Vernal Pool Mitigation Area Planning 5-1 April 2015

Draft EA 

5 List of Personnel or Agencies Contacted or Consulted

1 United States Government

2 Department of the Navy

3 Rachelle Hill, NAVFAC SW Environmental Planner

4 Karen Mabb, NAVFAC SW Natural Resource Specialist

5 United States Marine Corps

6 Myrna Alzaga, MCAS Miramar Environmental Management Department

7 Chuck Black, MCAS Miramar Environmental Management Department

8 Dave Boyer, MCAS Miramar Environmental Management Department

9 Colleen Eckenroad, MCB Camp Pendleton, Environmental Security

10 Lieutenant Colonel Thomas Fries, MCAS Miramar Command

11 Tony Guinn, MCAS Miramar Operations

12 Rick Gomez, MCAS Miramar S-3 Training

13 John Hawthorne, MCAS Miramar Operations

14 JoEllen Kassebaum, MCAS Miramar Environmental Management

15 Lieutenant Colonel Thomas Kerley, MCAS Miramar Environmental Management

16 Delmer Lake, MCAS Miramar I&L/Public Works Department

17 Ronald E. Lamb, CEP, HQMC/MCICOM GF-7

18 Ros Lezerda, MCAS Miramar I&L/Public Works Department

19 Juan Lias, MCAS Miramar CP&L

20 Zak Likins, MCI West

21 Bill Moog, MCAS Miramar Environmental Management

22 Ryan Orndorff, MCI Headquarters

23 Antoinette Perez, MCAS Miramar I&L/Real Estate

24 Bertha Riens, MCAS Miramar I&L/Real Estate

25 Captain Jody Stelly, MCAS Miramar I&L/Public Works Department

26 Keith Spencer, MCAS Miramar S-7

27 John Stimson, MCAS Miramar Legal Counsel

28 Lieutenant Colonel Eric Wolf, MCAS Miramar I&L

29 United States Army Corps of Engineers

30 Peggy Bartels, USACE Regulatory

31 Therese Bradford, USACE Regulatory

32 Meris Bantilan-Smith, USACE Regulatory
MCAS Miramar 5 Personnel or Agencies Contacted

Vernal Pool Mitigation Area Planning 5-2 April 2015

Draft EA 

1 United States Environmental Protection Agency

2 Elizabeth Goldmann, EPA Region 9

3 United States Fish and Wildlife Service

4 Katy Kughen, Biologist

5 Jonathan Snyder, Supervisory Biologist
Vernal Pool Mitigation Area Planning 6-1 April 2015

Draft EA 

6 List of Preparers

1 Lead Agency

2 USMC

3 MCAS Miramar

4 San Diego, California

5 Myrna Alzaga, Project Leader

6 This EA was prepared for MCAS Miramar under the direction of the DoN by Leidos (formerly a part of 

7 SAIC). Members of Leidos’ professional staff who contributed to the preparation of this document are 

8 listed below. 

Name Title Degree

Years of 

Experience Project Participation

Trevor Pattison Program Manager/ 

Senior Environmental 

Scientist

B.S., Geological SciencesEarth Systems16 Project Manager, 

Endangered Species Act, 

Biological Resources, 

QA/QC

Catrina Gomez Project Manager/ 

Environmental Planner

MSEM, Environmental 

Science and Management

10 Deputy Project Manager;

Executive Summary; 

Land Use; Other NEPA 

Considerations

Chris Crabtree Air Quality Specialist B.A., Environmental Studies 21 Air Quality

Joel Degner, PE, 

CPSWQ, QSD/QSP

Hydrologist/Biologist B.S., Hydrologic Sciences 10 Biological Resources, 

Water Resources, 

Restoration Ecology

Catherine FitzGerald Graphic Artist A.A., Fine Arts 30+ Graphic Design

Karen Foster, RPA Cultural Resources 

Manager/NEPA P

Ph.D., Anthropology 20 Cultural Resources,

QA/QC

Joe Jimenez, RPA Cultural Resources 

Manager

M.A., Anthropology 30+ Cultural Resources

Perry Russell, PG, 

CEG

Geologist/ 

Hydrogeologist

M.S., Geological Sciences 24 Geological Resources; 

Public Health and Safety; 

Water Resources

Tara Schoenwetter Senior 

Ecologist/Biologist

Ph.D., Ecology & 

Conservation Biology

13 Biological Resources

Elizabeth Riley Word Processing 

Specialist

B.A., Psychology 3 Word Processing

Nicole Schoo Environmental Scientist B.S., Biology 3 Copy Editing

Alison Smith Editor B.A., English 7 Technical Editing

Chris Woods GIS Programmer B.A., Geography 15 GIS

Andrew Nelson Senior Planner MPP, Environmental Policy 30+ QA/QC
MCAS Miramar 6 List of Preparers

Vernal Pool Mitigation Area Planning 6-2 April 2015

Draft EA 

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Vernal Pool Mitigation Area Planning 7-1 April 2015

Draft EA 

7 References

1 Accord MACTEC Joint Venture (AMJV). 2012. Draft Soil Assessment Report For The Proposed 

2 Wastewater Equalization Tank Site. Unpublished report prepared for U.S. Department of the 

3 Navy, Naval Facilities Engineering Command, Southwest; San Diego, California. Contract 

4 No.: N62473–09–D–2613.

5 Airport Land Use Commission. 2011. MCAS Miramar Airport Land Use Compatibility Plan, Adopted 

6 October 2008, Amended December 2010 and November 2011. San Diego County Regional 

7 Airport Authority. November.

8 AMEC Environment & Infrastructure, Inc. 2014. Draft Mission Bay Watershed Management Area Water

9 Quality Improvement Plan. Submitted to the San Diego Regional Water Quality Control Board by 

10 the City of San Diego and Caltrans.

11 Baldwin, B.G., D.H. Goldman, D.J. Keil, R. Patterson, T.J. Rosatti, and D.H. Wilken, editors. 2012. The 

12 Jepson Manual: Vascular Plants of California, Second Edition. University of California Press, 

13 Berkeley.

14 Bitterroot Restoration, Inc. 2005. Coastal California Gnatcatcher (Polioptila californica californica)

15 Surveys on Marine Corps Air Station Miramar, San Diego, California. Final Report. San Diego, 

16 CA.

17 Black, C.H. 2009. Identification of Basins Suitable for Restoration and Enhancement 2005-06 through 

18 2007-08 Rainfall Years. Contract N68711-04-D-6216. Prepared for MCAS Miramar, Natural 

19 Resources Division, in Cooperation with Naval Facilities Engineering Command Southwest, San 

20 Diego, California. Final Report.

21 . 2007. Vernal Pool Regulatory Surveys, Marine Corps Air Station Miramar, San Diego, 

22 California. Potential Pool Re-establishment Surveys, 2004-05 Rainfall Year. Contract N68711-

23 04-D-6216. Prepared for MCAS Miramar, Natural Resources Division, in Cooperation with 

24 Naval Facilities Engineering Command Southwest, San Diego, California. Final Report.

25 California Air Resources Board (ARB). 2012. Ambient Air quality Standards. Available at: 

26 http://www.arb.ca.gov/research/aaqs/aaqs2.pdf. Accessed: 03 May 2013.

27 . 2009. 2008 Estimated Annual Average Emissions - San Diego County. Available at:

28 http://www.arb.ca.gov/app/emsinv/emssumcat_query.php?F_DIV=-

29 4&F_DD=Y&F_YR=2008&F_SEASON=A&SP=2009&F_AREA=CO&F_CO=37. Accessed: 

30 03 May 2013.

31 California Energy Commission. 2012. Our Changing Climate 2012 - Vulnerability & Adaptation to the 

32 Increasing Risks from Climate Change in California: A Summary Report on the third Assessment 

33 from the California Climate Center. Publication number CEC-500-2012-007. Available at: 

34 http://www.climatechange.ca.gov/adaptation/third_assessment/. Accessed on: 03 May 2013.

35 Council on Environmental Quality (CEQ). 2010. Draft Guidance for Greenhouse Gas 

36 Emissions and Climate Change Impacts. Available at http://www.whitehouse.gov/administration/

37 eop/ceq/initiatives/nepa/ghg-guidance. Accessed: 21 February 21 2013.

38 . 1997. CEQ Handbook: Considering Cumulative Effects under the National Environmental 

39 Protection Act. January.

40 Department of the Navy (DoN). 2010. Final United States Marine Corps F-35B West Coast Basing 

41 Environmental Impact Statement. October.

42 . 1996. Final Environmental Impact Statement Realignment of NAS Miramar. San Diego, 

43 California, February.
MCAS Miramar 7 References

Vernal Pool Mitigation Area Planning 7-2 April 2015

Draft EA 

1 Donald, D.B. 1983. Erratic occurrence of anostracans in a temporary pond: colonization and extinction or 

2 adaptation to variations in annual weather. Can. J. Zool. 61: 1492-1498.

3 Dossey and Associates. 2008. Western Miramar Rare Plant Surveys Report, Marine Corps Air Station 

4 Miramar, San Diego, California (N68711-02-R-8077-0003,0004,005,0006). Prepared for MCAS 

5 Miramar and Naval Facilities Engineering Command, South West. August 18, 2008.

6 . 2006. Western Miramar Rare Plant Surveys, Final Report (Rose Canyon, Eastgate Mall, 

7 Areas Adjacent to I-805) Marine Corps Air Station Miramar, San Diego, California 

8 (N68711-02-D-8077-0001 and N68711-02-D-8077-0002). Prepared for MCAS Miramar and 

9 Naval Facilities Engineering Command, South West. September 17, 2006.

10 Eriksen, C.H. and D. Belk. 1999. Fairy Shrimps of California’s Puddles, Pools, and Playas. Mad River 

11 Press, Inc. Eureka, California.

12 Giacomini and Caudell. 2004. Post-Fire Archaeological Survey of 9635 Acres on Marine Corps Air 

13 Station Miramar, San Diego, California. October 2004.

14 Haas, W.E. 2010. Distribution of the California Gnatcatcher (Polioptila californica) on Marine Corps Air 

15 Station Miramar Results of 2009 Surveys. Report prepared under contract M67865-08-T-0068. 

16 33pp+figs

17 Hector, S., S. Ghabhlain, M. Becker, and K. Moslak. 2004. Archaeological Evaluation of 19 Sites on 

18 Marine Corps Air Station Miramar, San Diego County, California. October 2004.

19 Holland, R.F. 1986. Preliminary Description of the Terrestrial Natural Communities of California. State 

20 of California, The Resources Agency, Sacramento, CA.

21 Hubbs-Sea World Research Institute. 2006. The Effects of Helicopter Noise on the Coastal California 

22 Gnatcatcher at Marine Corps Air Station Miramar. Contract Number N68711-05-M-1008. Final 

23 Report Prepared for Marine Corps Air Bases Western Area and Naval Facilities Engineering 

24 Command, Southwest.

25 Intergovernmental Panel on Climate Change. 2014. Climate Change 2014: Impacts, Adaptation, and 

26 Vulnerability. Contribution of Working Group II to the Fifth Assessment Report of the 

27 Intergovernmental Panel on Climate Change. March.

28 Lichvar and Dixon. 2008. Delineation of Wetlands, Other Waters of the United States, and Nexus 

29 Determinations at Marine Corps Air Station Miramar, California. Main Station and Flight Line 

30 Areas.

31 Marine Corps Air Station (MCAS) Miramar. 2011a. Integrated Natural Resources Management Plan for 

32 Marine Corps Air Station Miramar, California.

33 . 2011b. Integrated Cultural Resources Management Plan Update for Marine Corps Air Station 

34 Miramar. Prepared by ASM Affiliates, Carlsbad, California. On file, Environmental Management 

35 Department, Natural Resources Division, MCAS Miramar.

36 . 2005. AICUZ Update, Air Installations Compatible Use Zones. Prepared by Southwest Division, 

37 Naval Facilities Engineering Command. San Diego, California. March.Marine Corps Installations 

38 West (MCI West). 2009. Greenhouse Gas Assessment for Marine Corps Installations West.

39 Natural Resource Conservation Service (NRCS). 2014. Custom Soil Report for San Diego County Area, 

40 California. Generated from http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx on May 

41 28, 2014.

42 Naval Facilities Engineering Command (NAVFAC). 2006a. Renewable Energy and Distributed 

43 Generation Projects.
MCAS Miramar 7 References

Vernal Pool Mitigation Area Planning 7-3 April 2015

Draft EA 

1 . 2006b. MCAS Miramar Master Plan. Unpublished report prepared for Marine Corps 

2 Installations, West.

3 Oberbauer, T., M. Kelly, and J. Buegge. 2008. Draft Vegetation Communities of San Diego County. 

4 Based on “Preliminary Descriptions of the Terrestrial Natural Communities of California.” 

5 Robert F. Holland, Ph.D., October 1986.

6 Quach and Becker, ASM Affiliates. 2015. 1200-Acre Survey on MCAS Miramar in Support of Section 

7 106 National Historic Preservation Act. Prepared for Department of the Navy, Naval Facilities 

8 Engineering Command, Southwest and Environmental Division, MCAS Miramar. Contract 

9 Number N62473-14-1415, Delivery Order 10. Final, March 2015.

10 RECON Environmental, Inc. 2008. Final Report for the 2007 MCAS Miramar Coastal California

11 Gnatcatcher Survey Project. Prepared for MCAS Miramar, San Diego, CA. San Diego, CA. 

12 35 pp. + maps and attachments.

13 San Diego County Air Pollution Control District (SDCAPCD). 2013a. Air Quality Planning. Available at: 

14 http://www.sdapcd.org/planning/plan.html. Accessed on: 03 May 2013.

15 . 2013b. Rules and Regulations. Available at: http://www.sdapcd.org/rules/rules.html. Accessed 

16 on 06 May 2013.

17 San Diego Regional Water Quality Control Board (RWQCB). 2011. Water Quality Control Plan for the 

18 San Diego Basin (9). Adopted by the California Regional Water Quality Control Board San 

19 Diego Region on 8 September 1994 with amendments effective on or before April 4, 2011.

20 Available at: http://www.swrcb.ca.gov/sandiego/water_issues/programs/basin_plan/. Accessed: 

21 18 November 2013.

22 Skinner M.W. and B.M. Pavlik. 1994. California Native Plant Society’s Inventory of Rare and 

23 Endangered Vascular Plants of California, Special Publication, 5th ed., California Native Plant 

24 Society.

25 Smith and Lichvar. 2001. Planning Level Delineation of Aquatic Resources, Floodplain Mapping, and 

26 Functional Assessment of Riparian Ecosystems at Marine Corps Air Station Miramar, San Diego 

27 County, California.

28 Tetra Tech, Inc. 2013. Willowy Monardella (Monardella viminea) Census and Monitoring surveys. Final 

29 Report. Report prepared under contract with NAVFAC SW contract N62470-08-D1008. January. 

30 . 2012. Del Mar Manzanita Monitoring Surveys Final Report, MCAS Miramar, San Diego, 

31 California. 

32 Tierra Data Inc. 2014. Coastal California Gnatcatcher (Polioptila californica californica) Surveys at 

33 Marine Corps Air Station Miramar, California. Final. Report prepared under contract N62473-06-

34 D-2402. January.

35 United States Department of Agriculture Soil Conservation Service. 1973. Soil Survey of San Diego 

36 County.

37 United States Environmental Protection Agency (EPA). 2013. Compensatory Mitigation Fact Sheet. 

38 Available at: http://water.epa.gov/lawsregs/guidance/wetlands/upload/

39 2003_05_30_wetlands_CMitigation.pdf.

40 United States Fish and Wildlife Service (USFWS). 2012a. Conservation Banking, Incentives for 

41 Stewardship. http://www.fws.gov/endangered/esa-library/pdf/conservation_banking.pdf. August.

42 ______. 2012b. Endangered and Threatened Wildlife and Plants; Revised Critical Habitat for the 

43 Riverside Fairy Shrimp (Streptocephalus woottoni); Proposed Rule. Federal Register Vol. 77, 

44 No. 233: 72069-72140. 4 December.
MCAS Miramar 7 References

Vernal Pool Mitigation Area Planning 7-4 April 2015

Draft EA 

1 . 2012c. Endangered and Threatened Wildlife and Plants; Revised Endangered Status, Revised 

2 Critical Habitat Designation, and Taxonomic Revision for Monardella linoides ssp. viminea; 

3 Final Rule. Federal Register Vol. 77, No. 44: 13394-13447. 6 March.

4 ______. 2010a. Coastal California Gnatcatcher (Polioptila californica californica) 5-year Review: 

5 Summary and Evaluation. U.S. Fish and Wildlife Service Carlsbad Fish and Wildlife Office, 

6 Carlsbad, California. September.

7 ______. 2010b. Endangered and Threatened Wildlife and Plants; Revised Critical Habitat for Navarretia 

8 fossalis (Spreading Navarretia); Final Rule. Federal Register Vol. 75 No.194 62192 – 62255. 

9 7 October.

10 . 2007. Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for the 

11 San Diego Fairy Shrimp (Branchinecta sandiegonensis); Final Rule. Federal Register 72(238): 

12 70648-70714. December 12.

13 . 2002. Species Account for the San Diego Fairy Shrimp (Branchinecta sandiegonensis). Species 

14 Code K049 101. http://ecos.fws.gov/docs/life_histories/K049.html. February 15.

15 . 2000. Endangered and Threatened Wildlife and Plants; Final Determination of Critical Habitat 

16 for the Coastal Gnatcatcher; Final Rule. Federal Register 65(206):63680-63743, October 24.

17 . 1998. Vernal Pools of Southern California Recovery Plan. U.S. Fish and Wildlife Service,

18 36 Portland, Oregon. 113+ pp.

19 . 1997. Endangered and Threatened Wildlife and Plants: Determination of Endangered Status for 

20 the San Diego Fairy Shrimp. Federal Register 62:4925-4935.

21 . 1993a. Endangered and Threatened Wildlife and Plants: Determination of Endangered Status 

22 for Three Vernal Pool Plants and the Riverside Fairy Shrimp. Federal Register

23 58(147):41384-41392.

24 . 1993b. Endangered and Threatened Wildlife and Plants; Determination of Threatened Status for 

25 the Coastal California Gnatcatcher. Federal Register 58:16742-16757.

26 . 1978. Endangered and Threatened Wildlife and Plants: Determination of Five Plants as 

27 Endangered Species. Federal Register 43(189):44810-44812.

28 United States Global Change Research Program. 2014. Global Climate Change Impacts in the United 

29 States. Jerry M. Melillo, Terese Richmond, and Gary W. Yohe (eds.). U.S. Government Printing 

30 Office.

31 Weston Solutions. 2007. San Diego County Municipal Copermittees 2005-2006 Urban Runoff 

32 Monitoring Report. January.
Appendix A

Agency Correspondence
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Appendix B 

Stakeholder Meeting
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MCAS Miramar Vernal Pool Mitigation Bank Project

1

Developing a Vernal Pool Mitigation Bank on MCAS Miramar 

Stakeholder Meeting 

Final Meeting Minutes

Date: 20 February 2013 

Time/Place: 0900-1200 Marine Corps Air Station (MCAS) Miramar, Environmental Conference Room. 

Attendees: See attached attendance list. 

1. Purpose of the Meeting

• Present an overview of mitigation banking(or some type of “advanced mitigation”) and the 

proposed project to MCAS Miramar leadership and stakeholders.

• Receive agency perspectives on the proposed project. 

• Collaborate with stakeholders to develop siting alternatives for the National Environmental 

Policy Act (NEPA) document that are mission-compatible and feasible. 

2. Agenda

0900-0915 Introductions, Welcome

0915-0945 Project Description - Dave Boyer (MCAS Miramar EMD)

0945-1000 Agency Perspective

1000-1015 NEPA and Exercise Introduction - Rachelle Hill (NAVFAC SW) Co-project Manager

1015-1045 Break-out SME review of additional constraints

1045-1130 Info Roll-up and Determination of Alternatives

EMD - Environmental Management Division

NAVFAC SW - Naval Facilities Engineering Command Southwest

SME – Subject Matter Expert

3. Stakeholder Presentation

Part 1 - Project Overview (original attached). 

• Question was raised as to what the financial benefits of advanced mitigation planning are.

o Mr. Boyer responded that advanced mitigation streamlines regulatory process and 

therefore time commitment of staff as well as project schedule. He also noted that 

advanced mitigation can reduce compensatory mitigation rations requested by agencies.

o Ryan Orndorff also noted that advanced mitigation can dramatically reduce the per acre 

cost for mitigation and provided an example of $10K - $15K/acre as part of advanced 

mitigation versus $40K - $50K/acre associated with project-specific mitigation. 

o Mr. Orndorff also noted that other Marine Corps installations have received Operations 

and Maintenance (O&M) funds for advanced mitigation projects. 

o Comment was also made that advanced mitigation may alleviate mitigation cost pressures 

on individual project proponents. 
MCAS Miramar Vernal Pool Mitigation Bank Project

2

o A final comment noted that without advanced mitigation, projects would have to 

individually fund an entire mitigation project to compensate for its impacts. For smaller 

projects, this has the potential for a project to exceed the cost threshold for it to become a 

Military Construction Project, thus requiring congressional approval.

• Mr. Boyer emphasized that there is not enough funding to complete an entire advanced mitigation 

project at one single time; time-phasing will be required. 

Part 2 – NEPA Alternatives and Development (original attached).

• Ms. Hill emphasized NEPA as a process law covering potentially all the phases of an advanced 

mitigation project. 

• Ms. Bartels reiterated the importance of sites having a connection to Traditional Navigable 

Waters for Clean Water Act (CWA) jurisdiction. See Item 4, Summary of Agency Perspective 

for more details. 

4. Summary of Agency Perspective

U.S. Army Corps of Engineers (USACE; Peggy Bartels - Regulatory Project Manager) - 

• There are no CWA/Endangered Species Act conservation/mitigation banks in southern 

California. 

• The project is beneficial to both the mission and the resources themselves and is on the right 

track. 

• The project really needs to identify and establish sites that will have a connection to Traditional 

Navigable Waters so that CWA jurisdiction can be established. 

• Colleen Eckenroad (MCB Camp Pendleton Environmental Security) asked whether vernal pool 

preservation would also provide credit. 

• The response from USACE was that preservation credit should be considered here but 

that the actual preservation would be small compared to new pool development. 

Environmental Protection Agency (Elizabeth Goldmann - Water Quality/CWA Permit Oversight; 

Interagency Review Team) - 

• There are tremendous advantages to going through this process now, including establishing a 

framework and expectations for mitigation in advance and expediting future agency approvals 

later.

5. Break-out SME Review and Alternatives Development Results

Description of Break-out SME Review

• MCAS Miramar EMD staff and the NEPA team identified preliminary screening criteria, 

preliminary list of no-go areas, and a list of known site development considerations for 

stakeholder review/concurrence. These resources were mapped and presented graphically to the 

stakeholders for their review during the break-out SME review. 

• Ms. Hill emphasized site-accessibility and future projects as information that may have been 

limited during the preliminary analysis, but also requested a review of missing data regarding 

infrastructure, mission operation constraints, or other concerns. 
MCAS Miramar Vernal Pool Mitigation Bank Project

3

• Stakeholder group was asked to further refine potential pool development areas based on their 

area of expertise. 

Screening criteria - The following screening criteria were given to the stakeholder group as a basis for 

alternatives development: 

• Maximum density of potential vernal pool creation;

• CWA jurisdiction; 

• Existing vernal pools that may be incorporated for preservation credit; 

• Aircraft accident potential zone overlay;

• Additional community planning purposes are served such as encroachment buffer or maximum 

use of sites where no other use could be feasibly supported; and,

• Long-term management potential to ensure avoidance of future land use conflicts.

Potential Suitable Mitigation Area Alternative Development Results - 

• Several areas were confirmed by stakeholders as non-suitable, including: 

o Flightline/Main Station;

o Existing Mitigation Areas;

o Training Areas;

o Future developments including the Veterans Affairs Cemetery and City of San Diego lease 

expansion around the landfill for monitoring wells;

o Leases, outgrants, easements, and rights-of-way; 

o private land inholdings (and adjacent area subject to restoration at the Harris Plant); and, 

o “G” parcel subject to special authorization to transfer to the Department of Interior (U.S. Fish 

and Wildlife Service National Wildlife Refuge system) in the south-central part of the station. 

• Six locations were identified as potential mitigation bank sites (Alpha, Bravo, Charlie, Delta, 

Echo, and Foxtrot). An overview map of the stakeholder-identified potential suitable mitigation

areas is included as Map 1, Vernal Pool Mitigation Bank Development Sites. Maps 2 through 4 

present the same information at a smaller scale. 

Potential NEPA Alternatives Identified - 

• Alternative 1 – All sites: Alpha, Bravo, Charlie, Delta, Echo, and Foxtrot. 

• Alternative 2 – To be determined. 

• Alternative 3 – To be determined. 

• No Action Alternative. 
MCAS Miramar Vernal Pool Mitigation Bank Project

4

6. Action Items

Action Organization Status

Develop Maps of Potential Bank 

Locations based on Stakeholder Meeting SAIC Complete 

Review/revise potential pool 

development areas within the identified 

pool development site alternatives 

MCAS Miramar EMD Complete

Provide project description and methods 

information from existing vernal pool 

developments at MCAS Miramar

MCAS Miramar EMD Complete 

Provide information, environmental 

documents, or other materials from other 

USMC mitigation bank projects

MCAS Miramar EMD Complete 

NEPA Alternatives follow-up Meeting NAVFAC SW, SAIC, 

MCAS Miramar EMD Thursday, 7 March 2013 

Attachments

• Sign-in Sheet. 

• Presentation Part 1: Project Overview. 

• Presentation Part 2: NEPA Alternative Development. 

• Potential Development Areas Suitable for Mitigation: Maps 1 to 4. 

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Appendix C

Record of Non-Applicability (RONA)
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MCAS Miramar Appendix C RONA

Vernal Pool Mitigation Area Planning C-1 $SULO 2015

Appendix C. United States Marine Corps

Record of Non-Applicability (RONA) for Clean Air Act Conformity and 

Air Quality Emissions Estimates

1 Introduction

2 This proposed action falls under the Record of Non-Applicability (RONA) category and is documented 

3 with this RONA.

4 The United States Environmental Protection Agency (EPA) published “Determining Conformity of 

5 General Federal Actions to State or Federal Implementation Plans; Final Rule” in the 30 November 1993 

6 Federal Register (40 Code of Federal Regulations [CFR] Parts 6, 51, and 93). In 2006, the EPA revised 

7 the general conformity rule to include de minimis emission levels for particulate matter with a diameter 

8 equal to or less than 2.5 microns (PM2.5) and its precursors. On 5 April 2010, EPA finalized more wide9 sweeping revisions to the general conformity rule (75 Federal Register [FR] 17253-17279). These 

10 revisions took effect on 6 July 2010. These publications provide guidance on how to document Clean Air 

11 Act Conformity requirements.

12 Federal regulations state that no department, agency, or instrumentality of the Federal Government shall 

13 engage in, support in any way or provide financial assistance for, license to permit, or approve any 

14 activity that does not conform to an applicable State Implementation Plan (SIP). It is the responsibility of

15 the Federal agency to determine whether a Federal action conforms to the applicable SIP before the action 

16 is taken (40 CFR Part 1 51.850[a]). 

17 Federal actions are exempt from conformity determinations if their emissions do not exceed designated 

18 de minimis levels for criteria pollutants (40 CFR 93.153c). The general conformity rule also exempts 

19 certain federal actions from the requirements of the rule, as these actions are assumed to conform to a SIP. 

20 Conformity de minimis levels (in tons per year) for the San Diego Air Basin, the region potentially 

21 affected by the proposed action, are listed in Table 1.

Table 1. Conformity De Minimis Levels for Criteria Pollutants in the San Diego Air Basin

Criteria Pollutant De Minimis Level (tons/year)

Carbon Monoxide (CO) 100

Volatile Organic Compounds (VOC) 100

Oxides of Nitrogen (NOx) 100

22 Proposed Action 

23 Activity: Develop and operate vernal pools as mitigation areas at Marine Corps Air Station Miramar 

24 (MCAS Miramar). Proposed action proponent is the Public Works Department at MCAS Miramar. 

25 Location: MCAS Miramar, California. Proposed activities would occur along De La Garza Road located 

26 in West Miramar. 

27 Proposed Action Name: Vernal Pool Conservation/Mitigation Bank Planning at MCAS Miramar. 

28 Proposed Action Summary: The Marine Corps proposes to create, restore, enhance, and operate (maintain 

29 and monitor) potentially up to 22 acres of vernal pools at various locations within MCAS Miramar. Creation 
MCAS Miramar Appendix C RONA

Vernal Pool Mitigation Area Planning C-2 April 2015

1 of new sites would require clearing of vegetation and grading to create new basins through soil 

2 re-contouring. Excavated material from new basin areas would typically be used on-site to create upland 

3 mounds. Any debris associated with site preparation and soil re-contouring would be removed and 

4 transported to a permitted, off-site disposal site. Site preparation and soil re-contouring associated with 

5 restoration/enhancement of existing basins would be done carefully with small-scale equipment or hand 

6 tools. The project sites would be accessed by existing roads when feasible and by transiting fence line 

7 security clear zones. Access roads may be required for sites that do not have existing access roads or 

8 suitable access. Other development activities would include placement of inoculum in pools (soil 

containing fairy shrimp cysts1 9 and plant seeds) and weed/exotic plant control and removal. 

10 Operational activities (maintenance and monitoring) would require the occasional use of light duty 

11 vehicles and equipment. 

12 Air Emissions Summary: Based on the air quality analysis for the proposed action, the emissions for the 

13 proposed action would be well below conformity de minimis levels. 

14 Affected Air Basin: San Diego Air Basin

15 Date RONA Prepared: November 22, 2013 

16 RONA Prepared by: Science Applications International Corporation (SAIC) 

17 Proposed Action Exemptions

18 The proposed action is exempt because the estimated total emissions are below de minimis levels set forth 

19 in the Clean Air Act General Conformity Regulation. 

20 Attainment Status and Emissions Evaluation and Conclusion

21 The General Conformity Rule requires conformity evaluations for proposed emissions that would occur 

22 within areas that are in nonattainment or maintenance of a national ambient air quality standard (NAAQS). 

23 The project site is within San Diego County and is under the jurisdiction of the San Diego County Air 

24 Pollution Control District. Therefore, the focus of this conformity applicability analysis is to compare 

25 project emissions to de minimis levels applicable to San Diego County. 

26 The San Diego Air Basin (SDAB) presently is classified as in nonattainment of the O3 NAAQS. Ozone is 

27 a secondary pollutant formed when ozone precursors, nitrogen oxides (NOx) and volatile organic 

28 compounds (VOCs), intermix in the atmosphere in the presence of sunlight. Therefore, the EPA general 

29 conformity regulations set de minimis levels for ozone precursors instead of ozone. The western portion 

30 of the SDAB (the portion of the county generally west of the interior desert region) also is in maintenance 

31 of the CO NAAQS. Based upon these designations, the applicable annual conformity de minimis thresholds 

32 for these areas are 100 tons of VOCs, CO, and NOx. 

33 Equipment usages associated with the potential development of vernal pools by the proposed action and 

34 their resulting emissions are not known at this time. However, the proposed action would minimize ground 

35 disturbances, which would minimize equipment usages needed for the development of vernal pools. This 

36 approach would produce annual air emissions that would be substantially less than their applicable 

 

1 Fairy shrimp cysts can accumulate in the soil after several years of reproduction. Cyst banks resemble the seed banks of animals and 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 Appendix C RONA

Vernal Pool Mitigation Area Planning C-3 April 2015

1 conformity de minimis threshold. Maintenance and monitoring activities associated with the proposed 

2 action would produce minor amounts of air emissions due to the occasional use of light duty vehicles and 

3 equipment. As a result, this activity would produce annual air emissions that would be substantially less 

4 than their applicable conformity de minimis threshold. Therefore, emissions from the proposed action 

5 would show conformity under the Clean Air Act, as amended. 

6 RONA Approval

7 I concur in the finding that air emissions associated with the proposed action are below de minimis levels 

8 and therefore do not require further conformity evaluation. 

______________________________________________________ Date: ____________________ 

9 

10 Name of Responsible Official 

11 Title of Responsible Official

12 MCAS Miramar
MCAS Miramar Appendix C RONA

Vernal Pool Mitigation Area Planning C-4 April 2015

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