April 2015

Marine Corps Air Station Miramar

San Diego, California

Draft Environmental Assessment

MCAS Miramar Vernal Pool Mitigation Area Planning
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Draft

Environmental Assessment

Abstract

1 Lead Agency for the EA: United States Marine Corps Air Station Miramar

2 Title of Proposed Action: Vernal Pool Mitigation Area Planning at Marine Corps Air Station 

3 Miramar

4 Affected Region: San Diego, San Diego County, CA

5 Designation: Draft Environmental Assessment

6 The United States (U.S.) Marine Corps Air Station (MCAS) Miramar has prepared this Draft 

7 Environmental Assessment (EA) in accordance with the National Environmental Policy Act (NEPA) 

8 of 1969; 42 United States Code §§ 4321–4370h, as implemented by the Council on Environmental Quality

9 regulations, 40 Code of Federal Regulations Parts 1500–1508; and Marine Corps Order P5090.2A, 

10 Change 3, Chapter 12, 26 August 2013, Environmental Compliance and Protection Manual, which 

11 establishes procedures for implementing NEPA. The purpose of the proposed action is to establish and 

12 manage proposed mitigation areas at MCAS Miramar to compensate for impacts to federally listed vernal 

13 pool species and/or jurisdictional Waters of the U.S. Proposed mitigation areas would be used in the 

14 future as part of a long-term mitigation/conservation strategy developed in coordination with the 

15 U.S. Fish and Wildlife Service (USFWS) and U.S. Army Corps of Engineers (USACE) with the objective 

16 of streamlining compensatory mitigation and reducing project by project cost. This is needed to maintain 

17 flexibility to implement new actions at the Station, such as adding new land uses, facilities, or training 

18 areas, and to mitigate for adverse impacts to federally listed vernal pool species and jurisdictional Waters

19 of the U.S. This EA analyzes three (3) alternatives and the No Action Alternative.

20 Point of Contact: Commanding Officer, MCAS Miramar

21 Environmental Management Department

22 P.O. Box 452001, Building 6306

23 San Diego, California 92145-2001

Phone: (858) 577-1108, Fax: (858) 577-4200

24 Contracting Officer’s

25 Technical Representative: Ms. Rachelle Hill

26 Naval Facilities Engineering Command, Southwest

27 1220 Pacific Highway

28 San Diego, California 92132-5182

29 Phone: (619) 532-4468

April 2015
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Table of Contents

1 Abstract

2 List of Figures..............................................................................................................................................iii

3 List of Tables...............................................................................................................................................iii

4 Acronyms and Abbreviations ....................................................................................................................... v

5 Executive Summary................................................................................................................................ ES-1

6 1 Purpose and Need for Proposed Action ........................................................................................1-1

7 1.1 Introduction......................................................................................................................1-1

8 1.2 Background......................................................................................................................1-1

9 1.2.1 MCAS Miramar Mission ....................................................................................1-1

10 1.2.2 MCAS Miramar Environmental Management....................................................1-3

11 1.2.3 Compensatory Mitigation and Conservation/Mitigation Banking Background ...........1-3

12 1.3 Location ...........................................................................................................................1-4

13 1.4 Purpose and Need ............................................................................................................1-4

14 1.5 Regulatory Setting and Intergovernmental Coordination ................................................1-5

15 1.6 Scope of Analysis ............................................................................................................1-6

16 1.7 Public Involvement..........................................................................................................1-8

17 2 Proposed Action and Alternatives ................................................................................................2-1

18 2.1 Proposed Action...............................................................................................................2-1

19 2.1.1 Overview of the Proposed Action.......................................................................2-1

20 2.1.2 Site-Selection Process.........................................................................................2-7

21 2.1.3 Proposed Mitigation Areas ...............................................................................2-12

22 2.2 Alternatives to the Proposed Action and the No Action Alternative.............................2-14

23 2.2.1 Alternative 1: Full Mitigation Area (Preferred Alternative).............................2-15

24 2.2.2 Alternative 2: Partial Configuration A (Areas Alpha, Bravo North, Delta, 

25 and Echo)..........................................................................................................2-15

26 2.2.3 Alternative 3: Partial Configuration B (Areas Charlie, Delta, Echo, 

27 and Foxtrot) ......................................................................................................2-16

28 2.2.4 No Action Alternative.......................................................................................2-16

29 2.2.5 Alternatives Considered but Eliminated...........................................................2-17

30 2.3 Environmental Protection Measures..............................................................................2-18

31 2.3.1 General Measures .............................................................................................2-18

32 2.3.2 Specific Protection Measures............................................................................2-19

33 2.4 Summary of Impacts......................................................................................................2-22

34 3 Affected Environment and Environmental Consequences ...........................................................3-1

35 3.1 Air Quality .......................................................................................................................3-1

36 3.1.1 Definition of Resource........................................................................................3-1

37 3.1.2 Region of Influence ............................................................................................3-2

38 3.1.3 Affected Environment.........................................................................................3-3

39 3.1.4 Applicable Regulations and Standards ...............................................................3-4

40 3.1.5 Environmental Consequences.............................................................................3-6

41 3.2 Biology.............................................................................................................................3-8

42 3.2.1 Definition of Resource........................................................................................3-8

43 3.2.2 Region of Influence ............................................................................................3-8

44 3.2.3 Affected Environment.........................................................................................3-9

45 3.2.4 Environmental Consequences...........................................................................3-26

46 3.3 Cultural Resources.........................................................................................................3-41

47 3.3.1 Definition of Resource......................................................................................3-41
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1 3.3.2 Definition of the Area of Potential Effects.......................................................3-41

2 3.3.3 Affected Environment.......................................................................................3-41

3 3.3.4 Environmental Consequences...........................................................................3-44

4 3.4 Geologic Resources .......................................................................................................3-47

5 3.4.1 Definition of Resource......................................................................................3-47

6 3.4.2 Region of Influence ..........................................................................................3-47

7 3.4.3 Affected Environment.......................................................................................3-47

8 3.4.4 Environmental Consequences...........................................................................3-48

9 3.5 Land Use........................................................................................................................3-50

10 3.5.1 Definition of Resource......................................................................................3-50

11 3.5.2 Region of Influence ..........................................................................................3-50

12 3.5.3 Affected Environment.......................................................................................3-50

13 3.5.4 Environmental Consequences...........................................................................3-53

14 3.6 Public Health and Safety................................................................................................3-55

15 3.6.1 Definition of Resource......................................................................................3-55

16 3.6.2 Region of Influence ..........................................................................................3-55

17 3.6.3 Affected Environment.......................................................................................3-55

18 3.6.4 Environmental Consequences...........................................................................3-58

19 3.7 Water Resources............................................................................................................3-60

20 3.7.1 Definition of Resource......................................................................................3-60

21 3.7.2 Region of Influence ..........................................................................................3-60

22 3.7.3 Affected Environment.......................................................................................3-60

23 3.7.4 Environmental Consequences...........................................................................3-62

24 4 Cumulative Impacts......................................................................................................................4-1

25 4.1 Projects Considered in the Cumulative Analysis.............................................................4-1

26 4.1.1 Sewer Line Equalization Tanks..........................................................................4-1

27 4.1.2 Fort Rosecrans National Cemetery Annex .........................................................4-7

28 4.1.3 West Coast Basing of the MV-22 .......................................................................4-7

29 4.1.4 West Coast Basing of the F-35B.........................................................................4-7

30 4.1.5 United States Army Reserve Center...................................................................4-8

31 4.1.6 Wet Weather In-stream Discharge......................................................................4-8

32 4.1.7 Miscellaneous Non-Federal Projects..................................................................4-8

33 4.2 Cumulative Impact Analysis............................................................................................4-9

34 4.2.1 Air Quality..........................................................................................................4-9

35 4.2.2 Biological Resources........................................................................................4-11

36 5 List of Personnel or Agencies Contacted or Consulted ................................................................5-1

37 6 List of Preparers............................................................................................................................6-1

38 7 References.....................................................................................................................................7-1

Appendices

39 Appendix A Agency Correspondence

40 Appendix B Stakeholder Meeting

41 Appendix C Record of Non-Applicability (RONA)
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List of Figures

1 1-1 Regional Map including Proposed Mitigation Areas..........................................................1-2

2 2-1 MCAS Miramar Proposed Mitigation Area Conceptual Layout.......................................2-11

3 3-1 Vegetation Mapping within the Proposed Mitigation Areas.............................................3-10

4 3-2 Historic and Recent Coastal California Gnatcatcher Occurrences in the Vicinity of 

5 Proposed Mitigation Areas................................................................................................3-15

6 3-3 Vernal Pool Fairy Shrimp in the Vicinity of Proposed Mitigation Areas.........................3-17

7 3-4 Special Status Plant Species in the Vicinity of the Proposed Mitigation Area .................3-22

8 3-5 Existing Streambeds and Associated Wetlands in the Vicinity of the Proposed 

9 Mitigation Areas ...............................................................................................................3-24

10 3-6 Land Use Sectors and Existing Land Use Constraints......................................................3-51

11 3-7 Installation Restoration and Munitions Response Program Sites in the Vicinity of 

12 Proposed Mitigation Areas................................................................................................3-57

13 3-8 100-Year Floodplain at MCAS Miramar..........................................................................3-63

List of Tables

14 ES-1 Summary of Impacts........................................................................................................ ES-2

15 1-1 Applicable Public Law, Federal Regulations, and Instructions..........................................1-5

16 2-1 Conceptual Performance Standards for Vernal Pool Wetland Habitat Restoration............2-8

17 2-2 Approximate Size of the Proposed Mitigation Areas, Suitable Sites for Vernal Pool 

18 Restoration, and Potential Vernal Pool Basin Area Realized for Mitigation 

19 Purposes............................................................................................................................2-10

20 2-3 Approximate Size of the Proposed Mitigation Areas and Potential Vernal Pool 

21 Basin Area for Alternatives 1 through 3 and the No Action Alternative ..........................2-14

22 2-4 Summary of Impacts.........................................................................................................2-23

23 3-1 National Ambient Air Quality Standards............................................................................3-2

24 3-2 Existing Vegetation Communities within the Proposed Mitigation Areas.........................3-9

25 3-3 Special Status Wildlife Occurring in the Vicinity of the Proposed Mitigation Areas.......3-13

26 3-4 Avian Species of Concern under the MBTA Known to Occur in the Vicinity of the 

27 Proposed Mitigation Areas................................................................................................3-18

28 3-5 Special Status Plants Occurring in the Vicinity of Proposed Mitigation Areas................3-20

29 3-6 Vegetation Communities in Alternative 1.........................................................................3-28

30 3-7 Vegetation Communities in Alternative 2 (Proposed Mitigation Areas Alpha, 

31 Bravo North, Delta, and Echo)..........................................................................................3-34

32 3-8 Vegetation Communities in Alternative 3 (Proposed Mitigation Areas Charlie, 

33 Delta, Echo, and Foxtrot)..................................................................................................3-37

34 3-9 Cultural Resources in the Project APE .............................................................................3-43

35 4-1 Related and Cumulative Projects........................................................................................4-2
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Acronyms and Abbreviations

1 AICUZ Air Installations Compatible Use Zones

2 APE Area of Potential Effects

3 APZ accident potential zone

4 BMP best management practice

5 BP before present

6 BRAC Base Realignment and Closure

7 CAA Clean Air Act

8 California ARB California Air Resources Board

9 CDFW California Department of Fish and Wildlife

10 CEQ Council on Environmental Quality

11 CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

12 CFR Code of Federal Regulations

13 CH4 methane

14 CNEL Community Noise Equivalent Level

15 CO carbon monoxide

16 CO2 carbon dioxide

17 CO2e CO2 equivalent 

18 CP&L Community Plans and Liaison Office

19 CWA Clean Water Act

20 dBA decibels A-weighted

21 DERP Defense Environmental Restoration Program

22 DoD Department of Defense

23 DODINST DoD Instruction

24 DoN Department of the Navy

25 EA Environmental Assessment

26 EIS Environmental Impact Statement

27 EMD Environmental Management Department

28 EO Executive Order

29 EOD Explosive Ordnance Disposal

30 EPA United States Environmental Protection Agency

31 ESA Endangered Species Act

32 ESO Explosive Safety Officer

33 ESS Explosives Safety Submission

34 FEMA Federal Emergency Management Agency

35 FONSI Finding of No Significant Impact

36 FUDS formerly used defense sites

37 GHG greenhouse gas

38 GIS geographic information system

39 GWP global warming potential

40 HAP hazardous air pollutant

41 HQMC Headquarters Marine Corps

42 I- Interstate

43 I&L Installations and Logistics

44 ICRMP Integrated Cultural Resources Management Plan

45 I MEF First Marine Expeditionary Force

46 INRMP Integrated Natural Resources Management Plan

47 IRP Installation Restoration Program

48 LEED Leadership in Energy and Environmental Design

49 LOS level of service

50 MAW Marine Aircraft Wing
MCAS Miramar Acronyms and Abbreviations

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1 MBTA Migratory Bird Treaty Act

2 MCAS Miramar Marine Corps Air Station Miramar

3 MCB Marine Corps Base

4 MCI West Marine Corps Installations West

5 MCICOM Marine Corps Installations Command

6 MCO Marine Corps Order

7 MARCORSYSCOM Marine Corps Systems Command

8 MMRP Military Munitions Response Program

9 MRP Munitions Response Program

10 MRSPP Munitions Response Site Prioritization Protocol

11 N2O nitrous oxide

12 NAAQS National Ambient Air Quality Standards

13 NAS Naval Air Station

14 NAVFAC Naval Facilities Engineering Command

15 NAVFAC SW Naval Facilities Engineering Command Southwest

16 NEPA National Environmental Policy Act

17 NHPA National Historic Preservation Act

18 NOx oxides of nitrogen

19 NOSSA Naval Ordnance Safety and Security Activity

20 NPDES National Pollutant Discharge Elimination System

21 NRHP National Register of Historic Places

22 NVC National Vegetation Classification

23 O3 ozone

24 OPNAVINST Chief of Naval Operations Instruction

25 PA Preliminary Assessment

26 PM2.5 particulate matter less than or equal to 2.5 microns in diameter

27 PM10 particulate matter less than or equal to 10 microns in diameter

28 POL Petroleum, Oil, and Lubricant

29 PSD Prevention of Significant Deterioration

30 PWD Public Works Division

31 RCRA Resource Conservation and Recovery Act

32 RE Real Estate

33 ROD Record of Decision

34 ROI region of influence

35 RONA Record of Non-Applicability

36 RWQCB Regional Water Quality Control Board

37 SDAB San Diego Air Basin

38 SDCAPCD San Diego County Air Pollution Control District

39 SDG&E San Diego Gas and Electric

40 SHPO State Historic Preservation Officer

41 SIP State Implementation Plan

42 SO2 sulfur dioxide

43 SPCC Spill Prevention, Control, and Countermeasures

44 SR- State Route

45 Station Marine Corps Air Station Miramar

46 SWPPP Storm Water Pollution Prevention Plan

47 SWRCB State Water Resources Control Board

48 TAC toxic air contaminant

49 TECOM Commanding General Training and Education Command

50 U.S. United States

51 USACE United States Army Corps of Engineers

52 USC United States Code

53 USFWS United States Fish and Wildlife Service
MCAS Miramar Acronyms and Abbreviations

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1 USMC United States Marine Corps

2 UXO unexploded ordnance

3 VA Department of Veterans Affairs

4 VOC volatile organic compound
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Executive Summary

1 The United States Marine Corps (USMC) has prepared this Environmental Assessment (EA) in 

2 accordance with the National Environmental Policy Act (NEPA) of 1969, 42 United States

3 Code §§ 4321-4370h, as implemented by the Council on Environmental Quality (CEQ) regulations, 

4 40 Code of Federal Regulations Parts 1500-1508, and Marine Corps Order P5090.2A, Change 3, 

5 Chapter 12, dated 26 August 2013, Environmental Compliance and Protection Manual, which establishes 

6 procedures for implementing NEPA. 

7 This EA describes the potential environmental consequences resulting from a proposal by Marine Corps 

8 Air Station (MCAS) Miramar, San Diego, California to establish and manage mitigation areas at MCAS 

9 Miramar to compensate for impacts to federally listed vernal pool species and/or jurisdictional Waters of 

10 the United States (U.S.). Proposed mitigation areas would be used in the future as part of a 

11 mitigation/conservation strategy, which may include a self-use, joint Endangered Species Act and 

12 Clean Water Act conservation/mitigation bank (herein referred to as “conservation/mitigation bank”), 

13 in-lieu fee mitigation program, or for permittee-responsible advanced mitigation. The USMC has 

14 developed three action alternatives: Alternative 1 (Full Mitigation Plan), Alternative 2 (Partial 

15 Configuration A – Areas Alpha, Bravo North, Delta, and Echo), and Alternative 3 (Partial Configuration 

16 B – Areas Charlie, Delta, Echo, and Foxtrot). The alternatives differ in the mix of proposed mitigation 

17 areas that would be implemented.

18 The CEQ regulations, NEPA, and the USMC procedures for implementing NEPA specify that an EA 

19 should address only those resource areas potentially subject to impacts. In addition, the level of analysis 

20 should be equivalent with the anticipated level of environmental impact. Based on this guidance, the 

21 following resource areas were evaluated for potential environmental consequences: Air Quality; 

22 Biological Resources; Cultural Resources; Geologic Resources; Land Use; Public Health and Safety; and 

23 Water Resources. Results of the air quality analysis indicate the emissions would be less than the 

24 General Conformity Rule thresholds which would satisfy the condition of a Clean Air Act Record of 

25 Non-Applicability to be prepared. Several other resource areas have been reviewed for environmental 

26 impacts but have not been carried forward for detailed analysis in this EA because potential impacts were 

27 determined to be negligible, including visual resources, environmental justice and protection of children, 

28 public services, socioeconomics, transportation/circulation/traffic, noise, and utilities.

29 The potential environmental consequences associated with implementation of Alternative 1, 

30 Alternative 2, Alternative 3, and the No Action Alternative are summarized briefly in Table ES-1. As 

31 shown in Table ES-1, implementation of Alternative 1, Alternative 2, Alternative 3, and the No Action 

32 Alternative would not result in significant adverse impacts to any resource area with the inclusion of 

33 Environmental Protection Measures. Beneficial impacts would occur for Biological Resources and Land 

34 Use under all alternatives except the No Action Alternative. Based on the analysis presented in this EA, 

35 the USMC has identified Alternative 1 as the Preferred Alternative.
MCAS Miramar Executive Summary

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Table ES-1. Summary of Impacts

Resource Area

Alternative 1:

Full Mitigation Area

(Preferred Alternative)

Alternative 2:

Partial Configuration A 

(Areas Alpha, Bravo 

North, Delta, and Echo)

Alternative 3:

Partial Configuration B 

(Areas Charlie, Delta, 

Echo, and Foxtrot)

No Action 

Alternative

Air Quality NSI NSI NSI NI

Biological Resources NSI/BI NSI/BI NSI/BI NI

Cultural Resources NSI NSI NSI NI

Geologic Resources NSI NSI NSI NI

Land Use NSI/BI NSI/BI NSI/BI NI

Public Health and Safety NSI NSI NSI NI

Water Resources

NI (Groundwater); 

NSI (Surface Water; 

Floodplains/Flooding; 

Water Quality)

NI (Groundwater); 

NSI (Surface Water; 

Floodplains/Flooding; 

Water Quality)

NI (Groundwater); 

NSI (Surface Water; 

Floodplains/Flooding; 

Water Quality)

NI

Notes: BI = Beneficial Impact; I = Impact; NI = No Impact; NSI = No Significant Impact
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1 Purpose and Need for Proposed Action

1 1.1 Introduction

2 This Environmental Assessment (EA) has been prepared by Marine Corps Air Station Miramar

3 (MCAS Miramar or Station) in accordance with the National Environmental Policy Act (NEPA) of 1969 

4 (42 United States Code [USC] §§ 4321–4370h, as amended), as implemented by the Council on 

5 Environmental Quality (CEQ) Regulations for Implementing the Procedural Provisions of NEPA 

6 (40 Code of Federal Regulations [CFR] Parts 1500–1508). Each federal agency is required to develop its 

7 own regulations that are consistent with NEPA. As such, the Department of Defense (DoD) developed 

8 DoD Instruction (DODINST) 4715.9. The DoD instructs each branch to develop procedures that are specific 

9 to their mission requirements. The Department of the Navy (DoN), which has two unique branches,

10 published DoN regulations at 32 CFR 775 that required the Chief of Naval Operations and the Commandant 

11 of the Marine Corps to create branch-specific procedures. The United States Marine Corps (USMC)

12 Environmental Compliance and Protection Manual (Marine Corps Order [MCO] P5090.2A, Change 3, 

13 Chapter 12, dated 26 August 2013) was created to meet this requirement. All USMC installations, including

14 MCAS Miramar, comply with the MCO P5090.2A and thus, each document referenced above.

15 In addition, NEPA encourages public involvement in the environmental review process, and the 

16 development of this EA includes the public review of this EA. Please refer to Section 1.7 for additional 

17 information regarding the public participation process for the proposed action.

18 Under NEPA, agencies with jurisdiction by law or special expertise with respect to an environmental 

19 impact associated with a proposed action or alternative may be identified as a cooperating agency. Several 

20 federal agencies, including the United States Environmental Protection Agency (EPA), United States 

21 Army Corps of Engineers (USACE), and the United States Fish and Wildlife Service (USFWS), have a

22 regulatory role in approving the wetland habitat development plans and banking instruments for the 

23 proposed action, consistent with applicable policies and regulations of the Endangered Species Act (ESA)

24 and the Federal Water Pollution Control Act (or Clean Water Act [CWA]). Therefore, MCAS Miramar 

25 invited these agencies to participate as federal cooperating agencies with MCAS Miramar in the NEPA 

26 process (Appendix A, Agency Correspondence).

27 This EA presents an analysis of the potential environmental impacts resulting from a proposal to establish 

28 and manage mitigation areas at MCAS Miramar in San Diego, California, to compensate for impacts to 

29 federally listed vernal pool species and/or jurisdictional Waters of the United States (U.S.) (Figure 1-1).

30 Proposed mitigation areas would be used in the future as part of a mitigation/conservation strategy, which 

31 may include a self-use, joint ESA and CWA conservation/mitigation bank (herein referred to as

32 “conservation/mitigation bank”), in-lieu fee mitigation program, or for permittee-responsible advanced

33 mitigation.

34 1.2 Background

35 1.2.1 MCAS Miramar Mission

36 The USMC is required to properly train Marines to meet the training and operational readiness 

37 requirements set forth in USC Title 10, Subtitle C, Part 1, Chapter 507, §5063. MCAS Miramar directly 

38 supports this mission and serves as an area for training, operation of critical West Coast assets, and as

home for the Third Marine Aircraft Wing (3rd MAW). The 3rd 39 MAW serves as the aviation combat 

40 element for the First Marine Expeditionary Force (I MEF) and provides combat-ready, expeditionary 

41 aviation forces capable of short-notice, worldwide deployment to Marine Air Ground Task Force and 

42 Unified Commanders.
MCAS Miramar 1 Purpose and Need for Proposed Action

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Figure 1-1. Regional Map including Proposed Mitigation Areas
MCAS Miramar 1 Purpose and Need for Proposed Action

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The 3rd 1 MAW conducts aviation operations, including offensive air support, anti-air warfare, assault 

2 support, aerial reconnaissance, electronic warfare, and control of aircraft and missiles. To support the 

3rd 3 MAW, MCAS Miramar operates the airfield and provides equipment support for staging, loading and 

unloading, and service assets. MCAS Miramar’s ranges and training areas are used by 3rd 4 MAW ground 

5 support units, other tenant commands, and visiting units. The training areas include live-fire small arms 

6 training, land-based navigation, convoy operations, communications, air traffic control, an aircraft fire 

7 rescue training site, and a nuclear, biological, and chemical training facility.

8 1.2.2 MCAS Miramar Environmental Management

9 MCAS Miramar is subject to restrictions under the CWA and the ESA, among others. The CWA requires 

10 that no jurisdictional Waters of the U.S., including wetlands, shall be impacted unless permitted by the 

USACE, and impacts can be mitigated. The ESA prohibits the “taking”1 11 of federally listed (threatened 

12 and endangered) species unless authorized in consultation with the USFWS. Habitat mitigation may be 

13 proposed as a way to minimize adverse impacts to a listed species. Should any impact to CWA-regulated

14 Waters of the U.S. or federally listed species occur, mitigation may be required as a condition during 

15 consultation. However, opportunities to compensate for these impacts off-Station are rarely available. In 

16 addition, the few off-Station parcels with vernal pool wetland habitat that are available are cost 

17 prohibitive to purchase.

18 Currently, MCAS Miramar consults on impacts to natural resources on a project-by-project basis. 

19 Without a broader mitigation/conservation strategy, projects at MCAS Miramar would have to 

20 individually fund compensatory mitigation for any impacts to federally listed vernal pool species and/or 

21 Waters of the U.S. For smaller projects managed by MCAS Miramar, the costs associated with 

22 implementing mitigation requirements have the potential to exceed the cost thresholds that require 

23 programming as a Military Construction Project. Military Construction Projects must be approved and 

24 funded through the Congressional legislation process, which can take years, making it more difficult for 

25 projects to be implemented within a reasonable time frame.

26 1.2.3 Compensatory Mitigation and Conservation/Mitigation Banking Background

27 To meet the evolving nature of the USMC mission, MCAS Miramar must maintain flexibility to 

28 implement new actions at the Station such as adding new land uses, facilities, or training areas. Given 

29 existing operational and environmental constraints to land use at MCAS Miramar, these actions may 

30 affect natural resources, including federally listed vernal pool species and jurisdictional Waters of the 

31 U.S. As noted above, impacts to these resources require compensatory mitigation where protection and 

32 conservation in place is not possible or feasible. In support of this requirement, the proposed action would

33 establish mitigation areas at the Station in advance of specific project mitigation requirements. These 

34 locations may simply be identified as mitigation areas where project-specific mitigation could occur in the 

35 future. Alternatively, the Station is considering use of the proposed mitigation areas to develop and 

36 conserve a self-use joint CWA and ESA conservation/mitigation bank. Mitigation areas, regardless of 

37 type, would require long-term conservation and protection as necessary elements of conservation or 

38 mitigation banks. Long-term conservation requires compliance with DODINST 4715.03 and possibly 

coordination with the General Services Administration.

2 39

 1 The term ‘take’ as defined under ESA (16 USC Section 1532) means to harass, harm, pursue, hunt, shoot, wound, 

kill, trap, capture, or collect, or to attempt to engage in any such conduct.

2 Conservation and mitigation banks are typically permanently protected lands that contain natural resource values.

Section 13(a)(2) of DODINST 4715.03 details that “DoD components [i.e., USMC] shall not restrict the use of 

DoD fee-owned or withdrawn lands such that the lands may be unavailable for otherwise appropriate mission 

uses.” This and other DoD-specific regulations are discussed in greater detail in Section 2.1.1.1. 
MCAS Miramar 1 Purpose and Need for Proposed Action

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1 Conservation and mitigation banks share many of the same characteristics, primarily because they entail 

2 the restoration and enhancement of a natural resource. The term “conservation bank” refers to lands that 

3 are conserved and managed for species that are endangered, threatened, candidates for listing, or are 

4 otherwise designated species-at-risk under the ESA (USFWS 2012a). Conservation banks contribute to 

5 species recovery and allow for more reliable mitigation of species impacts because they provide habitat to 

6 preserve federally listed species. A “mitigation bank” is a wetland, stream, or other aquatic resource area 

7 (in this case vernal pools) that has been restored, established, enhanced, or (in certain circumstances) 

8 preserved for the purpose of providing compensation for unavoidable impacts to aquatic resources 

9 permitted under the CWA and/or applicable state wetland regulations (EPA 2013). Vernal pools can be 

10 conserved under both the ESA and the CWA for the benefit of federally listed species and for the 

11 purposes of providing compensation for unavoidable impacts to aquatic resources; therefore, these 

12 resources on MCAS Miramar can be managed as one joint bank. Mitigation and conservation banks

13 may be created when a government agency, corporation, nonprofit organization, or other entity 

14 undertakes these activities under a formal agreement with a regulatory agency. Any formalized

15 conservation/mitigation bank needs to have a banking instrument, which documents agency concurrence 

16 on the objectives and administration of the bank. Requirements for conservation banks and mitigation 

17 banks are sufficiently similar that both can be addressed concurrently.

18 Advanced mitigation planning, whether as established mitigation areas or as a formally structured 

19 conservation/mitigation bank, serves to streamline the regulatory process, reduce further conflict between 

20 natural resource management and the military mission at the Station, reduce per-acre mitigation costs, and 

21 alleviate mitigation cost pressures on individual project proponents.

22 1.3 Location

23 MCAS Miramar is located approximately 13 miles north of downtown San Diego and 4 miles east of the 

24 Pacific Ocean (Figure 1-1). The Station is 23,065 acres in size and the southern and western boundaries 

25 are generally defined by State Route 52 (SR-52) and Interstate 805 (I-805). The communities of Mira 

26 Mesa and Scripps Ranch have been built up to the northern limits of the Station. The communities of 

27 Tierrasanta and Clairemont are located to the south of the Station. The community of University City is 

28 located to the west. The eastern boundary abuts the City of Santee and an unincorporated area of 

29 San Diego County.

30 The proposed action would occur on MCAS Miramar. Specific locations are the subject of the alternatives 

31 presented in Chapter 2.

32 1.4 Purpose and Need

33 To meet the evolving nature of the USMC mission, MCAS Miramar must maintain flexibility to 

34 implement new actions at the Station such as adding new land uses, facilities, or training areas. As a result 

35 of land use constraints and loss of vernal pools throughout the region, new development on MCAS 

36 Miramar are likely to impact federally listed vernal pool species and jurisdictional Waters of the U.S.

37 Adverse impacts must be mitigated and, as a result, the USMC needs to establish mitigation areas for 

38 impacts to federally listed vernal pool species and jurisdictional Waters of the U.S. that would not impact 

39 MCAS Miramar operations, existing leases, or easements. Creating vernal pools in advance of individual 

40 projects improves planning and provides a more efficient means of mitigating.
MCAS Miramar 1 Purpose and Need for Proposed Action

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Draft EA

1 1.5 Regulatory Setting and Intergovernmental Coordination

2 This EA is written to analyze potential environmental impacts that may occur should the proposed action 

3 be implemented. It discusses reasonable alternatives for meeting the purpose and need for the proposed 

4 action; existing environmental conditions in the vicinity of the proposed action; direct, indirect, and 

5 cumulative impacts that might result from the proposed action; and measures to avoid or minimize 

6 potential adverse impacts. The analysis provides the MCAS Miramar Commanding Officer with 

7 information to support a well-informed decision as to which alternative best fulfills the purpose and need 

8 for the proposed action while avoiding or minimizing adverse environmental impacts. The MCAS 

9 Miramar Commanding Officer may also choose to implement the No Action Alternative, which would 

10 result in the proposed action not being completed. For more information on alternatives examined within 

11 this EA, please see Section 2.2.

12 This EA has been prepared in accordance with applicable public law, federal regulations, and instructions, 

13 including, but not limited to, those identified in Table 1-1.

Table 1-1. Applicable Public Law, Federal Regulations, and Instructions

Name Regulation

Public Law

National Environmental Policy Act of 1969 42 USC §§ 4321–4370h

National Historic Preservation Act 54 USC §§ 300101

Clean Water Act 33 USC §§ 1251–1387

Clean Air Act, as amended, including 1990 General Conformity Rule 42 USC §§ 7401–7671q

Comprehensive Environmental Response, Compensation, and Liability Act 42 USC §§ 9601–9675

Resource Conservation and Recovery Act 42 USC §§ 6901–6992k

Endangered Species Act 16 USC §§ 1531–1544

Migratory Bird Treaty Act 16 USC §§ 703–712

Federal Regulations

Council on Environmental Quality Regulations for Implementing the Procedural Provisions 

of National Environmental Policy Act 40 CFR Parts 1500–1508

Department of the Navy Procedures for Implementing National Environmental Policy Act 32 CFR Part 775

Federal Guidance for the Establishment, Use and Operation of Mitigation Banks 60 CFR Part 58605

Executive Orders

Federal Compliance with Pollution Control Standards EO 12088

Federal Actions to Address Environmental Justice in Minority Populations and Low-income 

Populations, 11 February 1994 EO 12898

Protection of Children from Environmental Health Risks and Safety Risks, 23 April 1997 EO 13045

Responsibility of Federal Agencies to Protect Migratory Birds, 11 January 2001 EO 13186

Protection of Wetlands, 24 May 1977 EO 11990

Invasive Species EO 13112

Federal Compliance with Pollution Control Standards EO 12088

Strengthening Federal Environmental, Energy, and Transportation Management EO 13423

Cooperation Among Agencies in Protecting the Environment with Respect to Greenhouse 

Gas Emissions from Motor Vehicles, Nonroad Vehicles, and Nonroad Engines EO 13432

Federal Leadership in Environmental, Energy, and Economic Performance EO 13514

Department of the Navy Instructions

United States Marine Corps Environmental Compliance and Protection Manual Commandant of the Marine 

Corps Order P5090.2A 

Notes: CFR = Code of Federal Regulations; EO = Executive Order; USC = United States Code 
MCAS Miramar 1 Purpose and Need for Proposed Action

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Draft EA

1 NEPA requires consideration of potential impacts to the environment in the decision-making process for 

2 federal actions. CEQ regulations implement the “action forcing” provisions of NEPA to ensure that 

3 federal agencies comply with the letter and spirit of NEPA. MCO P5090.2A provides specific guidance 

4 for MCAS Miramar in preparing environmental documents for proposed actions subject to NEPA.

5 The proposed action may require the following permits, plans, certifications, and/or determinations:

6 • ESA Biological Opinion from the USFWS;

7 • Conservation Bank or other agreement from the USFWS;

8 • CWA Section 404 permit from the USACE;

9 • CWA Section 230 (EPA) and 332.8 (USACE) requirements (Banking Prospectus, Bank Enabling 

10 Instrument, Mitigation Plan [See Section 1.2 for more detail]); and/or

11 • 33 CFR Section 332.4(c) requirements (Mitigation Plan) approved by the USACE—required for 

12 permittee-responsible advanced mitigation or in-lieu fee mitigation program, if implemented.

13 Under NEPA, any federal agency, other than the lead agency, that has jurisdiction by law or special 

14 expertise with respect to an environmental impact associated with a proposed action or alternative may be 

15 identified as a cooperating agency. Several federal agencies, including the EPA, USACE, and USFWS,

16 have a regulatory role in approving the wetland habitat development plans and banking instruments for 

17 the proposed action.

18 As discussed in Section 1.1, MCAS Miramar has invited the USACE and USFWS to participate as 

19 federal cooperating agencies with MCAS Miramar in the NEPA process (Appendix A, Agency 

20 Correspondence). As cooperating agencies, the USACE and USFWS assume responsibility for 

21 developing information and preparing environmental analysis, including portions of this EA for which the 

22 agency has special expertise (40 CFR §1501.6). They may adopt this EA without recirculation if, after 

23 independent review, the agency concludes that its comments and suggestions have been satisfied 

24 (40 CFR §1506.3).

25 In addition, MCAS Miramar is coordinating with the EPA and invited the EPA to participate in the NEPA 

26 process as a cooperating agency. The EPA declined the invitation to be a cooperating agency; however,

27 the agency is supportive of the concept and will coordinate with MCAS Miramar as needed.

28 MCAS Miramar is in consultation with local Native American Tribes and the State Historic Preservation 

29 Office. Discussion with the General Services Administration concerning long-term management of 

30 federal properties may be required. If any access to bank sites would need to be established outside of the 

31 MCAS Miramar boundary, coordination with the appropriate parties may be undertaken. Cooperating 

32 agencies, such as the USACE, may use lead agency consultations to support any additional permit 

33 responsibilities.

34 1.6 Scope of Analysis

35 CEQ and DoN regulations and MCO P5090.2A, Chapter 12, specify that an EA should focus on those 

36 resource areas potentially subject to impacts. The level of analysis should be equivalent to the anticipated 

37 level of environmental impact. Resource areas analyzed in detail in this EA include the following:

• Air quality/greenhouse gases; • Geologic resources;

• Biological resources; • Land use; and
MCAS Miramar 1 Purpose and Need for Proposed Action

Vernal Pool Mitigation Area Planning 1-7 April 2015

Draft EA

• Cultural resources; • Water resources

• Public health and safety;

1 Several other resource areas were considered but not carried forward for detailed analysis in this EA 

2 because potential impacts from the alternatives would be non-existent or would be considered negligible. 

3 Resources not analyzed further include visual resources, environmental justice, public services, 

4 socioeconomics, transportation/circulation/traffic, noise, and utilities, as described below.

5 Visual Resources: The proposed action would not adversely affect visual resources. The proposed action 

6 involves creation and/or restoration of vernal pools that would be consistent with the existing visual 

7 landscape at MCAS Miramar and the surrounding area. While removal of non-native trees and shrubs is 

8 anticipated, no new buildings or other structures would be included as part of the project and the proposed 

9 action would not result in a permanent alteration of the current visual setting. The resulting area would 

10 represent a natural landscape consistent with other native environments in the region. Therefore, impacts 

11 on visual resources would not occur.

12 Environmental Justice and Protection of Children: The proposed action would comply with Executive 

13 Order (EO) 12898, Federal Actions to Address Environmental Justice in Minority and Low-income 

14 Populations, and EO 13045, Protection of Children from Environmental Health Risks and Safety Risks. 

15 No communities, including low-income communities and minority communities, exist at or adjacent to 

16 the proposed mitigation areas. The proposed action would not result in any long-term change to the 

17 characteristics of the landscape or result in any functions that may otherwise affect the local population. 

18 The proposed action would not result in disproportionate impacts to minority or low-income populations 

19 and would not result in environmental health or safety risks to children. Therefore, no environmental 

20 justice or impacts to children would occur.

21 Public Services: There would be no additional military, government, civilian, and/or contractor support 

22 personnel stationed at MCAS Miramar as a result of the proposed action. Consequently, the proposed 

23 action would not require any increase in public services. Short-term basin development/restoration would 

24 not result in any interruption or reduction of current public services. Additionally, no requirement for 

25 additional schools, fire departments, or any other public services is anticipated. Therefore, no impacts on 

26 public services would occur.

27 Socioeconomics: The proposed action would be located entirely within MCAS Miramar. There would be 

28 no additional military, government, civilian, and/or contractor support personnel stationed at MCAS 

29 Miramar during development and management of the proposed action. Development and management of 

30 the proposed action would not have a noticeable effect on local population, employment, or income 

31 levels. This project would not have an effect on the local economy, nor on the sociological structure of the 

32 surrounding community. Therefore, no impacts on socioeconomics would occur.

33 Transportation/Circulation/Traffic: The proposed action is not expected to produce any increase in 

34 traffic at MCAS Miramar during proposed operations. However, a temporary increase in traffic during 

35 wetland habitat restoration is expected. This increase is expected to be minimal and would be within the 

36 normal flux of vehicles on the Station. The project would not require any road closures or result in any 

37 changes in traffic or circulation. Therefore, no impacts on transportation would occur.

38 Noise: The proposed action would not generate any noise above the Community Noise Standards of 

39 70 decibels (A-weighted). The noise levels created by earth movement activities would be much less than 

40 the noise generated by that of surrounding highways and overhead aircraft. Any minor increases to noise 
MCAS Miramar 1 Purpose and Need for Proposed Action

Vernal Pool Mitigation Area Planning 1-8 April 2015

Draft EA

1 would be temporary in nature and would not affect human or biological receptors. Therefore, no impacts 

2 to the noise environment would occur.

3 Utilities: The proposed action is not expected to produce any impact to utilities. There are no changes to 

4 utility demands, nor would new utilities be required.

5 1.7 Public Involvement

6 MCAS Miramar plans to publish a Notice of Availability of the Draft EA for three consecutive days in 

7 the San Diego Union Tribune. The notice will describe the proposed action, request and provide 

8 instructions to submit public comments on the project, and announce that copies of the Draft EA are

9 available for public review on the MCAS Miramar website (www.miramar-ems.marines.mil/ under 

10 “Links”). In addition, the Notice of Availability specifically solicits information from the public regarding 

11 the presence of historical or archaeological resources in the project areas in compliance with Section 106 

12 of the National Historic Preservation Act (NHPA), as well comments on the potential impacts on the 

13 floodplain/wetlands from the proposed action, as required by EOs 11988 (Floodplain Management) and 

14 11990 (Protection of Wetlands). All applicable public comments will be considered accordingly in the 

15 development of the Final EA.
Vernal Pool Mitigation Area Planning 2-1 April 2015

Draft EA

2 Proposed Action and Alternatives

1 This chapter describes the proposed action and reasonable alternatives for accomplishing the proposed 

2 action. Section 2.1 describes the proposed action, which is the establishment and management of 

3 mitigation areas at MCAS Miramar to provide the means to mitigate for future impacts to federally listed 

4 vernal pool species and jurisdictional Waters of the U.S. resulting from projects at MCAS Miramar. The 

5 proposed mitigation areas may be used in the future as part of a mitigation/conservation strategy, which 

6 may include the formalization of a self-use conservation/mitigation bank, in-lieu fee mitigation program,

7 or permittee-responsible advanced mitigation area. The establishment and management of formally 

8 designated mitigation areas would represent a change in land use at MCAS Miramar for those specific 

9 locations and would require a Master Plan update and internal coordination. Proposed mitigation areas 

10 would not be available for incompatible uses such as construction, trenching, and ground-based military 

11 training. Section 2.1 also describes other actions such as range closure (if applicable), regulatory approval 

12 and permitting, and site-specific planning to develop functional habitats. Finally, this section also 

13 includes a description of the screening criteria and alternatives development process.

14 Section 2.2 identifies the three alternatives under the proposed action that are carried forward for analysis 

15 in this EA. Also included are the No Action Alternative and the alternatives that were considered but 

16 eliminated from further evaluation. Section 2.3 identifies environmental protection measures that would 

17 be carried forward as part of any alternative selected. These measures are considered part of the project 

18 description. Finally, Section 2.4 presents a summary of the environmental consequences resulting from 

19 implementation of Alternatives 1 through 3 and the No Action Alternative.

20 2.1 Proposed Action

21 This section presents an overview of the proposed action; a discussion of the site-selection process 

22 followed to identify proposed mitigation areas on MCAS Miramar, including selection criteria; and 

23 identification of the specific mitigation areas evaluated as part of the proposed action. Section 2.1.1 

24 provides an overview of the specific types of planning and restoration actions that would occur 

25 independent of the alternative or sites selected. Section 2.1.2 describes the process undertaken to identify 

26 specific site alternatives on MCAS Miramar including the selection criteria and screening process 

27 utilized. Section 2.1.3 identifies the “proposed mitigation areas” resulting from the site selection process. 

28 2.1.1 Overview of the Proposed Action

29 The proposed action is the proactive establishment and management of mitigation areas at MCAS 

30 Miramar. The proposed mitigation areas would accommodate future project and operational mitigation 

31 needs. Proposed mitigation areas would be used as part of a mitigation/conservation strategy on MCAS 

32 Miramar, which includes phased establishment of areas suitable for compensatory mitigation for federally

33 listed vernal pool species, as well as jurisdictional Waters of the U.S. when feasible. This approach would

34 include the formalization of a self-use conservation/mitigation bank, a permittee-responsible advanced 

35 mitigation structure, or an in-lieu fee mitigation program because of the benefits of advanced mitigation

36 planning (Section 1.2). The three alternatives represent various locations on MCAS Miramar where the 

37 proposed action could be accomplished; therefore, this section describes the general requirements for 

38 establishment of a mitigation area on MCAS Miramar, independent of the specific location.

39 The proposed action would be located at various proposed mitigation areas throughout MCAS Miramar 

40 as developed through the site-selection process. Development of each mitigation area would involve site41 specific planning (i.e., range closure, other remedial actions, and preparation of site-specific restoration 

42 documents); temporary access roads and laydown areas if necessary; land re-contouring for vernal pool
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-2 April 2015

Draft EA

creation and enhancement; placement of inoculum in pools (soil containing fairy shrimp cysts3 1 and plant 

2 seeds); weed/exotic plant control and removal; as well as maintenance and monitoring. In general, typical 

3 equipment would include hand tools, mechanical line trimmers, scrapers, bulldozers, bobcats, backhoes, 

4 loaders, water trucks, pickup trucks, and miscellaneous smaller equipment. Staging and laydown areas 

5 would be located within each mitigation area for the duration of the restoration period and identified in 

6 the implementation plan specific to each mitigation area. The proposed mitigation areas would be 

7 accessed by existing roads when feasible and by transiting fence line security clear zones. However, 

8 access roads may be required for sites that do not have existing access roads or access suitable for the 

9 delivery of heavy equipment.

10 2.1.1.1 Site-Specific Planning

11 Stakeholder Coordination

12 Conservation and mitigation banks are typically permanently protected lands that contain natural resource 

13 values. However, with respect to the creation of conservation banks on DoD lands, Section 13(b) of 

14 DODINST 4715.03 details that “DoD shall ensure the USFW Directors’ approval to create conservation 

15 banks on DoD lands...” but that such banks shall not be created to sell, trade, or transfer credits to 

16 non-DoD entities. The instruction further details that “DoD components [i.e., USMC] shall not restrict the 

17 use of DoD fee-owned or withdrawn lands such that the lands may be unavailable for otherwise 

18 appropriate mission uses.” The proposed self-use joint conservation/mitigation bank, in-lieu fee 

19 mitigation program, or other advanced mitigation instrument would support the MCAS Miramar mission. 

20 Bank creation can facilitate operations, facilities construction, and utility maintenance/repair while 

21 thoughtfully compensating for the habitats in an area of lesser operational importance or conflict. In areas 

22 with existing land use constraints (e.g., pre-existing mitigation, concentrations of protected resources, 

23 accident potential zones [APZ]), use as a mitigation site can be the most appropriate mission use. 

24 Early in the planning process, a stakeholder meeting was held on 20 February 2013 to identify areas best 

25 suited for mitigation that would not further restrict or impede current or future military operations 

26 (see Section 2.1.2.1 and Appendix B). Further coordination with the stakeholder group would occur 

27 throughout the entire planning and implementation process, including meetings, briefings, and decision 

28 maker involvement. Prior to the restoration of each area, proposed mitigation areas would be re-examined 

29 by a stakeholder group to ensure that there have been no changes to the human environment or mission 

30 requirements. As a result, not all areas may be used and/or additional review may be required. 

31 Any impacts to the mitigation area after implementation would require additional consultations with 

32 regulatory agencies, which may result in the need for additional mitigation. To provide conservation 

33 assurances as long as the proposed mitigation areas are under military control, the Station Master Plan 

34 and the Integrated Natural Resources Management Plan (INRMP) would be revised to identify and 

35 protect the conservation land use of the areas. Although, some long-term assurance mechanisms may be 

36 legally restricted on federal government property, DODINST4717.03 does allow for the designation of 

37 “Special Areas” and provides other guidance related to natural resources mitigation. In addition, 

38 coordination with the General Services Administration, which ultimately oversees the usage of land in the 

39 event that the land would ever leave DoN control, may occur. Specific long-term assurances are 

40 determined on a case by case basis with the appropriate regulatory agencies.

 3 Fairy shrimp cysts can accumulate in the soil after several years of reproduction. Cyst banks resemble the seed 

banks of plants. Cysts that are near the soil surface are available for hatching. The cyst bank is generally present 

in a few centimeters of soil.
MCAS Miramar 2 Proposed Action and Alternatives

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Draft EA

1 Range Closure and Other Contaminated Areas 

2 Any proposed mitigation areas located east of Kearny Villa Road are within the East Miramar Range 

3 Complex and, therefore, are incompatible with range activities. These incompatible use areas require 

4 removal from the operational range inventory. USMC guidance allows for an incompatible use area to be 

5 administratively closed where no active or historic ranges occur and where no known current or historical 

6 military munitions use resulted in a potential release as defined by the Comprehensive Environmental

7 Response, Compensation, and Liability Act (CERCLA). Range closure will require approval from 

8 MCAS Miramar S-3 Training, MCAS Miramar Commanding Officer, Marine Corps Installations

9 West (MCI West), Commanding General Training and Education Command (TECOM), and 

10 Headquarters Marine Corps (HQMC)/MCI Command (MCICOM).

11 In the case of historical ranges and/or when munitions-related release is suspected, the project will be 

12 required to evaluate and remove any contaminates if present, in accordance with CERCLA and all 

13 appropriate local, state, and federal regulations. Additionally, for explosive safety concerns, the project 

14 will comply with all Naval Ordnance Safety and Security Activity (NOSSA) or Marine Corps Systems 

15 Command (MARCORSYSCOM) requirements. These munitions cleanup areas may be entered into the 

16 Military Munitions Response Program (MMRP). The MMRP was established under the Defense 

17 Environmental Restoration Program (DERP) and addresses areas that are suspected or known to contain 

18 unexploded ordnance (UXO), discarded military munitions, or munitions constituent contamination from 

19 past military munitions activities. Current sites being addressed under the MMRP included MRP Site 1, a 

20 historical Grenade Course.

21 Suspected releases that are non-munitions related may be addressed through the Installation Restoration 

22 Program (IRP), such as old buildings and foundations that may be contaminated with asbestos and/or 

23 lead-based paint. IRP was also established under the DERP. Both IRP and MMRP cleanups are the 

24 responsibility of Naval Facilities Engineering Command (NAVFAC).

25 If a munitions cleanup area is entered into the MMRP, the area will be subjected to an evaluation and 

26 scoring process using the Munitions Response Site Prioritization Protocol (MRSPP). The MRSPP score 

27 reflects the relative potential for the site to be a danger to human health and the environment. The MMRP

28 process is driven by a number of policy and guidance documents that are consistent with the CERCLA.

29 Site-Specific Restoration Planning

30 To ensure that the proposed mitigation areas are planned properly, multiple documents are needed. The

31 documents provide a general framework to ensure success of the proposed mitigation areas both in the 

32 short term and in the long term. The following documents would be produced, regardless of the 

33 mitigation strategy chosen:

34 Development Plan. Site-specific development plans describe the methods and procedures for habitat 

35 creation, including a habitat design, planting plan, and sources of materials and permits. The development 

36 plan includes a rationale as to why the design would be successful, explains how the site would be 

37 monitored for success, and describes the standards to measure success. Finally, the development plan also 

38 outlines the general process to phase the implementation of the mitigation development. The phasing may 

39 occur by developing a whole area (or multiple areas) at a time, or it may allow for the development of 

40 portions of one area.

41 Interim Management Plan. Describes the management of the mitigation area(s) until the mitigation area is 

42 fully restored and credits have been used. The Interim Management Plan would be included within the 

43 MCAS Miramar INRMP.
MCAS Miramar 2 Proposed Action and Alternatives

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Draft EA

1 Long-Term Management Plan. Outlines the management of the mitigation area after success standards are 

2 met and credits have been used. It incorporates contingency planning and may need to be updated to adapt 

3 results from monitoring. The Long-Term Management Plan would be included within the MCAS 

4 Miramar INRMP.

5 Terminology and structure of required documentation depends on the specific type of mitigation planning 

6 mechanism implemented (mitigation/conservation bank, in-lieu fee mitigation program, or advanced7 permittee responsible mitigation). However, encapsulated within the documentation noted above, or 

8 otherwise required separately, the following minimum requirements are likely to be required independent 

9 of the advanced mitigation instrument developed. 

10 • Prospectus or other Project Description. This is the preliminary assessment (PA) of the 

11 mitigation areas proposed for development that is used to initiate planning and review by the 

12 appropriate agencies. A draft is typically submitted prior to the full Bank Enabling Instrument, 

13 and the final is included within the Bank Enabling Instrument. General information as to 

14 objectives of the bank, what species or habitat would be used for mitigation, proposed joint land 

15 uses, and any other pertinent information that allows the regulatory agencies to determine need 

16 and technical feasibility is included in the prospectus. The prospectus is used as a formal agency 

17 involvement initiation. Prior to this, it is recommended that proponents involve the agencies for 

18 pre-application coordination. 

19 • Phase I Site Assessment. This document analyzes the mitigation area’s history to determine if 

20 there are any prior issues with contamination or pollution that may impact the site. It also 

21 examines a buffer area to ensure that surrounding land uses would not cause degradation of 

22 habitat.

23 • Real Estate Assurances. In the private sector, this would be a conservation easement or grant 

24 deed. Due to federal regulations, the USMC is unable to grant an easement or deed for 

25 government property. To meet this requirement, MCAS Miramar would revise the Base Master 

26 Plan map to include the proposed mitigation areas as a protected land use. To ensure long-term 

27 conservation and protection, in the event of a Station realignment or closure scenario, the USMC 

28 may develop and sign a Site Protection Memorandum of Agreement with regulatory agencies or

29 may seek a letter from the General Services Administration regarding resource protection in 

30 circumstances of any future land transfer of the mitigation area. The MCAS Miramar INRMP 

31 also contains site identification and protection provisions (MCAS Miramar 2011a).

32 • Objectives. A description of the resource type(s) and amount(s) that will be provided, the method 

33 of compensation, and the manner in which the resource functions of the project would address the 

34 needs of the watershed.

35 • Site Selection. A description of the factors considered during the site selection process.

36 • Site Protection Instrument. A description of the legal arrangements and instrument that would

37 ensure the long-term protection of the proposed mitigation areas.

38 • Baseline Site Information. A description of the ecological characteristics of the proposed site.

39 • Determination of Credits. A description of the number of credits to be provided, including a brief 

40 explanation of the rationale for this determination.

41 • Mitigation Work Plan. Detailed written specifications and work descriptions for the project,

42 including geographic boundaries; construction methods, timing, and sequence; source(s) of water, 

43 including connections to existing waters and uplands; methods for establishing the desired plant 

44 community; plans to control invasive plant species; the proposed grading plan; soil management; 

45 and erosion control measures.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-5 April 2015

Draft EA

1 • Maintenance Plan. A description and schedule of maintenance requirements to ensure the

2 continued viability of the resource once initial grading/basin development is completed.

3 • Performance Standards. Ecologically based standards that would be used to determine whether

4 the compensatory mitigation project is achieving its objectives.

5 • Monitoring Requirements. A description of parameters to be monitored in order to determine if 

6 the compensatory mitigation project is on track to meet performance standards and if adaptive 

7 management is needed. A schedule for monitoring and reporting on monitoring results must also 

8 be included.

9 • Long-term Management Plan. A description of how the project would be managed after

10 achievement of performance standards to ensure the long-term sustainability of the resource,

11 including long-term financing mechanisms and the party responsible for long-term management.

12 • Adaptive Management Plan. A management strategy to address unforeseen changes in site

13 conditions or other components of the project, including the party or parties responsible for

14 implementing adaptive management measures. The adaptive management plan would guide

15 decisions for revising mitigation plans and implementing measures to address both foreseeable 

16 and unforeseen circumstances that adversely affect the project’s success.

17 • Financial Assurances. A description of financial assurances that would be provided and how they 

18 are sufficient to ensure a high level of confidence that the compensatory mitigation project would

19 be successfully completed, in accordance with its performance standards.

20 • Other information as deemed necessary.

21 2.1.1.2 Vernal Pool Restoration Actions

22 Individual vernal pools would be established, enhanced, and/or preserved (hereafter collectively referred to 

23 as vernal pool restoration) within suitable sites of each mitigation area. Where possible, the proposed action 

24 includes restoration of vernal pools that are immediately adjacent to and/or connected to federal CWA 

25 jurisdictional Waters of the U.S. Specific creation sites would be cleared of vegetation and graded to create 

26 new basins through soil re-contouring. The ability of the basin to hold water would be tested and then the 

27 basin would be inoculated. Upland areas disturbed by restoration activities would be replanted with 

28 appropriate native seed or plantings. Post-restoration management and monitoring would evaluate the 

29 success of the restoration actions against the performance criteria outlined in the Restoration Plan. Adaptive 

30 management strategies, as outlined in the Restoration Plan, would be implemented in the event that the 

31 performance standards are not met.

32 Site Access

33 The proposed mitigation areas would be accessed by existing roads or along the 20-foot-wide fence line 

34 security clear zones whenever feasible. “Cross-country” access during the dry season and/or temporary 

35 access routes may be required. No paving is anticipated. Staging and laydown areas would be located 

36 within each mitigation site for the duration of the restoration period and identified in the implementation 

37 plan specific to each mitigation area.

38 Site Preparation and Soil Re-Contouring

39 Individual basins would be created by clearing, grading, and re-contouring the existing topography to 

40 duplicate hydrologic depth, surface area, and inundation period of similar naturally occurring vernal 

41 pools. Excavated material from new basin areas would typically be used on-site to create upland mounds. 

42 Any debris associated with site preparation and soil re-contouring would be removed and transported to a 

43 permitted, off-site disposal site. In addition to creation, enhancement of existing but disturbed or degraded 
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-6 April 2015

Draft EA

1 vernal pool habitat would generally create larger, more natural basins. New basins adjacent to CWA 

2 jurisdictional streambeds may be designed to flow between basins and streambeds during extreme rainfall 

3 periods so as to be hydrologically connected to the jurisdictional feature. Small ephemeral channels 

4 connecting to the existing streambed may also be created to better establish adjacency or hydrologic 

5 connection to waters of the U.S. for more of the area in which vernal pools would be created.

6 Site preparation and soil re-contouring associated with restoration/enhancement of existing basins would 

7 be done carefully, using small-scale equipment or hand tools. Soil re-contouring and any other heavy 

8 equipment work would occur during the dry season, when the soil is completely dry.

9 Water Retention and Inoculation

10 Newly created vernal pools may be filled via water trucks to determine if they hold sufficient water long 

11 enough to support vernal pool species, including San Diego fairy shrimp. Once the pools are deemed 

12 suitable, inoculum from MCAS Miramar would be placed into each vernal pool. Surface sediment at any 

13 basin supporting federally listed vernal pool fairy shrimp species and/or federally listed vernal pool plant 

14 species would be salvaged prior to the start of soil disturbance during enhancement activities to minimize 

15 displacement of shrimp cysts. Pool inoculation (placement of inoculum into the pools) would be timed to 

16 occur in the fall/early winter to coincide with the rainy season.

17 Planting and Seeding

18 The relatively small size of vernal pools allows for preservation of desirable shrubs and perennial grasses 

19 when adapting the design to site-specific conditions. In addition, surface sediment at any basin supporting 

20 federally listed vernal pool species would be salvaged prior to the start of soil disturbance during 

21 enhancement activities to minimize displacement of vernal pool plant seeds or vernal pool fairy shrimp 

22 cysts.

23 Upland areas disturbed by restoration activities would be replanted with appropriate native seed or 

24 plantings as outlined in site-specific restoration plans. Planting would be timed to occur in the fall/early 

25 winter to coincide with the rainy season. Reseeding/replanting that becomes necessary after the start of 

26 the rainy season would be done as soon as possible. The vernal pool creation and planting schedule would 

27 vary by site and would depend on the size and topography of each proposed mitigation area.

28 Irrigation water may be provided to the proposed mitigation areas by a water truck as necessary during 

29 establishment and maintenance of the areas. No utilities are required as part of the proposed action.

30 2.1.1.3 Restoration Monitoring and Maintenance

31 The vernal pool restoration sites would be actively maintained and monitored by the restoration contractor 

32 for at least 5 years following restoration of vernal pools (i.e. establishment, enhancement of vernal pools), 

33 or until the performance standards are met. Biological monitoring during rain events at newly created or 

34 enhanced vernal pools would determine if runoff from ground-disturbing activities is entering any 

35 watershed and would recommend and implement necessary best management practices (BMPs). 

36 Maintenance would include irrigation of native vegetation, invasive weed control (i.e., hand removal, 

37 mechanical and herbicide), maintenance of erosion control materials (e.g., straw wattles), trash removal, 

38 and site protection measures. Invasive weed control in upland areas would be implemented with the start 

39 of each phase of vernal pool restoration.

40 Monitoring of the sites would be conducted in accordance with established vernal pool monitoring 

41 transect procedures already in use at MCAS Miramar. In addition, all pools would include a depth gauge 

42 installed at the lowest elevation to compare functionality against other natural and constructed vernal 
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-7 April 2015

Draft EA

1 pools in the area. The restoration plans would outline detailed performance standards for the mitigation 

2 sites and reference site(s) as part of the site-specific planning process in coordination with approving 

3 agencies. Performance standards would primarily involve hydrology, vernal pool and upland watershed 

4 vegetation, and presence of vernal pool species (Table 2-1). Monitoring would assess the performance of 

5 the mitigation sites relative to the reference site. The adaptive management plan would guide decisions 

6 for revising and implementing measures (e.g., reseeding and watering) to address foreseeable and 

7 unforeseen circumstances that affect the mitigation site’s success. The status would be reported to 

8 USFWS and USACE, as appropriate, as part of the monitoring program.

9 Mitigation credit would be available approximately 6–7 years after the start of vernal pool restoration. 

10 This accounts for 1–2 years of pool restoration and 5 years of monitoring. 

11 2.1.2 Site-Selection Process

12 2.1.2.1 Selection Criteria

13 MCAS Miramar lands include vernal pool habitat that are unique to Southern California. The 

14 Environmental Management Department (EMD) at MCAS Miramar maintains a database of these 

15 resources, including vernal pool habitat that could support future restoration (conceptual vernal pool 

16 development restoration areas). For the purposes of this exercise, conceptual vernal pool restoration 

17 development areas were mapped installation-wide and establish the basis for the screening analysis. These 

18 areas were initially delineated based on the following functional requirements:

19 • Nearly level topography (< 5 percent slope);

20 • No impacts to existing pools and pool watersheds;

21 • Redding gravely loam soil series with hardpan; and

22 • Areas with high non-native annual grassland cover or disturbed areas (Black 2007, 2009).
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-8 April 2015

Draft EA

Table 2-1. Conceptual Performance Standards for Vernal Pool Wetland Habitat Restoration*

Parameter Metric Examples of Standard

Hydrology Ponding depth and duration relative to reference vernal 

pools

Newly constructed vernal pools fall within the range of ponding characteristics of 

reference vernal pools by year 5.**

Vernal pool plant 

presence

Frequency of individual species relative to values in 

reference vernal pools

At least three native vernal pool plants present in more than one ponding year by 

year 5 (Indicator Species for Vernal Pools from USACE Special Public Notice of 

November 25, 1997). Native vernal pool plant presence frequency at > 75% of the 

range in reference vernal pools by year 5.**

General vernal pool 

basin ground cover

Vegetative ground cover relative to estimated values in 

reference vernal pools

Vernal pool and upland plant cover falls within > 75% of the range of estimates from 

reference vernal pools by year 5.** Cobble, plant litter, and bare ground also recorded.

Upland watershed 

vegetation

Upland plant cover in surrounding watershed area relative 

to estimated values at reference vernal pools

Watersheds have > 75% upland vegetation cover compared with that surrounding 

reference vernal pools by year 5.** Upland restoration may be emphasized, where 

feasible, to develop suitable California gnatcatcher habitat credit.

Federally listed vernal pool species

Flora Presence and abundance relative to reference vernal pools For ESA credit, presence and population estimate of at least one listed plant species 

within 60% of the range in reference vernal pools containing particular listed plant species 

by year 5.**

Fauna Presence and abundance relative to reference vernal pools For ESA credit, population estimate of San Diego fairy shrimp within 60% of the range in 

reference vernal pools containing the species by year 5. Cyst density by year 5 is > 20% 

of the range found in reference pools.**

Weeds

Flora-basin Frequency of individual species relative to values in 

reference vernal pools

No invasive plants on federal or California noxious weed lists, nor any on California 

Invasive Plant Council (Cal-IPC) Invasive Plants of California Wildlands list. Frequency of 

other non-native plants less than average of reference vernal pools, annually.**

Flora-watershed Presence and percent cover relative to values at reference 

vernal pool watersheds

No invasive plants on federal or California noxious weed lists, nor any on Cal-IPC 

Invasive Plants of California Wildlands list. Non-native upland plant cover in surrounding 

vernal pools watershed less than average at reference basins, annually.**

* ”Restoration” includes the establishment of new vernal pool wetland habitat and/or the enhancement of existing vernal pool wetland habitat.

** MCAS Miramar has long-term ecological monitoring data being collected for 15 natural or purposely created vernal pools that could be used as reference pools (data periodically collected from 1989–2010 and annually 

collected from 2010–2014). Additionally, two ongoing vernal pool establishment and re-establishment projects are collecting data in accordance with the same data collection protocol.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-9 April 2015

Draft EA

1 From there, a two-tiered screening process was applied to narrow and then focus the reasonable site 

2 alternatives that meet the purpose and need of the proposed action. The fundamental selection criteria 

3 were first applied to ensure that the proposed mitigation areas met minimum requirements. The 

4 preferential selection criteria were then applied to focus on transitional needs and efficiencies associated 

5 with specific potential mitigation areas. The selection criteria are described next.

6 Fundamental Selection Criteria

7 MCAS Miramar identified three fundamental selection criteria that must be satisfied to meet the purpose 

8 and need for the proposed action. These criteria include:

9 • A location at MCAS Miramar that does not support mission-essential operations and other 

10 incompatible land uses (i.e., flightline, designated ground training areas, lease areas, outgrants, 

11 easements, right-of-way), and that would not be subject to known future development or land use 

12 changes;

13 • An area that is large enough to support vernal pool habitat function and to maintain viable 

14 populations of federally listed vernal pool species within its boundary or situated in a strategic 

15 location that would overlay previously used mitigation sites and/or concentrations of other 

16 protected resources; and

17 • A location that provides a nexus to traditional navigable waters or tributaries for at least part of 

18 the area, as defined by the USACE, so that CWA jurisdiction can be established.

19 Preferential Selection Criteria

20 MCAS Miramar further identified eight preferential selection criteria that were applied to proposed 

21 mitigation areas that met the fundamental selection criteria. The preferential selection criteria are not 

22 fundamental to the purpose and need for the proposed action; however, these criteria substantially affect 

23 the suitability of, or preferences for, a specific advanced mitigation strategy alternative. These criteria 

24 include:

25 • Proximity to existing vernal pools that support federally listed species;

26 • Maximization of the potential density of vernal pool creation;

27 • Protection from future land use conflicts; 

28 • Support of additional community planning purposes such as encroachment buffer or maximum 

29 use of sites where no other use could be feasibly supported;

30 • Minimization of potential impacts to sensitive cultural and biological resources;

31 • Ease of access for restoration and maintenance of the mitigation area;

32 • Limitation on public access and prevention of unauthorized use of the site, which could damage 

33 restoration of vernal pool habitat; and

34 • Avoidance of underground utilities.

35 2.1.2.2 Screening Process

36 Geographic Information System Mapping

37 Based on review of all potential mitigation areas at MCAS Miramar and the fundamental selection 

38 criteria, MCAS Miramar identified potential locations for the proposed action. This was accomplished by 

39 using existing geospatial data from the MCAS Miramar geographic information system (GIS) program 
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-10 April 2015

Draft EA

1 and overlaying it to remove areas that did not meet the fundamental performance standards. Preferential 

2 selection criteria were then included, calculated, and identified on maps (Appendix B). The resulting 

3 maps were utilized to help define possible mitigation areas to present to other stakeholders on 

4 MCAS Miramar.

5 Stakeholder Meeting

6 A stakeholder meeting was held to discuss the viability of possible mitigations areas on MCAS Miramar. 

7 The stakeholder group included representatives from USACE, EPA Region 9, Naval Facilities 

8 Engineering Command Southwest (NAVFAC SW), MCI West, Marine Corps Base (MCB) Camp 

9 Pendleton, and HQMC/MCICOM. MCAS Miramar was represented by Operations, Environmental 

10 Management Division, Command, Installations and Logistics/Public Works Division (I&L/PWD), 

11 Community Plans and Liaison Office (CP&L), I&L/Real Estate (RE), and Counsel (Appendix B). MCAS 

12 Miramar has also requested collaboration and participation by the USFWS, which has indicated general 

13 support during an early project development meeting. The USFWS has previously approved several of the 

14 proposed mitigation areas (including Charlie, Delta, and Echo) as part of prior homebasing projects. 

15 MCAS Miramar EMD, in coordination with a stakeholder group, used the GIS maps to further refine 

16 possible mitigation areas. The group also examined the areas that would not restrict or impede current or 

17 future military operations on MCAS Miramar. From this, larger areas were grouped into proposed 

18 mitigation areas. It was determined that six areas represent reasonable locations for the proposed action 

19 (Figure 2-1). These six areas are described in Section 2.1.3 and are the basis for the alternatives presented 

20 in Section 2.2.

21 Within each of the six potential mitigation areas, mapping of conceptually suitable vernal pool restoration 

22 sites was provided by previous surveys (Black 2007, 2009). Table 2-2 presents GIS calculations of these 

23 sites and the potential acres of vernal basin that could be realized. Creation of vernal pools requires a 

24 watershed area surrounding each pool of about 7 to 10 times the area of the actual pool basin; therefore, 

25 the resulting vernal pool basin is substantially less than the area subjected to restoration. While these 

26 areas conceptually appear suitable for restoration, site-specific restoration planning is likely to identify 

27 somewhat different site configurations, quantities, and additional opportunities for enhancement of 

28 existing basins to create more vernal pool habitat. Each site-specific restoration plan would be reviewed 

29 and approved by MCAS Miramar Natural Resources Division staff and appropriate regulatory agencies 

30 prior to implementation. Areas and activities described in this EA would remain essentially as described 

31 except to accommodate site-specific nuances that would affect project success.

Table 2-2. Approximate Size of the Proposed Mitigation Areas, Suitable Sites for Vernal

Pool Restoration, and Potential Vernal Pool Basin Area Realized for Mitigation Purposes

Proposed 

Mitigation Area

Total Size of 

Proposed 

Mitigation Area 

(acres)

Estimate of Suitable Area 

including Watershed for Vernal 

Pool Restoration within Proposed 

Mitigation Areas (acres)

Estimated Amount of Vernal Pool

Basins Realized for Mitigation 

Purposes within the Proposed 

Mitigation Areas (acres)

Alpha 42 21 2

Bravo (North/South) 183 (84/99) 50 5 (3/2)

Charlie 109 26 3

Delta 132 60 6

Echo 189 36 4

Foxtrot 44 18 2

Total 699 210 22
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-11 April 2015

Draft EA

Figure 2-1. MCAS Miramar Proposed Mitigation Area Conceptual Layout
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-12 April 2015

Draft EA

1 2.1.3 Proposed Mitigation Areas

2 The proposed action would occur within up to six different proposed mitigation areas at MCAS Miramar 

3 as developed through the stakeholder and alternatives screening process described in Section 2.1.2.2. 

4 These proposed mitigation areas are shown in Figure 2-1. Within each of the proposed mitigation areas, 

5 only a portion may be suitable for vernal pool restoration; these portions are hereafter referred to as 

6 “suitable sites for vernal pool restoration.” An estimate of the total acreage of each mitigation area, as 

7 well as the estimated amount of area identified as sites suitable for vernal pool restoration and resulting 

8 potential vernal pool basin area, is shown in Table 2-2. Vernal pools require a surrounding upland 

9 “watershed” planned for a 7-10:1 ratio; the actual vernal pool basin area created by restoration would be 

10 between one-seventh and one-tenth of the area suitable for vernal pool restoration. Site-specific 

11 restoration planning for each mitigation area may identify somewhat different site boundaries and other 

12 enhancement opportunities that could result in additional vernal pool basin areas.

13 The exact locations of the vernal pools within each mitigation area would be determined based on final 

14 mitigation and design plans; therefore, deviations from the current conceptual areas may be appropriate 

15 during site-specific planning. The conceptual restoration areas were designed to represent an estimate of 

16 area likely to undergo substantial landscape re-contouring for pool creation. All areas potentially 

17 disturbed are included within the boundaries for each mitigation area. 

18 Mitigation Area Alpha. Mitigation area Alpha would be a 42-acre parcel located between I-15 and 

19 Kearny Villa Road. About 2 acres of vernal pool basins could be created within the conceptual vernal 

20 restoration sites. The specific acreage of the vernal pools that would support a nexus to federal CWA 

21 jurisdictional Waters of the U.S. would depend on the specific location; however, only the southern part 

22 of proposed mitigation area Alpha would be suitable for establishing a nexus. This area is associated with 

23 two historical ranges: 1) Range D, a .30 caliber machine guns, maneuver, combat, and marksmanship 

24 range; and 2) Range E, a tank course combat firing range. Prior to range closure, both ranges would be 

25 removed from the active range inventory and need to follow the CERCLA process for evaluation and 

26 remove any contaminates, in accordance with CERCLA and all appropriate local, state, and federal 

27 regulations. Consultation with the MCAS Miramar Explosive Safety Officer (ESO) would occur to 

28 determine if an Explosives Safety Submission (ESS) and/or any other NOSSA or MARCORSYSCOM 

29 requirements will be needed. The ranges may be entered into the MMRP. Areas outside the two ranges 

30 but still located within East Miramar Range Complex would be removed from the active range inventory 

31 with appropriate Marine Corps approval.

32 Proposed mitigation area Alpha has been subject to encroachment by non-military land uses and is of low 

33 potential for ground-based field training use due to the proximity of I-15 and Kearny Villa Road.

34 Mitigation Area Bravo. Proposed mitigation area Bravo would be a 183-acre parcel located directly east 

35 of I-15 and south of Pomerado Road. The northern half of the area is the only location on MCAS Miramar 

36 with endangered Riverside fairy shrimp (Streptocephalus wootoni). The proposed mitigation area is 

37 divided into Bravo North and Bravo South. About 5 acres of vernal pool basins (3 acres in Bravo North 

38 and 2 acres in Bravo South) could be created within the conceptual vernal pool restoration sites. Some of 

39 proposed mitigation area Bravo could support a nexus to federal CWA jurisdictional Waters of the U.S. 

40 This area is associated with two historical ranges: Range D and Range E, as described for mitigation area

41 Alpha. Prior to range closure, both ranges would be removed from the active range inventory and need to

42 follow the CERCLA process for evaluation and remove any contaminates. Consultation with the MCAS 

43 Miramar ESO would occur to ensure compliance with all NOSSA or MARCORSYSCOM requirements. 

44 Areas outside the two ranges but still located within East Miramar Range Complex would be removed 

45 from the active range inventory. Please refer to Section 2.1 for additional information.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-13 April 2015

Draft EA

1 Overall, lands within proposed mitigation area Bravo have been subject to non-military uses and are of 

2 low potential for ground-based field training use. However, some potential for use exists. In comparison 

3 to Bravo North, lands within the proposed Bravo South have minimal natural resource constraints and 

4 therefore have a higher potential to be used for military readiness needs than proposed mitigation area 

5 Bravo North, which has Riverside fairy shrimp. Due to this, proposed mitigation area Bravo has been 

6 divided to allow for separate inclusion in some alternatives as described in Section 2.2.

7 Mitigation Area Charlie. Proposed mitigation area Charlie would be a 109-acre parcel located between I-15 

8 and Kearny Villa Road south of Miramar Way. About 3 acres of vernal pool basins could be created within 

9 the conceptual vernal pool restoration sites. Some of the conceptual vernal restoration could have a nexus to 

10 federal CWA jurisdictional Waters of the U.S. This area is associated with a historical World War I machine 

11 gun dugout and emplacement range. Prior to range closure, both ranges would be removed from the active 

12 range inventory and follow the CERCLA process for evaluation and remove any contaminates. Consultation 

13 with the MCAS Miramar ESO would occur to ensure compliance with all NOSSA or MARCORSYSCOM 

14 requirements. Areas outside the two ranges but still located within East Miramar Range Complex would be 

15 removed from the active range inventory. Please refer to Section 2.1 for additional information.

16 Proposed mitigation area Charlie includes a Base Realignment and Closure (BRAC) vernal pool mitigation 

17 site, which already requires special conservation protection. It is located under aircraft APZ 1 associated with 

18 the typical runway approach from the east. There is low potential for ground-based field training use. 

19 Mitigation Area Delta. Proposed mitigation area Delta would be a 132-acre parcel located between I-15 and 

20 Kearny Villa Road to the south of mitigation area Charlie. Most of the area is inside aircraft APZs 

21 associated with the downwind turn of the typical flight pattern. There is low potential for ground-based field 

22 training use. About 6 acres of vernal pool basins could be created, a portion of which could support a nexus 

23 to federal jurisdictional Waters of the U.S. Prior to range closure, any areas associated with East Miramar 

24 Range Complex would be removed from the active range inventory. If a suspected munitions-related release 

25 is discovered, the project would be required to follow the CERCLA process for evaluation and removal of 

26 contaminates. Already being addressed by the CERCLA process is MRP Site 1, a historical grenade course 

27 range. Based on previous work conducted by NAVFAC at MRP Site 1, UXO support would be required 

28 during grading activities. Consultation with the MCAS Miramar ESO would occur to ensure compliance 

29 with all NOSSA or MARCORSYSCOM requirements. In addition, the southernmost part of Area Delta is 

30 associated with World War II Camp Elliot buildings and foundations that are potentially contaminated with 

31 asbestos and/or lead-based paint. These buildings and foundations will be evaluated under the appropriate 

32 federal, state and local regulations and possibly be included into the IRP. Camp Elliot is the only known 

33 area of concern for potential asbestos and lead contamination within any of the proposed mitigation areas. 

34 Both the MRP Site 1 and Camp Elliot portion would be restored as a separate phase from other portions of 

35 Area Delta. Please refer to Section 2.1 for additional information.

36 Proposed mitigation area Delta currently is the site for the MV-22 vernal pool mitigation site, which 

37 already requires special conservation protection. It is isolated from the rest of MCAS Miramar by I-15 and 

38 Kearny Villa Road. The site also has floodplains and CWA jurisdictional Waters of the U.S. There is low 

39 potential for ground-based field training and the surrounding APZ is compatible with vernal pool mitigation.

40 Mitigation Area Echo. Proposed mitigation area Echo would be a 189-acre parcel located west of 

41 Highway 163 and Kearny Villa Road. The area includes a vernal pool mitigation site related to past leases 

42 associated with the Harris Plant. About 4 acres of vernal pool basins could be created within the conceptual 

43 vernal pool development restoration sites, a portion of which would likely support a nexus to federal CWA 

44 jurisdictional Waters of the U.S. The area includes an existing San Diego Gas and Electric (SDG&E) natural 

45 gas pipeline easement through the middle that may be excluded; however, the easement access road would 

46 be an important access route for restoration work. The area is not within the East Miramar Range Complex 

47 Inventory; thus, administrative removal from the range inventory is not applicable to the area.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-14 April 2015

Draft EA

1 There is low potential for ground-based field training and the overlying APZ provides an overlying land 

2 use that is compatible with vernal pool mitigation. There are current mitigation sites located on the parcel.

3 Mitigation Area Foxtrot. Proposed mitigation area Foxtrot would be a 44-acre parcel located west of 

4 Highway 163 south of Area Echo. It is located within the Miramar Mounds National Natural Landmark, 

5 which already requires special conservation attention. About 2 acres of vernal pool basins could be created 

6 within the conceptual vernal pool restoration sites. A small portion of the area could reasonably support a 

7 nexus to federal CWA jurisdictional Waters of the U.S. This area is not within the East Miramar Range

8 Complex Inventory; thus administrative removal from the range inventory is not applicable to the area.

9 There is low potential for ground-based field training and the overlying APZ provides an overlying land 

10 use that is compatible with vernal pool mitigation. 

11 2.2 Alternatives to the Proposed Action and the No Action 

12 Alternative

13 Based on the site-selection process described in Section 2.1.2, MCAS Miramar has determined that 

14 six mitigation areas (Alpha through Foxtrot) represent suitable locations for the proposed action. These 

15 options are carried forward as alternatives for evaluation. These options were analyzed and identified as 

16 ways to provide the most efficient and substantive amount of mitigation area. Through this discussion, it 

17 was determined that proposed mitigation area Bravo would be split into two different sites, Bravo North 

18 and Bravo South.

19 This section describes the three alternatives to the proposed action carried forward for analysis. This 

20 section also describes the No Action Alternative and the alternatives that were considered but not carried 

21 forward for analysis in this EA. Table 2-3 provides an estimate of the total acreage of each mitigation area 

22 for Alternatives 1 through 3, as well as the estimated amount of potential vernal pool basin area that could 

23 be created.

Table 2-3. Approximate Size of the Proposed Mitigation Areas and 

Potential Vernal Pool Basin Area for Alternatives 1 through 3 and the No Action Alternative

Mitigation 

Area

Full Mitigation Area 

(Alternative 1)

Partial Configuration A 

(Areas Alpha, Bravo 

North, Delta, and Echo) 

(Alternative 2)

Partial Configuration B 

(Areas Charlie, Delta, 

Echo, and Foxtrot) 

(Alternative 3) No Action Alternative

Mitigation 

Area 

(Acres)

Potential 

Pool Basin 

Area 

(Acres)

Mitigation 

Area 

(Acres)

Potential 

Pool Basin 

Area 

(Acres)

Mitigation 

Area 

(Acres)

Potential 

Pool Basin 

Area 

(Acres)

Mitigation 

Area 

(Acres)

Potential 

Pool Basin 

Area 

(Acres)

Alpha 42 2 42 2 - - - -

Bravo North 84 3 84 3 - - - -

Bravo South 99 2 - - - - - -

Charlie 109 3 - - 109 3 - -

Delta 132 6 132 6 132 6 - -

Echo 189 4 189 4 189 4 - -

Foxtrot 44 2 - - 44 2 - -

Total 699 22 447 15 474 15 0 0
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-15 April 2015

Draft EA

1 The restoration of vernal pool habitat within each of the proposed mitigation areas would be phased 

2 (i.e., one mitigation area, or a portion thereof, would be developed at a time). Regulatory commitments 

3 would similarly be phased as proposed mitigation areas are formally planned for use. In addition, 

4 development of the conceptual vernal pool areas within each mitigation area would likely also be phased 

5 (i.e., the development areas within each mitigation area could be developed all at once or sequentially). 

6 All areas and sites would be restored, as described previously in Section 2.1, with environmental 

7 protection measures described in Section 2.3 implemented, as applicable.

8 Regardless of the alternative selected, Area Delta would be restored first because it supports an existing 

9 vernal pool mitigation project currently undergoing active maintenance and monitoring (MV-22 Basing 

10 Mitigation). This already limits land use and requires conservation management and protection to the 

11 area. Using Area Delta first would also allow the most efficient capture of credit for a potential surplus 

12 from the MV-22 Basing Mitigation project. The order of subsequent phases would be determined by 

13 MCAS Miramar once mitigation within Area Delta has been completed.

14 2.2.1 Alternative 1: Full Mitigation Area (Preferred Alternative)

15 The Full Mitigation Area Alternative (Alternative 1) could ultimately create about 22 acres of vernal pool

16 basins within six proposed mitigation areas (proposed mitigation areas Alpha through Foxtrot) at MCAS 

17 Miramar (Figure 2-1; Table 2-2).

18 2.2.2 Alternative 2: Partial Configuration A (Areas Alpha, Bravo North, Delta, 

19 and Echo)

20 This alternative could ultimately create about 15 acres of vernal pool basins within four proposed 

21 mitigation areas (proposed mitigation areas Alpha, Bravo North, Delta, and Echo) at MCAS Miramar 

22 (Figure 2-1; Table 2-2). The partial configuration reduces the options for phased implementation of vernal 

23 pool restoration and the total potential vernal pool restoration. However, this alternative meets the 

24 purpose and need and was developed based on the following rationale:

25 • Proposed mitigation areas within this alternative are not located under the direct aircraft approach 

26 to the airfield from the east, which may be needed in the future for placement of aircraft 

27 navigational equipment;

28 • The configuration includes areas of lesser operational importance that have been subject to non29 military land use interests (such as removing Bravo South);

30 • There is low potential for ground-based field training use;

31 • Areas Delta and Echo underlie aircraft APZs, which reduces the potential for future conflicts with 

32 military operations or new development;

33 • All sites provide potential for connection to jurisdictional Waters of the U.S.;

34 • There is sufficient suitable area for vernal pool restoration;

35 • Access is available to most areas;

36 • Proposed mitigation areas include sites previously used for vernal pool mitigation, and thus are 

37 already subject to special conservation protection (e.g., proposed mitigation area Delta includes 
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-16 April 2015

Draft EA

1 vernal pool mitigation for the MV-22 Basing; proposed mitigation area Echo includes vernal pool 

mitigation from the Harris Plant Lease4 2 ); and

3 • This configuration includes sites suitable for re-establishment of the federally listed willowy 

4 monardella (proposed mitigation area Bravo North).

5 2.2.3 Alternative 3: Partial Configuration B (Areas Charlie, Delta, Echo,

6 and Foxtrot)

7 The Partial Configuration B Alternative (Alternative 3) could ultimately create about 15 acres of vernal 

8 pool basins within four proposed mitigation areas (Areas Charlie, Delta, Echo, and Foxtrot) at MCAS 

9 Miramar (Figure 2-1; Table 2-2). Similar to Alternative 2, this partial configuration reduces the options 

10 for phased implementation of vernal pool restoration and the total potential vernal pool restoration. 

11 However, this alternative meets the purpose and need of the proposed action based on the following 

12 rationale:

13 • All areas underlie aircraft APZs;

14 • There is low potential for ground-based field training use;

15 • Access is available to most areas, with the exception of Area Foxtrot;

16 • Proposed mitigation areas are close or adjacent to each other, which may provide cost and/or 

17 logistical efficiencies;

18 • There is sufficient suitable area for vernal pool restoration;

19 • Areas Charlie, Delta, Echo, and Foxtrot provide potential for connection to federal CWA Waters

20 of the U.S.;

21 • There is a limited need for range closure actions because Areas Echo and Foxtrot are not overlain 

22 by existing or former ranges; and

23 • This configuration also includes sites previously used for mitigation that already require special 

24 conservation protection (e.g., Area Charlie includes vernal pool mitigation for past BRAC

25 actions; Area Delta includes vernal pool mitigation for the MV-22 Basing; Area Echo includes 

26 vernal pool mitigation from the Harris Lease; and Area Foxtrot is located near the Miramar 

27 Mounds National Natural Landmark).

28 2.2.4 No Action Alternative

29 Under the No Action Alternative, the proposed mitigation areas would not be specifically identified and 

30 approved for future impacts to federally listed vernal pool species and jurisdictional Waters of the U.S.

31 from projects at MCAS Miramar. As described in Chapter 1, impacts to federally listed vernal pool 

32 species and jurisdictional Waters of the U.S. would be mitigated on a project-by-project basis.

33 Without a well-planned mitigation program, projects at MCAS Miramar would have to individually fund 

34 compensatory mitigation for any impacts to federally listed vernal pool species and jurisdictional Waters

 4 The Harris Plant (owned by Hanson Aggregates) is a 76-acre private inholding within the boundaries of MCAS 

Miramar, located south of the Mainside. Adjacent to this property, the company obtained rights from the Navy for 

mineral extraction on two separate parcels (Parcel A and Parcel B) on what is now MCAS Miramar. The presence 

of vernal pool habitat on Parcel A resulted in cancellation of mining and required mitigating restoration of 

damaged vernal pools on the site. 
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-17 April 2015

Draft EA

1 of the U.S. Benefits of regulatory agency pre-approval and advanced mitigation would not be realized. 

2 The ability to develop mitigation credit in advance and independent of project-specific requirements 

3 would not be possible. For smaller construction and repair projects, the added cost of mitigation has the 

4 potential to cause the total project cost to exceed the threshold for a Military Construction Project, 

5 requiring Congressional approval.

6 The No Action Alternative is not considered a reasonable alternative because it does not meet the purpose 

7 and need for the proposed action. While compensatory mitigation could occur on a project-by-project basis 

8 under the No Action Alternative, it would require additional time to execute and higher mitigation ratios. 

9 Therefore, the No Action Alternative does not meet the purpose of the proposed action to establish an 

10 efficient means to mitigate for impacts to listed vernal pool species and jurisdictional Waters of the U.S. or 

11 the need to provide flexibility and cost-effective mitigation.

12 However, the No Action Alternative does provide a measure of the baseline conditions against which 

13 impacts of the proposed action can be compared. In this EA, the No Action Alternative represents the 

14 baseline condition described in Chapter 3. In addition, the No Action Alternative would be implemented 

15 in the event that MCAS Miramar decides not to go forward with the proposed action.

16 2.2.5 Alternatives Considered but Eliminated

17 As part of MCAS Miramar’s decision-making process, three potential mitigation areas alternatives were 

18 considered but eliminated as infeasible.

19 2.2.5.1 Alternative Location Off-MCAS Miramar

20 Establishing proposed mitigation areas at different locations off of MCAS Miramar was evaluated as a 

21 potential alternative. However, mitigation on land outside of MCAS Miramar is costly, and the 

22 availability of suitable locations within Southern California is limited. Therefore, this alternative was 

23 eliminated from further consideration.

24 2.2.5.2 Alternative Locations at MCAS Miramar

25 Northwestern Portion of MCAS Miramar

26 Developing proposed mitigation areas in the northwestern portion of MCAS Miramar was evaluated as a 

27 potential location for the proposed action. However, the presence of the Veterans Affairs Cemetery limits 

28 establishment of the potential mitigation areas in this location. The capacity to create new vernal pools is 

29 quite limited when considering a larger banking approach. In addition, this area is located relatively far 

30 away from the other potential mitigation areas that could hamper collective bank management and 

31 conservation. Therefore, this location was eliminated from further consideration.

32 Southeastern Portion of MCAS Miramar

33 There is low potential to create a large number of vernal pools in the southeastern part of the Station 

34 because of inappropriate topography. Access to the area is limited because it is within the surface danger 

35 zone of firing ranges adjacent to Training Area 5. Therefore, this location was eliminated from further 

36 consideration.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-18 April 2015

Draft EA

1 South-central Portion of MCAS Miramar

2 Potential locations adjacent to or within the Miramar Mounds National Natural Landmark were also 

3 evaluated (just to the north of SR-52). The existing designation of the landmark would benefit any 

4 restoration done there. However, beyond Area Foxtrot, which is evaluated in this EA, the amount of 

5 suitable restoration area is quite limited and access is difficult because of existing vernal pool resources.

6 2.3 Environmental Protection Measures

7 This section summarizes the environmental protection measures that would be included in all action 

8 alternatives (i.e., Alternative 1, Alternative 2, and Alternative 3). These measures would be included as 

9 requirements on all relevant project scoping, scheduling, and planning documents.

10 2.3.1 General Measures

11 1. Access to restoration areas will maximize the use of existing roads and by transiting 20-foot fence 

12 line security clear zones. However, new temporary unpaved access roads and temporary 

13 laydown/stockpiling areas may be required for sites that do not have existing access roads or 

14 access suitable for the delivery of heavy equipment. When required, these will be depicted on 

15 restoration plans and designed to minimize disturbance. All measures prescribed to the restoration 

16 of vernal pool upland watershed areas also apply to establishment and restoration of temporary 

17 access roads. 

18 2. MCAS Miramar will coordinate with the San Diego Regional Water Quality Control Board 

19 (RWQCB) to ensure compliance with the National Pollution Discharge Elimination System 

20 (NPDES) permit program. Project activities may be eligible for a Rainfall Erosivity Waiver, if the 

21 rainfall erosivity is less than five during the period of construction activity and the disturbance is 

22 less than 5 acres. If the project is not eligible for the waiver and the ground disturbance is greater 

23 than one (1) acre, the project will need coverage under the Construction General Permit. Specific 

24 conformance requirements include submitting a Notice of Intent to the State Water Resources 

25 Control Board (SWRCB), implementing a Storm Water Pollution Prevention Plan (SWPPP) for 

26 the proposed construction, including associated BMPs, and submitting a Notice of Termination to 

27 the SWRCB upon completion of construction.

28 3. Should petroleum-impacted soil be encountered during excavation, MCAS Miramar will comply 

29 with all applicable requirements of the San Diego RWQCB Order No. R9-2002-0342.

30 4. No earthwork, storage of equipment/vehicles, or other type of laydown work would be allowed 

31 within the MRP Site 1 until all necessary remedial action activities are deemed complete by the 

32 appropriate regulatory agencies.

33 5. Temporary activities that involve the storage of oils in quantities equal to or greater than 

34 55-gallon are required to implement Spill Prevention, Control, and Countermeasures (SPCC) 

35 requirements as presented in 40 CFR 112; MCO P5090.2A, Chapter 7; and the MCAS Miramar 

36 SPCC Plan. This includes any container used for standby storage, seasonal storage, temporary 

37 storage, or not otherwise considered “permanently closed.” Additionally, spill containment 

38 structures must be provided to prevent spills, leaks, and unauthorized discharges.

39 6. In the event that contamination is discovered, grading/excavation activities will be conducted in 

40 compliance with EPA BMPs for Region IX; 40 CFR Part 260 (Federal Hazardous Waste 

41 Regulations); and California Code of Regulations, Title 22 (Minimum Standards for Management 

42 of Hazardous and Extremely Hazardous Wastes). The contamination will be appropriately 

43 documented and the proper regulatory program would be consulted for further requirements. In 
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-19 April 2015

Draft EA

1 the event that contaminated soil is removed from a proposed mitigation area, appropriate hazard 

2 constituent sampling and testing will be completed in accordance with the regulations noted 

3 above. In addition, stockpiled soil will be properly characterized using San Diego Department of 

4 Environmental Health Site Assessment and Mitigation Manual, and any contaminated soil 

5 excavated would be managed in accordance with conditions set forth in San Diego 

6 RWQCB Order No. R9-2002-342.

7 2.3.2 Specific Protection Measures

8 2.3.2.1 Air Quality/Greenhouse Gases

9 Measure 1. Fugitive Dust Control. MCAS Miramar, restoration oversight authority, or the duly 

10 designated contractor will ensure that fugitive dust emissions do not extend beyond the property line for 

11 more than 3 minutes in any 60-minute period and will mitigate fugitive dust to minimize track out/carry 

12 out emissions during restoration activities/development, and transport in accordance with the San Diego 

13 County Air Pollution Control District (SDCAPCD) Rule 55.

14 The restoration contractor will implement the following measures, where applicable, to minimize fugitive 

15 dust emissions: 

16 1. Use water trucks or sprinkler systems to keep all areas of vehicle movement damp enough to 

17 prevent dust from leaving the restoration area.

18 2. Minimize the amount of disturbed ground area at a given time.

19 3. Minimize traffic speeds on all unpaved roads.

20 4. Install gravel pads at restoration area access points to prevent tracking of soil onto paved roads, 

21 where applicable.

22 5. Provide temporary wind fencing around sites being graded or cleared.

23 6. Suspend all soil disturbance activities when winds exceed 25 miles per hour or when visible dust 

24 plumes emanate from the site. Stabilize all disturbed areas at this time.

25 7. Cover truck loads that haul dirt, sand, or gravel or maintain at least two feet of freeboard in 

26 accordance with Section 23114 of the California Vehicle Code.

27 8. After completion of clearing, grading, earthmoving, or excavation, treat the disturbed areas by 

28 watering, revegetation, or by spreading non-toxic soil binders to stabilize restoration areas and

29 prevent dust generation.

30 9. Designate personnel to monitor the dust control program and to order increased watering, as 

31 necessary, to prevent the transport of dust off-site. Their duties would include holiday and 

32 weekend periods when work may not be in progress.

33 Measure 2. Construction Equipment Emission Control Measures. The restoration contractor will

34 implement the following measures during proposed vernal pool development activities, where feasible. 

35 1. Maintain equipment according to manufacturer specifications.

36 2. Restrict idling of equipment and trucks to a maximum of five minutes at any location.

37 3. Ensure that diesel oxidation catalysts and/or catalyzed diesel particulate traps are installed on 

38 equipment exhaust systems.

39 4. Use construction equipment with engines that meet EPA Tier 3 and 4 non-road standards.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-20 April 2015

Draft EA

1 5. Use alternatively fueled construction equipment, such as compressed natural gas, liquefied 

2 natural gas, or electric. 

3 2.3.2.2 Biological Resources

4 The proposed action includes many measures applicable to vernal pools, associated vernal pool species, 

5 and vernal pool restoration. Those measures are described in Section 2.1 and are not repeated as 

6 environmental protection measures. Additional measures beyond those described in Section 2.1 are 

7 included below.

8 Measure 3. Avoid and Minimize Disturbance to Sensitive Resources.

9 1. During the site-specific design, the proposed vernal pool restoration sites will be selected to avoid 

10 sensitive plant and wildlife species to the extent feasible. In addition, restoration sites will be 

11 located in disturbed or non-native habitats to the extent feasible. 

12 2. Where existing survey data do not exist, a qualified biologist will identify and survey (during the 

13 appropriate time of year) sensitive resources in the vicinity of any proposed grubbing, grading, or 

14 restoration activities to protect or relocate the individuals. Resources of primary concern are the 

15 coastal California gnatcatcher, and vernal pools, federally listed plant species.

16 3. Sensitive resources to be protected will be identified and marked beyond their boundaries for 

17 protection prior to any ground-disturbing activities.

18 Measure 4. Conduct Initial Vegetation Removal/Grubbing Outside of Nesting Season for Migratory Bird 

19 Treaty Act-Protected Species.

20 1. Any initial grading, grubbing, mowing, and/or removal of surface vegetation will be scheduled 

21 outside of the bird nesting season, to the maximum extent feasible, to avoid potential impacts on 

22 nesting. If surface vegetation removal cannot be completed outside of the nesting season, a 

23 biological monitor will be present and daily nest surveys will be completed by an MCAS 

24 Miramar-approved biologist immediately prior to earthwork to ensure that no nests would be 

25 affected. Most birds typically nest between January and August. Birds can nest in buildings, trees, 

26 shrubs, and on the ground. If nesting birds or eggs are encountered, the restoration contractor

27 must phase the work to avoid disrupting the birds. The restoration contractor cannot take action to 

28 remove the bird or nest from the areas which is being used. 

29 Measure 5. Avoid Impacts on coastal California Gnatcatcher, and Avoid, Minimize Disturbance to 

30 Suitable Habitat.

31 1. At proposed restoration sites in occupied California gnatcatcher habitat, any grading, mowing, 

32 and/or mechanical removal of surface vegetation, particularly native shrubs, will not be scheduled 

33 between 15 February and 15 August to avoid potential impacts to a nest.

34 2. Within occupied California gnatcatcher habitat, native shrubs typically used by the species will be 

35 protected. One exception would be narrow areas necessary to establish connection to Waters of 

36 the U.S., as outlined in site-specific restoration planning. Restoration reports will document the 

37 actual effects to the species.

38 3. The removal of native upland vegetation will be replaced through upland restoration at the same 

39 proposed mitigation area, including within the watershed area surrounding newly created or 

40 enhanced vernal pools.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-21 April 2015

Draft EA

1 Measure 6. Avoidance of Adjacent Vernal Pools and Other Seasonally Ponded Features Occupied by 

2 Federally Listed Species, but not Proposed for Enhancement. Vernal pools and other seasonally ponded 

3 basins occupied by federally listed vernal pool plant or fairy shrimp species, but not proposed for 

4 enhancement, will be protected.

5 1. Vernal pools and other seasonally ponded basins in the immediate vicinity of individual sites 

6 proposed for restoration will be clearly marked on restoration plans, and flagged or fenced prior 

7 to the start of restoration activities. During the rainy season (about 1 November to 1 June) 

8 adequate protective measures, as determined by the Project Biologist, will be implemented to 

9 prevent runoff into these adjacent basins.

10 2. Restoration will avoid an increase or decrease of water quantity, sediment transport, and change 

11 in water quality runoff to adjacent vernal pools or other seasonally ponded basins not proposed 

12 enhancement or restoration. Sedimentation shall be prevented through the implementation of 

13 BMPs and soil-disturbing activities during rainy season or when ground is wet (about 

14 1 November to 1 June) shall be minimized.

15 Measure 7. Invasive Plant Species Control. In addition to invasive plant and weed control on restoration 

16 sites, all equipment and/or vehicles will be power-washed before entering MCAS Miramar property and 

17 the proposed mitigation areas. 

18 Measure 8. Collection of Inoculum. No more than five percent of the surface of any inoculum source pool 

19 will be collected to minimize impacts to the source pool, and all inoculum collection will be supervised 

20 by a USFWS-permitted biologist or an MCAS Miramar staff biologist.

21 2.3.2.3 Cultural Resources

22 No Environmental Protection Measures are required with respect to Cultural Resources.

23 2.3.2.4 Geologic Resources

24 No Environmental Protection Measures are required with respect to Geologic Resources.

25 2.3.2.5 Land Use

26 No Environmental Protection Measures are required with respect to Land Use.

27 2.3.2.6 Public Health and Safety

28 No Environmental Protection Measures are required with respect to Public Health and Safety.

29 2.3.2.7 Water Resources

30 No Environmental Protection Measures are required with respect to Water Resources.

31 2.3.2.8 Summary of Environmental Protection Measures by Alternative

32 Although the scale of activities varies by proposed alternative, with Alternative 2 and Alternative 3 

33 representing a reduced scale of activities, the scope of activities would be the same across all alternatives. 

34 As a result, all general and specific Environmental Protection Measures would apply to all alternatives.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-22 April 2015

Draft EA

1 2.4 Summary of Impacts

2 Resource areas analyzed in this EA include the following: air quality/greenhouse gases; biological 

3 resources; cultural resources; geology/soils/seismicity; land use; and water resources. The environmental 

4 consequences associated with implementation of Alternative 1, Alternative 2, Alternative 3, and the No 

5 Action Alternative are presented and compared in Table 2-4. A detailed description of the affected 

6 environment and analysis of the environmental consequences are presented in Chapter 3.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-23 April 2015

Draft EA

Table 2-4. Summary of Impacts

Resource 

Area

Full Mitigation Area

(Alternative 1)

Partial Configuration A

(Areas Alpha, Bravo North, 

Delta, and Echo) (Alternative 2)

Partial Configuration B

(Areas Charlie, Delta, Echo, 

and Foxtrot) (Alternative 3) No Action Alternative

Air Quality/ 

Greenhouse 

Gases

Emissions from Alternative 1 would be below the 

Conformity Rule de minimis or the Prevention of 

Significant Deterioration thresholds and would satisfy 

the conditions of a Clean Air Act Record of NonApplicability (RONA). Implementation of 

Environmental Protection Measures 1 and 2 would 

minimize emissions of fugitive dust and construction 

equipment emission during earthwork. The mobile 

and intermittent operation of proposed dieselpowered construction equipment over a large area

would result in disperse emissions of toxic air 

contaminants (TACs) from these sources, which 

would produce minimal ambient impacts of these 

pollutants. Therefore, significant impacts to air quality 

would not occur and no mitigation beyond the 

Environmental Protection Measures described in 

Section 2.3 would be required.

Under Alternative 2, impacts on 

air quality would be de minimis. 

Implementation of Environmental 

Protection Measures 1 and 2 

would minimize emissions of 

fugitive dust and construction 

equipment emission during 

earthwork. Therefore, 

significant impacts to air quality 

would not occur and no mitigation 

beyond the Environmental 

Protection Measures described in 

Section 2.3 would be required.

Under Alternative 3, impacts on 

air quality would be de minimis. 

Implementation of Environmental 

Protection Measures 1 and 2 

would minimize emissions of 

fugitive dust and construction 

equipment emission during 

earthwork. Therefore, 

significant impacts to air quality 

would not occur and no mitigation 

beyond the Environmental 

Protection Measures described in 

Section 2.3 would be required.

For the No Action 

Alternative, the proposed 

action would not occur, and 

there would be no change 

in existing conditions. No 

impacts on air quality would 

occur and no mitigation is 

required.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-24 April 2015

Draft EA

Table 2-4. Summary of Impacts

Resource 

Area

Full Mitigation Area

(Alternative 1)

Partial Configuration A

(Areas Alpha, Bravo North, 

Delta, and Echo) (Alternative 2)

Partial Configuration B

(Areas Charlie, Delta, Echo, 

and Foxtrot) (Alternative 3) No Action Alternative

Biological 

Resources

Alternative 1 could result in the temporary loss of 

suitable habitat for the federally listed coastal 

California gnatcatcher within proposed mitigation 

areas Charlie and Echo; however, the amount of 

potentially suitable habitat removed for each 

restoration would be very small and all upland 

watershed plants removed would be immediately 

restored in place. Disturbed upland areas subject to 

restoration would be replaced with native shrubs 

suitable for the California gnatcatcher or other 

appropriate types representing a net benefit. 

Seasonal avoidance of vegetation removal/grubbing 

would avoid direct adverse impacts to nesting 

gnatcatchers. 

For migratory bird species, suitable habitat exists in 

all proposed mitigation areas and restoration 

activities could result in the temporary loss of habitat 

and an increase in noise, dust, and activity. Seasonal 

avoidance and on-site restoration of upland habitats 

would reduce the potential adverse impacts.

Under Alternative 2, adverse 

impacts to gnatcatchers would be 

similar to Alternative 1; however, 

only proposed mitigation area 

Echo supports gnatcatchers 

under this alternative.

Adverse impacts to migratory 

birds would also be similar but 

reduced as compared to 

Alternative 1, including temporary 

loss of habitat and increase in 

noise, dust, and activity in small 

areas subject to 

development/restoration. 

Seasonal avoidance and on-site 

restoration of upland habitats 

would reduce the potential 

adverse impacts.

Under Alternative 3, impacts to 

coastal California gnatcatchers 

would be identical to 

Alternative 1. 

Adverse impacts to migratory 

birds would also be similar but 

reduced as compared to 

Alternative 1, including temporary 

loss of habitat and increase in 

noise, dust, and activity in small 

areas subject to 

development/restoration. 

Seasonal avoidance and on-site 

restoration of upland habitats 

would reduce the potential 

adverse impacts.

For the No Action 

Alternative, the proposed 

action would not occur, and 

there would be no change 

in existing conditions. No 

impacts, beneficial or 

adverse, on biological 

resources would occur and 

no environmental 

protection measures are 

proposed. 
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-25 April 2015

Draft EA

Table 2-4. Summary of Impacts

Resource 

Area

Full Mitigation Area

(Alternative 1)

Partial Configuration A

(Areas Alpha, Bravo North, 

Delta, and Echo) (Alternative 2)

Partial Configuration B

(Areas Charlie, Delta, Echo, 

and Foxtrot) (Alternative 3) No Action Alternative

Biological 

Resources

(continued)

Alternative 1 could also result in impacts to special 

status vernal pool species resulting from 

seed/inoculum collection and disturbance to existing 

basins during enhancement. Potential adverse 

impacts resulting from the collection of inoculum 

would be minimized by limiting the collection to no 

more than five percent of the surface area from a 

vernal pool (Environmental Protection Measure 8). 

The longer term ecological benefits of enhanced

vernal pools would exceed the adverse impacts 

associated with the temporary ground disturbance 

caused during restoration. In conclusion, potential 

adverse impacts would not be significant and 

implementation of Environmental Protection 

Measures 3 through 8 as described in Section 2.3 

would further reduce the scope and scale of adverse 

effects. Potential long-term effects would be 

beneficial resulting from an overall in-place increase 

in the ecological condition and quantity of vernal pool 

habitat.

Similarly, beneficial and adverse 

impacts to special status vernal 

pool species resulting from 

seed/inoculum collection and/or 

incidental damage to existing 

basins targeted for enhancement

would occur. Potential adverse 

impacts would not be significant 

and implementation of 

Environmental Protection 

Measures 3 through 8 as 

described in Section 2.3 would 

further reduce the scope and 

scale of adverse effects. Potential 

long-term effects would be 

beneficial resulting from an 

overall in-place increase in the 

ecological condition and quantity 

of vernal pool habitat.

Similarly, beneficial and adverse 

impacts to special status vernal 

pool species resulting from 

seed/inoculum collection and/or 

incidental damage to existing 

basins targeted for enhancement

would occur. Potential adverse 

impacts would not be significant 

and implementation of 

Environmental Protection 

Measures 3 through 8 as 

described in Section 2.3 would 

further reduce the scope and 

scale of adverse effects. Potential 

long-term effects would be 

beneficial resulting from an 

overall in-place increase in the 

ecological condition and quantity 

of vernal pool habitat.

Cultural 

Resources

There are no known traditional cultural resources, or 

historic buildings or structures eligible for the National 

Register of Historic Places (NRHP), located in the 

project Area of Potential Effects (APE) or immediately 

adjacent to the APE. In the event that previously 

unrecorded or unevaluated cultural resources are 

encountered, MCAS Miramar would manage these 

resources in accordance with the Integrated Cultural 

Resources Management Plan (ICRMP).

There are no known traditional 

cultural resources, or historic 

buildings or structures eligible for 

the NRHP, located in the project 

APE or immediately adjacent to 

the APE. In the event that 

previously unrecorded or 

unevaluated cultural resources 

are encountered, MCAS Miramar 

would manage these resources in 

accordance with the ICRMP.

There are no known traditional 

cultural resources, or historic 

buildings or structures eligible for 

the NRHP, located in the project 

APE or immediately adjacent to 

the APE. In the event that 

previously unrecorded or 

unevaluated cultural resources 

are encountered, MCAS Miramar 

would manage these resources in 

accordance with the ICRMP.

For the No Action 

Alternative, the proposed 

action would not occur, and 

there would be no change 

in existing conditions. No 

impacts on cultural 

resources would occur and 

no mitigation is required.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-26 April 2015

Draft EA

Table 2-4. Summary of Impacts

Resource 

Area

Full Mitigation Area

(Alternative 1)

Partial Configuration A

(Areas Alpha, Bravo North, 

Delta, and Echo) (Alternative 2)

Partial Configuration B

(Areas Charlie, Delta, Echo, 

and Foxtrot) (Alternative 3) No Action Alternative

Geologic 

Resources

With conformance to established plans and policies,

and through coordination and compliance with the 

NPDES permit program, including implementation of 

standard BMPs, and erosion control measures, 

significant impacts to geologic resources would not 

occur and no mitigation beyond the Environmental 

Protection Measures described in Section 2.3 would 

be required.

Under Alternative 2, impacts on 

geologic resources would be 

comparable to Alternative 1, but 

potentially fewer temporary 

access roads may be required. 

Therefore, significant impacts to 

geologic resources would not 

occur and no mitigation beyond 

the Environmental Protection 

Measures described in 

Section 2.3 would be required.

Under Alternative 3, impacts on 

geologic resources would be 

comparable to Alternative 1, but 

potentially fewer temporary 

access roads may be required. 

Therefore, significant impacts to 

geologic resources would not 

occur and no mitigation beyond 

the Environmental Protection 

Measures described in 

Section 2.3 would be required.

For the No Action 

Alternative, the proposed 

action would not occur, and 

there would be no change 

in existing conditions. No 

impacts on geologic 

resources would occur and 

no mitigation is required.
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-27 April 2015

Draft EA

Table 2-4. Summary of Impacts

Resource 

Area

Full Mitigation Area

(Alternative 1)

Partial Configuration A

(Areas Alpha, Bravo North, 

Delta, and Echo) (Alternative 2)

Partial Configuration B

(Areas Charlie, Delta, Echo, 

and Foxtrot) (Alternative 3) No Action Alternative

Land Use Alternative 1 would have a beneficial impact on land 

use by improving strategic planning for future mission 

requirements, reducing future development costs, 

utilizing partially constrained land for compensatory 

mitigation, and minimizing land use incompatibility 

issues. The mitigation sites would be designated as 

INRMP Level I Management Areas, which support 

the Station’s conservation and management of vernal 

pool habitat and limits future land uses. Alternative 1 

would be compatible with existing uses (i.e., minimal 

development within the APZs) and land use 

constraints (APZ and Air Installations Compatible Use 

Zone [AICUZ]) at the project sites and in the project 

vicinity. Military operations would continue to occur 

over and in areas surrounding the mitigation sites.

Implementation of Alternative 1 would require an 

update to the MCAS Miramar Master Plan and the 

MCAS Miramar INRMP. Following the update, 

Alternative 1 would be consistent with the MCAS 

Miramar Master Plan and the MCAS Miramar INRMP. 

Therefore, beneficial impacts would occur. 

Alternative 2 would have a 

beneficial impact on land use by 

improving strategic planning for 

future mission requirements, 

utilizing partially constrained land 

for compensatory mitigation, 

and minimizing land use 

incompatibility issues. 

Designation of the mitigation sites

as INRMP Level I Management 

Areas would be compatible with 

existing uses and land use 

constraints at the project sites 

and in the project vicinity. Military 

operations would continue to 

occur over and in areas 

surrounding the mitigation sites. 

Implementation of Alternative 2 

would require an update to the 

MCAS Miramar Master Plan and 

the MCAS Miramar INRMP. 

Following the update, Alternative 

2 would be consistent with the 

MCAS Miramar Master Plan and 

the MCAS Miramar INRMP. 

Alternative 3 would have a 

beneficial impact on land use by 

improving strategic planning for 

future mission requirements, 

utilizing partially constrained land

for compensatory mitigation, 

and minimizing land use 

incompatibility issues.

Designation of the mitigation sites

as INRMP Level I Management 

Areas would be compatible with 

existing uses and land use 

constraints at the project sites 

and in the project vicinity. Military 

operations would continue to 

occur over and in areas 

surrounding the mitigation sites. 

Implementation of Alternative 3 

would require an update to the 

MCAS Miramar Master Plan and 

the MCAS Miramar INRMP. 

Following the update, Alternative 

3 would be consistent with the 

MCAS Miramar Master Plan and 

the MCAS Miramar INRMP.

For the No Action 

Alternative, the proposed 

action would not occur, and 

there would be no change 

in existing conditions. No 

impacts on land use would 

occur and no mitigation is 

required. Under the No 

Action Alternative, some 

future conservation of 

these regulated resources 

may occur within or outside 

of the project area. The 

establishment of mitigation 

sites would occur on a 

project by project basis to 

support the mission and 

future military operations at 

MCAS Miramar; however, 

these future efforts would 

not be systematically 

planned as part of a longterm strategy. 
MCAS Miramar 2 Proposed Action and Alternatives

Vernal Pool Mitigation Area Planning 2-28 April 2015

Draft EA

Table 2-4. Summary of Impacts

Resource 

Area

Full Mitigation Area

(Alternative 1)

Partial Configuration A

(Areas Alpha, Bravo North, 

Delta, and Echo) (Alternative 2)

Partial Configuration B

(Areas Charlie, Delta, Echo, 

and Foxtrot) (Alternative 3) No Action Alternative

Public 

Health and 

Safety

The project would comply with established plans and 

policies; the DoN Environmental Restoration 

Program; USACE EM 385-1-4 (U.S. Safety and 

Health Requirement Manual); MCO 5090.2A (USMC

Environmental Compliance and Protection Manual); 

and EO 13423 (Strengthening Federal 

Environmental, Energy, and Transportation 

Management). Therefore, significant impacts to public 

health and safety would not occur and no mitigation is 

required.

Under Alternative 2, impacts on 

public health and safety would be 

the same as those described for 

Alternative 1. Therefore, 

significant impacts to public 

health and safety would not occur 

and no mitigation is required.

Under Alternative 3, impacts on 

public health and safety would be 

the same as those described for 

Alternative 1. Therefore, 

significant impacts to public 

health and safety would not occur

and no mitigation is required.

For the No Action 

Alternative, the proposed 

action would not occur, and 

there would be no change 

in existing conditions. No 

impacts on public health 

and safety would occur and 

no mitigation is required.

Water 

Resources

Alternative 1 may require the establishment of 

temporary access roads, which would potentially 

increase erosion locally, but not likely discharge 

sediment that would affect the quality of surface 

water. All ground disturbance activities would be 

managed in coordination with the San Diego RWQCB 

and in conformance with applicable requirements 

including the NPDES permit program and SPCC 

Plan. Therefore, significant adverse impacts to water 

resources would not occur and no mitigation beyond 

the Environmental Protection Measures described in 

Section 2.3 would be required.

Under Alternative 2, impacts on 

water resources would be similar 

to those described for Alternative 

1, although fewer temporary 

access roads may be required

(based on fewer proposed 

mitigation areas under this 

alternative). All ground 

disturbance activities would be 

managed in coordination with the 

San Diego RWQCB and in 

conformance with applicable 

requirements including the 

NPDES permit program and 

SPCC. Therefore, significant 

impacts to water resources would 

not occur, and no mitigation 

beyond the Environmental 

Protection Measures described in 

Section 2.3 would be required.

Under Alternative 3, impacts on 

water resources would be similar 

to those described for Alternative 

1, although fewer temporary 

access roads may be required

(based on fewer proposed 

mitigation areas under this 

alternative). All ground 

disturbance activities would be 

managed in coordination with the 

San Diego RWQCB and in 

conformance with applicable 

requirements including the 

NPDES permit program and 

SPCC Plan. Therefore, significant 

impacts to water resources would 

not occur and no mitigation 

beyond the Environmental 

Protection Measures described in 

Section 2.3 would be required.

For the No Action 

Alternative, the proposed 

action would not occur, and 

there would be no change 

in existing conditions. No 

impacts on public water 

resources would occur and 

no mitigation is required.