of 29 Date: 2/8/2017 5:03 PM

Energy Security and Resilience - San Diego County, Annual
3.4 Grading - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Fugitive Dust 7.5000e0040.0000 7.5000e0044.1000e0040.0000 4.1000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Off-Road 1.2100e0030.0105 7.9200e0031.0000e0057.3000e0047.3000e0047.0000e0047.0000e0040.0000 1.0699 1.0699 2.1000e0040.0000 1.0751

Total 1.2100e0030.0105 7.9200e0031.0000e0057.5000e0047.3000e0041.4800e0034.1000e0047.0000e0041.1100e0030.0000 1.0699 1.0699 2.1000e0040.0000 1.0751

Unmitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 5.0000e0054.0000e0053.7000e0040.0000 8.0000e0050.0000 8.0000e0052.0000e0050.0000 2.0000e0050.0000 0.0794 0.0794 0.0000 0.0000 0.0795

Total 5.0000e0054.0000e0053.7000e0040.0000 8.0000e0050.0000 8.0000e0052.0000e0050.0000 2.0000e0050.0000 0.0794 0.0794 0.0000 0.0000 0.0795

Unmitigated Construction Off-Site

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Energy Security and Resilience - San Diego County, Annual
3.4 Grading - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Fugitive Dust 7.5000e0040.0000 7.5000e0044.1000e0040.0000 4.1000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Off-Road 1.2100e0030.0105 7.9200e0031.0000e0057.3000e0047.3000e0047.0000e0047.0000e0040.0000 1.0699 1.0699 2.1000e0040.0000 1.0751

Total 1.2100e0030.0105 7.9200e0031.0000e0057.5000e0047.3000e0041.4800e0034.1000e0047.0000e0041.1100e0030.0000 1.0699 1.0699 2.1000e0040.0000 1.0751

Mitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 5.0000e0054.0000e0053.7000e0040.0000 8.0000e0050.0000 8.0000e0052.0000e0050.0000 2.0000e0050.0000 0.0794 0.0794 0.0000 0.0000 0.0795

Total 5.0000e0054.0000e0053.7000e0040.0000 8.0000e0050.0000 8.0000e0052.0000e0050.0000 2.0000e0050.0000 0.0794 0.0794 0.0000 0.0000 0.0795

Mitigated Construction Off-Site

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Energy Security and Resilience - San Diego County, Annual
3.5 Building Construction - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Off-Road 0.0641 0.6380 0.4035 5.7000e0040.0430 0.0430 0.0395 0.0395 0.0000 52.8851 52.8851 0.0162 0.0000 53.2902

Total 0.0641 0.6380 0.4035 5.7000e0040.0430 0.0430 0.0395 0.0395 0.0000 52.8851 52.8851 0.0162 0.0000 53.2902

Unmitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Unmitigated Construction Off-Site

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Energy Security and Resilience - San Diego County, Annual
3.5 Building Construction - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Off-Road 0.0641 0.6380 0.4035 5.7000e0040.0430 0.0430 0.0395 0.0395 0.0000 52.8850 52.8850 0.0162 0.0000 53.2901

Total 0.0641 0.6380 0.4035 5.7000e0040.0430 0.0430 0.0395 0.0395 0.0000 52.8850 52.8850 0.0162 0.0000 53.2901

Mitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Mitigated Construction Off-Site

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Energy Security and Resilience - San Diego County, Annual
3.6 Paving - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Off-Road 2.6300e0030.0249 0.0184 3.0000e0051.5200e0031.5200e0031.4100e0031.4100e0030.0000 2.4610 2.4610 6.8000e0040.0000 2.4781

Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Total 2.6300e0030.0249 0.0184 3.0000e0051.5200e0031.5200e0031.4100e0031.4100e0030.0000 2.4610 2.4610 6.8000e0040.0000 2.4781

Unmitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 2.1000e0041.7000e0041.6500e0030.0000 3.6000e0040.0000 3.6000e0041.0000e0040.0000 1.0000e0040.0000 0.3574 0.3574 1.0000e0050.0000 0.3577

Total 2.1000e0041.7000e0041.6500e0030.0000 3.6000e0040.0000 3.6000e0041.0000e0040.0000 1.0000e0040.0000 0.3574 0.3574 1.0000e0050.0000 0.3577

Unmitigated Construction Off-Site

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Energy Security and Resilience - San Diego County, Annual
3.6 Paving - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Off-Road 2.6300e0030.0249 0.0184 3.0000e0051.5200e0031.5200e0031.4100e0031.4100e0030.0000 2.4610 2.4610 6.8000e0040.0000 2.4781

Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Total 2.6300e0030.0249 0.0184 3.0000e0051.5200e0031.5200e0031.4100e0031.4100e0030.0000 2.4610 2.4610 6.8000e0040.0000 2.4781

Mitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 2.1000e0041.7000e0041.6500e0030.0000 3.6000e0040.0000 3.6000e0041.0000e0040.0000 1.0000e0040.0000 0.3574 0.3574 1.0000e0050.0000 0.3577

Total 2.1000e0041.7000e0041.6500e0030.0000 3.6000e0040.0000 3.6000e0041.0000e0040.0000 1.0000e0040.0000 0.3574 0.3574 1.0000e0050.0000 0.3577

Mitigated Construction Off-Site

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Energy Security and Resilience - San Diego County, Annual
3.7 Architectural Coating - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Archit. Coating 0.0116 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Off-Road 8.3000e0045.4600e0034.6700e0031.0000e0054.3000e0044.3000e0044.3000e0044.3000e0040.0000 0.6383 0.6383 7.0000e0050.0000 0.6400

Total 0.0124 5.4600e0034.6700e0031.0000e0054.3000e0044.3000e0044.3000e0044.3000e0040.0000 0.6383 0.6383 7.0000e0050.0000 0.6400

Unmitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Unmitigated Construction Off-Site

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Energy Security and Resilience - San Diego County, Annual
4.0 Operational Detail - Mobile

3.7 Architectural Coating - 2017

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Archit. Coating 0.0116 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Off-Road 8.3000e0045.4600e0034.6700e0031.0000e0054.3000e0044.3000e0044.3000e0044.3000e0040.0000 0.6383 0.6383 7.0000e0050.0000 0.6400

Total 0.0124 5.4600e0034.6700e0031.0000e0054.3000e0044.3000e0044.3000e0044.3000e0040.0000 0.6383 0.6383 7.0000e0050.0000 0.6400

Mitigated Construction On-Site

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Mitigated Construction Off-Site

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Energy Security and Resilience - San Diego County, Annual
ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Mitigated 1.9100e0038.5900e0030.0231 7.0000e0055.7900e0038.0000e0055.8700e0031.5500e0038.0000e0051.6300e0030.0000 6.5847 6.5847 3.7000e0040.0000 6.5940

Unmitigated 1.9100e0038.5900e0030.0231 7.0000e0055.7900e0038.0000e0055.8700e0031.5500e0038.0000e0051.6300e0030.0000 6.5847 6.5847 3.7000e0040.0000 6.5940

4.1 Mitigation Measures Mobile

4.2 Trip Summary Information

4.3 Trip Type Information

Average Daily Trip Rate Unmitigated Mitigated

Land Use Weekday Saturday Sunday Annual VMT Annual VMT

General Light Industry 6.97 1.32 0.68 15,369 15,369

Total 6.97 1.32 0.68 15,369 15,369

Miles Trip % Trip Purpose %

Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by

General Light Industry 9.50 7.30 7.30 59.00 28.00 13.00 92 5 3

4.4 Fleet Mix

Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH

General Light Industry 0.581689 0.044135 0.186694 0.113515 0.018244 0.005600 0.015197 0.022573 0.001888 0.002088 0.006279 0.000742 0.001357

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Energy Security and Resilience - San Diego County, Annual
5.0 Energy Detail

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Electricity 

Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 2.6453 2.6453 1.1000e0042.0000e0052.6546

Electricity 

Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 2.7615 2.7615 1.1000e0042.0000e0052.7712

NaturalGas 

Mitigated

6.0000e0055.1000e0044.3000e0040.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0000 0.5536 0.5536 1.0000e0051.0000e0050.5569

NaturalGas 

Unmitigated

6.0000e0055.7000e0044.8000e0040.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0000 0.6185 0.6185 1.0000e0051.0000e0050.6222

5.1 Mitigation Measures Energy

Exceed Title 24

Historical Energy Use: N

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Energy Security and Resilience - San Diego County, Annual
5.2 Energy by Land Use - NaturalGas

NaturalGa

s Use

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Land Use kBTU/yr tons/yr MT/yr

General Light 

Industry

11590 6.0000e0055.7000e0044.8000e0040.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0000 0.6185 0.6185 1.0000e0051.0000e0050.6222

Total 6.0000e0055.7000e0044.8000e0040.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0000 0.6185 0.6185 1.0000e0051.0000e0050.6222

Unmitigated

NaturalGa

s Use

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Land Use kBTU/yr tons/yr MT/yr

General Light 

Industry

10374.8 6.0000e0055.1000e0044.3000e0040.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0000 0.5536 0.5536 1.0000e0051.0000e0050.5569

Total 6.0000e0055.1000e0044.3000e0040.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0000 0.5536 0.5536 1.0000e0051.0000e0050.5569

Mitigated

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Energy Security and Resilience - San Diego County, Annual
6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity

Electricity 

Use

Total CO2 CH4 N2O CO2e

Land Use kWh/yr MT/yr

General Light 

Industry

8450 2.7615 1.1000e0042.0000e0052.7712

Total 2.7615 1.1000e0042.0000e0052.7712

Unmitigated

Electricity 

Use

Total CO2 CH4 N2O CO2e

Land Use kWh/yr MT/yr

General Light 

Industry

8094.4 2.6453 1.1000e0042.0000e0052.6546

Total 2.6453 1.1000e0042.0000e0052.6546

Mitigated

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Energy Security and Resilience - San Diego County, Annual
ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Mitigated 5.0700e0030.0000 1.0000e0050.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e0052.0000e0050.0000 0.0000 2.0000e005

Unmitigated 5.0700e0030.0000 1.0000e0050.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e0052.0000e0050.0000 0.0000 2.0000e005

6.2 Area by SubCategory

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

SubCategory tons/yr MT/yr

Architectural 

Coating

1.1600e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Consumer 

Products

3.9100e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Landscaping 0.0000 0.0000 1.0000e0050.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e0052.0000e0050.0000 0.0000 2.0000e005

Total 5.0700e0030.0000 1.0000e0050.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e0052.0000e0050.0000 0.0000 2.0000e005

Unmitigated

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Energy Security and Resilience - San Diego County, Annual
Apply Water Conservation Strategy

7.1 Mitigation Measures Water

7.0 Water Detail

6.2 Area by SubCategory

ROG NOx CO SO2 Fugitive 

PM10

Exhaust 

PM10

PM10 

Total

Fugitive 

PM2.5

Exhaust 

PM2.5

PM2.5 

Total

Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e

SubCategory tons/yr MT/yr

Architectural 

Coating

1.1600e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Consumer 

Products

3.9100e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

Landscaping 0.0000 0.0000 1.0000e0050.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e0052.0000e0050.0000 0.0000 2.0000e005

Total 5.0700e0030.0000 1.0000e0050.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2.0000e0052.0000e0050.0000 0.0000 2.0000e005

Mitigated

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Energy Security and Resilience - San Diego County, Annual
Total CO2 CH4 N2O CO2e

Category MT/yr

Mitigated 0.8459 6.0600e0031.5000e0041.0418

Unmitigated 1.0574 7.5700e0031.9000e0041.3023

7.2 Water by Land Use

Indoor/Out

door Use

Total CO2 CH4 N2O CO2e

Land Use Mgal MT/yr

General Light 

Industry

0.23125 / 

0

1.0574 7.5700e0031.9000e0041.3023

Total 1.0574 7.5700e0031.9000e0041.3023

Unmitigated

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Energy Security and Resilience - San Diego County, Annual
8.1 Mitigation Measures Waste

Institute Recycling and Composting Services

7.2 Water by Land Use

Indoor/Out

door Use

Total CO2 CH4 N2O CO2e

Land Use Mgal MT/yr

General Light 

Industry

0.185 / 0 0.8459 6.0600e0031.5000e0041.0418

Total 0.8459 6.0600e0031.5000e0041.0418

Mitigated

8.0 Waste Detail

CalEEMod Version: CalEEMod.2016.3.1 Page 26 of 29 Date: 2/8/2017 5:03 PM

Energy Security and Resilience - San Diego County, Annual
Total CO2 CH4 N2O CO2e

MT/yr

 Mitigated 0.0629 3.7200e0030.0000 0.1559

 Unmitigated 0.2517 0.0149 0.0000 0.6236

Category/Year

8.2 Waste by Land Use

Waste 

Disposed

Total CO2 CH4 N2O CO2e

Land Use tons MT/yr

General Light 

Industry

1.24 0.2517 0.0149 0.0000 0.6236

Total 0.2517 0.0149 0.0000 0.6236

Unmitigated

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Energy Security and Resilience - San Diego County, Annual
11.0 Vegetation

8.2 Waste by Land Use

Waste 

Disposed

Total CO2 CH4 N2O CO2e

Land Use tons MT/yr

General Light 

Industry

0.31 0.0629 3.7200e0030.0000 0.1559

Total 0.0629 3.7200e0030.0000 0.1559

Mitigated

9.0 Operational Offroad

Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment

Fire Pumps and Emergency Generators

Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type

Boilers

Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type

User Defined Equipment

Equipment Type Number

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Energy Security and Resilience - San Diego County, Annual
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Energy Security and Resilience - San Diego County, Annual
D-1

Appendix D

Appendix D

Noise Calculations
Roadway Construction Noise Model (RCNM),Version 1.1

Report date: 12/14/2016

Case Description: NAV-03.10 - NBSD

---- Receptor #1 ----

Baselines (dBA)

Description Land Use Daytime Evening Night

Chapel (Demo) Residential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Dozer No 40 81.7 1575 0

Front End Loader No 40 79.1 1575 0

Front End Loader No 40 79.1 1575 0

Concrete Saw No 20 89.6 1575 0

Concrete Saw No 20 89.6 1575 0

Calculated (dBA)

Equipment *Lmax Leq

Dozer 51.7 47.7

Front End Loader 49.1 45.2

Front End Loader 49.1 45.2

Concrete Saw 59.6 52.6

Concrete Saw 59.6 52.6

Total 59.6 56.9

*Calculated Lmax is the Loudest value.
Roadway Construction Noise Model (RCNM),Version 1.1

Report date: 12/14/2016

Case Description: NAV-03.10 - NBSD

---- Receptor #2 ----

Baselines (dBA)

Description Land Use Daytime Evening Night

Chapel (Site Prep) Residential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Grader No 40 85 1575 0

Front End Loader No 40 79.1 1575 0

Front End Loader No 40 79.1 1575 0

Calculated (dBA)

Equipment *Lmax Leq

Grader 55 51.1

Front End Loader 49.1 45.2

Front End Loader 49.1 45.2

Total 55 52.9

*Calculated Lmax is the Loudest value.
Roadway Construction Noise Model (RCNM),Version 1.1

Report date: 12/14/2016

Case Description: NAV-03.10 - NBSD

---- Receptor #3 ----

Baselines (dBA)

Description Land Use Daytime Evening Night

Chapel (Grading) Residential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Dozer No 40 81.7 1575 0

Concrete Saw No 20 89.6 1575 0

Front End Loader No 40 79.1 1575 0

Front End Loader No 40 79.1 1575 0

Calculated (dBA)

Equipment *Lmax Leq

Dozer 51.7 47.7

Concrete Saw 59.6 52.6

Front End Loader 49.1 45.2

Front End Loader 49.1 45.2

Total 59.6 54.9

*Calculated Lmax is the Loudest value.
Roadway Construction Noise Model (RCNM),Version 1.1

Report date: 12/14/2016

Case Description: NAV-03.10 - NBSD

---- Receptor #4 ----

Baselines (dBA)

Description Land Use Daytime Evening Night

Chapel (Construction) Residential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Crane No 16 80.6 1575 0

Tractor No 40 84 1575 0

Tractor No 40 84 1575 0

Front End Loader No 40 79.1 1575 0

Front End Loader No 40 79.1 1575 0

Calculated (dBA)

Equipment *Lmax Leq

Crane 50.6 42.6

Tractor 54 50.1

Tractor 54 50.1

Front End Loader 49.1 45.2

Front End Loader 49.1 45.2

Total 54 54.6

*Calculated Lmax is the Loudest value.
Roadway Construction Noise Model (RCNM),Version 1.1

Report date: 12/14/2016

Case Description: NAV-03.10 - NBSD

---- Receptor #5 ----

Baselines (dBA)

Description Land Use Daytime Evening Night

Chapel (Coatings) Residential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Compressor (air) No 40 77.7 1575 0

Calculated (dBA)

Equipment *Lmax Leq

Compressor (air) 47.7 43.7

Total 47.7 43.7

*Calculated Lmax is the Loudest value.
Roadway Construction Noise Model (RCNM),Version 1.1

Report date: 12/14/2016

Case Description: NAV-03.10 - NBSD

---- Receptor #6 ----

Baselines (dBA)

Description Land Use Daytime Evening Night

Chapel (Paving) Residential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Paver No 50 77.2 1575 0

Roller No 20 80 1575 0

Front End Loader No 40 79.1 1575 0

Concrete Mixer Truck No 40 78.8 1575 0

Concrete Mixer Truck No 40 78.8 1575 0

Concrete Mixer Truck No 40 78.8 1575 0

Concrete Mixer Truck No 40 78.8 1575 0

Calculated (dBA)

Equipment *Lmax Leq

Paver 47.3 44.2

Roller 50 43

Front End Loader 49.1 45.2

Concrete Mixer Truck 48.8 44.9

Concrete Mixer Truck 48.8 44.9

Concrete Mixer Truck 48.8 44.9

Concrete Mixer Truck 48.8 44.9

Total 50 53.1

*Calculated Lmax is the Loudest value.
Roadway Construction Noise Model (RCNM),Version 1.1

Report dat 2/2/2017

Case DescrNAV‐03.10 ‐ NBSD (Alt 2)

‐‐‐‐ Receptor #1 ‐‐‐‐

Baselines (dBA)

DescriptionLand Use Daytime Evening Night

Hotel (Site Residential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Paver No 50 77.2 1640 0

Roller No 20 80 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Front End Loader No 40 79.1 1640 0

Results

Calculated (dBA)

Day

Equipment *Lmax Leq Lmax

Paver 46.9 43.9 N/A

Roller 49.7 42.7 N/A

Concrete Mixer Truck 48.5 44.5 N/A

Concrete Mixer Truck 48.5 44.5 N/A

Concrete Mixer Truck 48.5 44.5 N/A

Concrete Mixer Truck 48.5 44.5 N/A

Front End Loader 48.8 44.8 N/A

Total 54.7 52.5 N/A

*Calculated Lmax is the Loudest value.
‐‐‐‐ Receptor #2 ‐‐‐‐

Baselines (dBA)

DescriptionLand Use Daytime Evening Night

Hotel (GradResidential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Paver No 50 77.2 1640 0

Roller No 20 80 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Front End Loader No 40 79.1 1640 0

Calculated (dBA)

Equipment *Lmax Leq

Paver 46.9 43.9

Roller 49.7 42.7

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Front End Loader 48.8 44.8

Total 59.3 54.5

*Calculated Lmax is the Loudest value.
‐‐‐‐ Receptor #3 ‐‐‐‐

Baselines (dBA)

DescriptionLand Use Daytime Evening Night

Hotel (Con Residential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Paver No 50 77.2 1640 0

Roller No 20 80 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Front End Loader No 40 79.1 1640 0

Calculated (dBA)

Equipment *Lmax Leq

Paver 46.9 43.9

Roller 49.7 42.7

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Front End Loader 48.8 44.8

Total 53.7 54.2

*Calculated Lmax is the Loudest value.
‐‐‐‐ Receptor #4 ‐‐‐‐

Baselines (dBA)

DescriptionLand Use Daytime Evening Night

Hotel (CoatResidential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Paver No 50 77.2 1640 0

Roller No 20 80 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Front End Loader No 40 79.1 1640 0

Calculated (dBA)

Equipment *Lmax Leq

Paver 46.9 43.9

Roller 49.7 42.7

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Front End Loader 48.8 44.8

Total 47.4 43.4

*Calculated Lmax is the Loudest value.
‐‐‐‐ Receptor #5 ‐‐‐‐

Baselines (dBA)

DescriptionLand Use Daytime Evening Night

Hotel (PaviResidential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Paver No 50 77.2 1640 0

Roller No 20 80 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Concrete Mixer Truck No 40 78.8 1640 0

Front End Loader No 40 79.1 1640 0

Calculated (dBA)

Equipment *Lmax Leq

Paver 46.9 43.9

Roller 49.7 42.7

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Concrete Mixer Truck 48.5 44.5

Front End Loader 48.8 44.8

Total 49.7 52.7

*Calculated Lmax is the Loudest value.
‐‐‐‐ Receptor #6 ‐‐‐‐

Baselines (dBA)

DescriptionLand Use Daytime Evening Night

Residential 75 75 75

Equipment

Spec Actual Receptor Estimated

Impact Lmax Lmax Distance Shielding

Description Device Usage(%) (dBA) (dBA) (feet) (dBA)

Paver No 50 77.2 1575 0

Roller No 20 80 1575 0

Concrete Mixer Truck No 40 78.8 1575 0

Concrete Mixer Truck No 40 78.8 1575 0

Concrete Mixer Truck No 40 78.8 1575 0

Concrete Mixer Truck No 40 78.8 1575 0

Front End Loader No 40 79.1 0 0

Calculated (dBA)

Equipment *Lmax Leq

Paver 47.3 44.2

Roller 50 43

Concrete Mixer Truck 48.8 44.9

Concrete Mixer Truck 48.8 44.9

Concrete Mixer Truck 48.8 44.9

Concrete Mixer Truck 48.8 44.9

Front End Loader 0

Total 50 53.1

*Calculated Lmax is the Loudest value.