DEPARTMENT OF VETERANS AFFAIRS

MEDICAL CENTER SAN DIEGO

DRAFT ENVIRONMENTAL ASSESSMENT

FOR THE

SEISMIC DEFICIENCY - SCI / CLC PROJECT

Project 664-401

June 19, 2013 

Prepared for: 

US Department of Veteran Affairs

Office of Construction and Facilities Management

Under Contract to: 

gkkworks 

2355 Main Street, Suite 220

Irvine, CA 92614

Submitted by: 

Geomorph Information Systems, LLC

P.O. Box 122886

San Diego, CA 92112

VA Project Number: 664-401

GeomorphIS Project Number: 9205-001
This page intentionally left blank
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego ES-1 June 19, 2013

EXECUTIVE SUMMARY

The Department of Veterans Affairs (VA) is proposing to construct a new Spinal Cord Injury (SCI) and 

Community Living Center (CLC) building, construct a new parking structure, and upgrade the existing SCI 

building at the VA Medical Center (VAMC) San Diego, California. In accordance with the National 

Environmental Policy Act (NEPA), the VA prepared this Environmental Assessment (EA) to analyze the 

potential environmental effects of the proposed action.

The existing SCI building at VAMC San Diego is seismically deficient and does not meet current VA space 

planning criteria, privacy standards, and infection-control best management practices. To correct these 

deficiencies, the VA considered the following alternatives: (1) construct new SCI building, (2) renovate 

existing SCI building, (3) contract out SCI services to outside providers, and (4) take no action. Construct 

new SCI building was selected as the preferred alternative and will be analyzed in this EA as the 

proposed action.

The proposed action also includes the following related improvements to the Medical Center. The 

existing CLC unit at the main hospital building would be relocated to the new SCI building. A new parking 

structure would be built to mitigate the loss of parking from the footprint of the new SCI/CLC building 

and to improve the current parking shortage at the Medical Center. The existing SCI building would be 

upgraded for reuse for administrative space and outpatient services.

VA prepared this EA in accordance with NEPA to analyze the potential environmental effects of the 

proposed action. The analysis performed in this EA concludes that the proposed action would not have 

significant adverse impact, either individually or cumulatively, to the human environment, provided 

mitigation measures consisting of best management practices and regulatory compliance measures 

described in this EA are implemented. Therefore, this EA concludes that a Finding of No Significant 

Impact is appropriate and that an Environmental Impact Statement is not required.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego i June 19, 2013

Contents

EXECUTIVE SUMMARY............................................................................................................................. 1

1 INTRODUCTION .......................................................................................................................... 1

1.1 Project Background............................................................................................ 1

1.2 Purpose and Need ............................................................................................. 1

2 ALTERNATIVES ............................................................................................................................ 6

2.1 Development of Alternatives ............................................................................. 6

2.2 Alternatives Retained For Detailed Analysis ....................................................... 6

2.2.1 Proposed Action Alternative (Preferred Alternative) .......................................... 7

2.2.2 No Action Alternative......................................................................................... 7

3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES OF THE ALTERNATIVES...... 12

3.1 Local Environmental Setting............................................................................. 12

3.2 Resources Analyzed ......................................................................................... 12

3.3 Air Quality........................................................................................................ 16

3.3.1 Existing Condition ............................................................................................ 16

3.3.2 Proposed Action Alternative ............................................................................ 19

3.3.3 No Action Alternative....................................................................................... 21

3.4 Hydrology and Water Quality........................................................................... 21

3.4.1 Existing Condition ............................................................................................ 22

3.4.2 Proposed Action Alternative ............................................................................ 23

3.4.3 No Action Alternative....................................................................................... 23

3.5 Noise ............................................................................................................... 23

3.5.1 Existing Condition ............................................................................................ 24

3.5.2 Proposed Action Alternative ............................................................................ 25

3.5.3 No Action Alternative....................................................................................... 25

3.6 Solid and Hazardous Wastes ............................................................................ 25

3.6.1 Existing Condition ............................................................................................ 25

3.6.2 Proposed Action Alternative ............................................................................ 26

3.6.3 No Action Alternative....................................................................................... 26

3.7 Transportation and Parking.............................................................................. 26

3.7.1 Existing Condition ............................................................................................ 26

3.7.2 Proposed Action Alternative ............................................................................ 27

3.7.3 No Action Alternative....................................................................................... 27

3.8 US Environmental Regulations......................................................................... 27

3.9 Cumulative Impact........................................................................................... 29

4 PUBLIC INVOLVEMENT.............................................................................................................. 31

5 MITIGATION.............................................................................................................................. 31

6 CONCLUSIONS .......................................................................................................................... 34

7 LIST OF PREPARERS ................................................................................................................... 35

8 REFERENCES CITED ................................................................................................................... 36

9 LIST OF ACRONYMS AND ABBREVIATIONS................................................................................. 41

Appendix A Native American Tribes Correspondence .............................................................................. 1

Appendix B Agency Correspondence ....................................................................................................... 1

Appendix C List of Environmental Permits / Modifications Required........................................................ 1
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego ii June 19, 2013

List of Figures

Figure 1. VAMC San Diego project location and vicinity ..................................................................... 3

Figure 2. VAMC San Diego location (yellow box) relative to UCSD campus (UCSD 2004)..................... 4

Figure 3. VAMC San Diego campus map (VA 2013)............................................................................. 4

Figure 4. VAMC San Diego, proposed SCI / CLC project site................................................................ 5

Figure 5. Layout of proposed new SCI/CLC and parking structure on the Medical Center campus...... 8

Figure 6. Contextual view of new SCI/CLC building and parking structure from the south .................. 8

Figure 7. Contextual view of new SCI/CLC building from the southeast.............................................. 9

Figure 8. Street-level contextual view of new SCI/CLC building from the southeast............................ 9

Figure 9. Aerial oblique view of new, fully built-out parking structure from northwest ....................10

Figure 10. Plan of fully built-out parking structure ...........................................................................10

Figure 11. Proposed site layout and traffic patterns.........................................................................11

List of Tables

Table 1. Environmental resources assessed in the EA.......................................................................13

Table 2. De minimis thresholds........................................................................................................17

Table 3. Proposed Action construction emissions ............................................................................20

Table 4. Proposed Action Alternative operational emissions............................................................20

Table 5 Project compliance with federal legal authorities................................................................28
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 1 June 19, 2013

1 INTRODUCTION

The Department of Veterans Affairs (VA) is proposing to construct a new Spinal Cord Injury (SCI) and 

Community Living Center (CLC) building, construct a new parking structure, and upgrade the existing SCI 

building at the VA Medical Center (VAMC) San Diego, California. In accordance with the National 

Environmental Policy Act (NEPA), the VA prepared this Environmental Assessment (EA) to analyze the 

potential environmental effects of the proposed action. 

1.1 Project Background

VAMC San Diego is located at 3350 La Jolla Village Drive, in the La Jolla area of San Diego (figure 1) (VA 

2010d). The Medical Center is situated on approximately 26 acres of federally owned property adjacent 

to the 1,152-acre University of California, San Diego (UCSD) campus. The Medical Center is affiliated 

with UCSD and shares infrastructure and community services such as roads and parking facilities. Figure 

2 shows the VA Medical Center in relation to UCSD facilities, and figure 3 shows the existing layout of 

the VA Medical Center campus. Figure 4 is an aerial close-up of the VAMC property with the project 

footprint.

This Environmental Assessment (EA) has been prepared to ensure VA compliance with the regulations 

set forth by the Council on Environmental Quality (CEQ) implementing the provisions of the National 

Environmental Policy Act (NEPA), Title 40 Code of Federal Regulations (CFR) Parts 1500-1508; and VA 

Regulations, Environmental Effects of VA Actions, Title 38 CFR, Part 26 (51 FR 37182, Oct. 20, 1986) (VA 

1998). This EA has also been prepared in accordance with the VA NEPA Interim Guidance for Projects 

(VA 2010c).

An Environmental Assessment looks at the effects of a proposed action and reasonable alternatives to 

achieve the agency’s objectives (VA 2010c). The EA is intended to be a concise document that 1) briefly 

provides sufficient evidence and analysis for determining the significance of the action and whether to 

prepare and Environmental Impact Statement (EIS); 2) aides the VA’s compliance with NEPA when no EIS 

is necessary; and 3) facilitates preparation of an EIS when one is necessary. If the analysis finds there are 

no significant impacts, a Finding of No Significant Impact (FONSI) can be issued concluding the NEPA 

process. 

1.2 Purpose and Need

The existing SCI building at VAMC San Diego is seismically deficient and not in compliance with current 

VA space planning criteria, privacy standards, and infection-control best management practices. A 

seismic study conducted by Degenkolb Engineers, Inc., recommended that the building be strengthened. 

The building is classified as Extremely High Risk (EHR) for seismic vulnerability and has been assigned a 

VA deficiency category of III, meaning that the building may be damaged in an earthquake. VAMC San 

Diego has a need to correct this seismic deficiency. In addition, the existing SCI building has thirteen 

shared inpatient rooms (and only four private rooms) that do not meet current patient privacy 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 2 June 19, 2013

standards; as such, VAMC San Diego has a need to provide all-private rooms to improve overall patient 

access and to allow for greater infection control. The purpose of the proposed action is to fulfill these 

identified needs. 

The proposed action also includes the following related improvements to the Medical Center. The new 

SCI building would include space for a CLC unit; VAMC San Diego has a need to relocate the existing CLC 

unit from the main hospital building to the new SCI building to replace the existing 2-resident and 4-

resident per bedroom nursing home configuration with new single occupancy bed/bath room models 

consistent with modern nursing home privacy standards. A new parking structure is needed to mitigate 

the loss of parking from the footprint of the new SCI/CLC building and to improve the current parking 

shortage at the Medical Center. The existing SCI building is needed to be structurally and nonstructurally upgraded for reuse for administrative space and outpatient services.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 3 June 19, 2013

Figure 1. VAMC San Diego project location and vicinity
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 4 June 19, 2013

Figure 2. VAMC San Diego location (yellow box) relative to UCSD campus (UCSD 2004)

Figure 3. VAMC San Diego campus map (VA 2013) 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 5 June 19, 2013

Figure 4. VAMC San Diego, proposed SCI / CLC project site
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 6 June 19, 2013

2 ALTERNATIVES

2.1 Development of Alternatives

The VA considered the following alternatives for correcting the existing SCI building deficiencies: (1) 

construct new SCI building, (2) renovate existing SCI building, (3) contract out SCI services to outside 

providers, and (4) take no action. 

Alternative 1 – Construct New SCI Building (Preferred Alternative): In this alternative, a new SCI 

building would be constructed. Along with being built to modern seismic standards, the new SCI 

building would feature all private inpatient rooms to meet current patient privacy standards and to 

allow for greater infection control. The new SCI building would include space for a CLC facility with 

single bed/bath rooms consistent with modern nursing home privacy standards. The existing space 

vacated by the CLC unit in the main hospital building would allow decompression of the main 

hospital building for expanded clinical space. A new parking structure would be built to mitigate the

loss of parking from the footprint of the new SCI/CLC building and to improve the current parking 

shortage at the VAMC. The existing SCI building would be structurally and non-structurally upgraded 

for reuse for administrative space and outpatient services. These facilities would allow VA to more 

adequately serve Veteran patients with higher quality of care. This option was determined to be the 

most cost effective, making it the preferred alternative.

Alternative 2 – Renovation: This alternative would renovate the existing SCI facility to withstand 

seismic impacts, as well as improve the building’s current layout and design to better improve 

patient quality of care. However, this alternative requires temporary space via modular lease 

buildings and associated activation/relocation into the temporary structure. Impact costs alone 

make this alternative impractical. In addition, the resultant space challenges of the renovation will 

preclude the benefit of modern space plans. This option is more costly than other alternatives of 

new construction and maintaining status quo.

Alternative 3 – Contract Out: This alternative would contract out all services that pertain to this 

project to local private providers. Based on a cost-effectiveness analysis, this is the most costly 

option due to the complexity of the SCI and extended care patients’ needs. Therefore this option 

was considered the least preferred.

Alternative 4 – No Action: In this alternative, the facility would remain in its current condition, and 

only non-recurring maintenance costs would be incurred. The facility would continue to have 

significant seismic deficiencies, cramped floors, and limited bed capacity. Moreover, the quality of 

patient care will remain low as patients will be lodged in shared rooms not conducive for patient 

privacy and infection control.

2.2 Alternatives Retained For Detailed Analysis

Alternative 1, Construct New SCI Building, was selected as the preferred alternative and will be analyzed 

in this EA as the proposed action. Alternatives 2 and 3 were considered but not carried forward for 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 7 June 19, 2013

reasons discussed above. This EA also evaluates Alternative 4, the No Action Alternative, under which 

the proposed action would not be implemented.

2.2.1 Proposed Action Alternative (Preferred Alternative)

The proposed action involves: (1) the construction of a new SCI/CLC building adjacent to the existing 

main hospital building and existing SCI building, (2) the construction of a new parking structure on the 

site of an existing parking area, and (3) the upgrade of the existing SCI building for reuse for 

administrative space and outpatient services. Utilities, landscape, parking, and internal traffic routes 

would be modified to accommodate the new buildings. Figure 5 shows the layout of the proposed new 

buildings relative to the existing Medical Center buildings. Figures 6, 7, and 8 provide simulated views of 

the new SCI/CLC building and associated landscaping from various perspectives. Figure 9 gives a 

simulated view of the new parking structure and figure 10 shows the proposed construction phases. 

Figure 11 shows a plan view of the proposed new building configuration and traffic pattern. The project 

will be designed to comply with the VA Sustainable Design and Energy Reduction Manual and to achieve 

a Leadership in Energy and Environmental Design (LEED) Silver certification.

The proposed new SCI/CLC building would add approximately 175,000 gross square-feet to the existing 

Medical Center facility. There are currently a total of 30 inpatient beds in 13 shared rooms and 4 private 

rooms at the existing SCI building; the new SCI building will have up to 50 inpatient beds in all private 

rooms. The existing CLC unit at the main hospital building currently houses 43 beds in eight 4-person 

rooms, five 2-person rooms, and one single room; the new SCI building will have space for the same 43 

CLC beds but in all private rooms. In total, there would be a net increase of no more than 20 patient 

beds at the Medical Center.

2.2.2 No Action Alternative

Under the No Action Alternative, the VA would not implement the proposed construction project at the 

Medical Center in San Diego. The new SCI/CLC building and parking garage would not be constructed 

and there would be no increase in space for patients and residents, and no addition to parking spaces. 

The No Action Alternative would not satisfy the purpose and need for the Proposed Action. It is included 

here to serve as a base-line condition to which the Proposed Action can be contrasted. 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 8 June 19, 2013

Figure 5. Layout of proposed new SCI/CLC and parking structure on the Medical Center campus

Figure 6. Contextual view of new SCI/CLC building and parking structure from the south
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 9 June 19, 2013

Figure 7. Contextual view of new SCI/CLC building from the southeast

Figure 8. Street-level contextual view of new SCI/CLC building from the southeast
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 10 June 19, 2013

Figure 9. Aerial oblique view of new, fully built-out parking structure from northwest

Figure 10. Plan of fully built-out parking structure
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 11 June 19, 2013

Figure 11. Proposed site layout and traffic patterns
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 12 June 19, 2013

3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

CONSEQUENCES OF THE ALTERNATIVES

This section describes the existing baseline conditions of the environment affected by the project 

alternatives and the likely consequences the project alternatives would have on this environment. 

3.1 Local Environmental Setting

The VA Medical Center is located off of La Jolla Village Drive near the interchange with Interstate 5 in 

San Diego. The Project area is in the unsectioned Pueblo Lands of San Diego in Township 15 South, 

Range 3 West, San Bernardino Base and Meridian, at an elevation of about 350 feet above mean sea 

level. The VAMC San Diego property consists of three adjacent parcels owned by the federal 

government bounded by Interstate 5 to the east, La Jolla Village Drive to the south, Villa La Jolla Drive to 

the west, and Gilman Drive to the north. These three parcels comprise 26 acres and contain the Medical 

Center buildings; landscaped areas with trees, shrubs, and grass; and paved parking areas (figure 4). The 

University of California, San Diego campus is adjacent to Medical Center to the west, north, and east. 

Commercial properties are located south of La Jolla Village Drive. The Medical Center is located on a 

coastal terrace between the Pacific Ocean to the west and Soledad Canyon to the northeast and Rose 

Canyon to the southeast. Two parcels leased from UCSD are used for parking by the Medical Center but 

are not part of the project area (ECORP 2009). 

The adjacent University of California, San Diego campus shares many environmental characteristics with

the VA Medical Center and has a related land use history. The University completed a Final 

Environmental Impact Report (FEIR) for their Long Range Development Plan in 2004 (PBS&J 2004b) and, 

more recently, completed an FEIR for a new medical facility located about a quarter-mile northeast of 

the VAMC (Helix 2010). The technical reports associated with these projects provide environmental 

baseline data for the area encompassing or near to the VAMC, and were reviewed to support the initial 

screening of likely environmental effects of the proposed VAMC SCI/CLC project. 

3.2 Resources Analyzed

An initial screening process was used to determine which environmental resources were likely to be 

significantly adversely impacted by the proposed action. Because the project is specifically designed to 

produce certain environmental benefits (e.g., aesthetic architecture, reduction of seismic hazard) and to 

avoid or mitigate others (e.g., reduce energy and water use, increase material recycling), some 

environmental resources were dismissed from further discussion. In other cases, environmental 

resources were dismissed from further analysis if they were unlikely to be significantly impacted by the 

proposed project. The remaining resources were analyzed further to assess the likely impacts of the 

proposed action and to determine what actions should be taken to mitigate adverse impacts. 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 13 June 19, 2013

Impact Intensity is a measure of the severity of an impact, and is used here to determine the relative 

significance of the impact for the purpose of screening. The intensity of an impact may be: 

• Negligible, when the impact is localized and not measurable or at the lowest level of 

detection; 

• Minor, when the impact is localized and slight but detectable; 

• Moderate, when the impact is readily apparent and appreciable; or 

• Major, when the impact is severe and highly noticeable.

Table 1 indicates which resources were dismissed or retained for analysis, and the rationale for doing so.

Table 1. Environmental resources assessed in the EA

Resource Dismissed? Rationale

Aesthetics Yes The proposed SCI/CLC building and parking garage were designed to enhance the 

(interior and exterior) aesthetic qualities of the medical facilities and improve the healing 

environment (gkkworks 2010b). The landscaping, open space, and ground amenities 

design will contribute to this objective. The “split-level” grading and partial subterranean 

construction will reduce the visibility of the parking garage relative to the existing 

structures. Because the new construction is consistent with the current appearance of 

the Medical Center as a built-up facility, the effect on aesthetic values of the area is 

considered negligible.

Air Quality No Construction at the project site will create dust, smoke, and engine emissions. 

Appropriate VA and other regulatory guidance will be followed during construction. The 

addition of building space and resident capacity at the Medical Center will increase 

electrical demand over current base-line conditions. As part of the VA Sustainable Design 

and Energy Reduction requirements and LEED criteria, the new buildings are specifically 

designed to allow for long-term reductions in energy use and air emissions compared to 

conventional building layouts (gkkworks 2010b). Construction of the new facilities will 

cause a minor, temporary negative impact to local air quality.

Community 

Services

Yes As part of the LEED sustainable sites criteria, this project will enhance community 

connectivity through architectural and landscape design, encourage alternative 

transportation (e.g., bicycle and electric vehicle facilities), improve public transportation

access, and improve walk-ability of the pedestrian paths. These features will have a longterm beneficial effect on Medical Center campus (gkkworks 2010b). Off-site parking and 

shuttle bus service will be provided during construction of the new buildings to mitigate 

for temporary loss of on-site parking, resulting in a negligible impact to local community 

services.

Cultural 

Resources

Yes A Phase I historic preservation study was conducted in accordance with the National 

Historic Preservation Act (NHPA) requirements and found no eligible properties at the 

Medical Center or other cultural resources of concern. The State Historic Preservation 

Officer (SHPO) was consulted and agreed with the determination. The proposed action 

will therefore have a negligible impact on local cultural resources (ECORP 2009; see 

Appendixes A and B).

Economic 

Activity 

Yes The project construction phase will have a short-term beneficial impact by providing 

additional jobs and purchase of goods in the area. The addition of medical staff 

associated with the increase in SCI/CLC residents will create a long-term increase in the 

number of jobs at the facility. Potential negative impacts to local economic activity are 

considered negligible. 

Environmental Yes Medical Center residents and staff comprise a broad range of economic and ethnic
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 14 June 19, 2013

Table 1. Environmental resources assessed in the EA

Resource Dismissed? Rationale

Justice groups. The Medical Center is bordered to the north, east, and west by the University of 

California, San Diego, which is designated as having a low median household income (< 

$27K) due to the student populations (ESRI 2010). Neighborhoods south of the Medical 

Center have median incomes between $40K and $80K, while areas further to the west 

include median household incomes between $80K and $375K. Given the localized nature 

of the proposed project, low-income or minority populations will not be 

disproportionally impacted by this project, and therefore a negligible impact on 

environmental justice. 

Floodplains, 

Wetlands, 

Coastal Zone, 

Etc.

Yes The Medical Center is outside of the FEMA-designated 100-year and 500-year 

floodplains, and is not regulated under Executive Order 11988 - Floodplain Management

(PBS&J 2004a, 2004b). The project site is outside of a Coastal Zone Management area, 

although runoff from the Medical Center does enter streams that are partially within the 

nearby Coastal Management Zone. No wetlands occur on the project site (PBS&J 2004a). 

The project will not negatively affect floodplains or related resources. Because the new 

construction does not significantly alter the aesthetics of the area, it does not negatively 

impact the nearby Coastal Management Zone. Refer to the Aesthetics, and Hydrology

and Water Quality sections for additional discussion.

Geology and 

Soils

Yes Investigations by Ninyo and Moore (2003, 2005) reported that the project site is situated 

on fill material overlaying Eocene-age Scripps Formation sediments (marine deposits). 

There are no active faults or landslides underlying or adjacent to the site; however, the 

active Rose Canyon fault zone is located about 2 miles away. The potential for strong 

ground motion is significant. Groundwater was not encountered during the 2005 

borings. Since the proposed new SCI/CLC building and parking garage are designed to 

meet VA seismic design requirements, the project will help mitigate local geologic 

hazards and enhance the long-term safety of residents and staff at the Medical Center. 

Potential negative impacts to local geology and soils resources are negligible.

Hydrology And 

Water Quality

No During construction and demolition phases, runoff from the project site could contribute 

silt and pollutants to the storm drain system. This temporary, short-term impact will be 

prevented by application of construction Best Management Practices (BMPs) and careful 

monitoring of the construction contractors. The proposed project will incur long-term 

benefits to water quality through improved stormwater management and stormwater 

design, water efficient landscaping, and water use (gkkworks 2010b). The overall 

potential negative effect of this action to water resources is considered minor and 

mitigable.

Land Use yes The Medical Center is bordered on the north and west by the UCSD campus, on the east 

by highway, and on the south by commercial and residential property. The VAMC 

campus is part of former Camp Matthews (US Marine Corps) (Parsons 2007, USACE 

1999) and, although there is not a specific risk of encountering unexploded ordnance, 

appropriate caution needs to be exercised during excavation. This proposed construction 

of a new SCI/CLC building and parking garage will be consistent with current institutional 

land use. The new buildings and ground improvements will have a long-term beneficial 

impact on utilities, traffic circulation, and parking at the facility (gkkworks 2010b). The 

new construction will have a negligible impact on local land use.

Noise No This project will cause a temporary, short-term increase in noise during the 

construction/demolition phases that may have an adverse impact on Medical Center

residents and workers, and neighboring communities. As this is a medical facility, 

additional noise control measures may be required during construction. The new 

buildings will incorporate noise reduction features that will have a long-term benefit to 

occupants (gkkworks 2010b). The project will have temporary, minor impact on this 

resource. 

Potential For Yes There are no known or anticipated issues likely to generate substantial issues among 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 15 June 19, 2013

Table 1. Environmental resources assessed in the EA

Resource Dismissed? Rationale

Generating 

Substantial 

Controversy

Medical Center stakeholders, regulatory agencies, or the general public. The likely 

negative impact of the project on these resources is negligible.

Solid/Hazardous 

Waste

No During demolition and construction phase, various hazardous wastes and other debris 

will be generated. The potential short-term, temporary adverse impact will be minor and 

will be avoided and mitigated through close adherence to federal, state, and local 

regulations, and incorporated into construction contracts. VA sustainable design and 

LEED design features are incorporated in the new building construction and operation, 

increasing the amount of recycled and bio-based content, and increasing the salvage and 

recycling of building materials and demolition debris (gkkworks 2010b). The project will 

therefore have a beneficial effect on long-term solid/hazardous waste management at 

the Medical Center.

Transportation 

And Parking

No During demolition and construction there will be a temporary, short-term alteration in 

facility access roads and reduction in parking (AS&G 2009). These minor adverse impacts 

will be mitigated by implementation of a traffic management plan that will include offsite parking and shuttle services during construction. The completed project will create 

improved traffic and parking conditions creating a long-term benefit in this category.

Utilities Yes The proposed new SCI/CLC building will be constructed to VA sustainable design and 

LEED design criteria that require increased efficiency in heat generation, air conditioning, 

lighting, and water systems over existing facilities. Though there will be a net increase in 

resident population, the more efficient utilities will reduce energy and water

consumption, and result in a long-term benefit to the Medical Center. The change to 

native landscaping, rain harvesting, and high-efficiency irrigation systems will save 

water. Existing drainage patterns will not be significantly affected. An analysis of water 

supply and wastewater facilities found that the current utilities were capable of meeting 

future demands resulting from the new facilities, although some utility lines would need 

to be rerouted (gkkworks 2010b). The potential negative impact of this project on 

utilities is considered negligible. See the Hydrology and Water Quality section concerning 

stormwater utilities.

Vegetation and 

Wildlife

Yes The Medical Center is a fully developed facility where native habitats have been replaced 

by urban landscaping. Habitat maps of UCSD campus show no sensitive wildlife habitat 

adjacent to the VAMC (Helix 2004). The US Fish and Wildlife Service (USFWS) does not 

require endangered species assessment for this built-up facility as there will be no effect 

on listed species. During the demolition/ construction phases, there will be a temporary 

removal of trees from the SCI/CLC and parking garage sites. However, the project will 

mitigate the loss of individual trees by planting new mature trees and by the 

establishment of healing gardens that will increase floral diversity and encourage bird

use of the area. The potential negative impact to vegetation and wildlife resources is 

considered negligible.

US 

Environmental 

Regulations

No The VA will be in compliance with all applicable environmental regulations regarding this 

project from design, through construction, and operational phases. Contract provisions 

will call for regulatory compliance during construction/demolition. The VAMC will use its 

Green Environmental Management System (GEMS) program to ensure regulatory 

compliance during operation.

Cumulative 

Effects

No Expansion of the proposed parking garage (by 400 spaces) beyond the currently planned 

1,200 spaces may be implemented as a future project. In addition, the VA has considered 

installing a large-scale solar photovoltaic system on the existing and proposed Medical 

Center buildings (Potomac-Hudson 2010). These possible future projects, in combination 

with the current proposed action may have a minor cumulative effect on the local area, 

primarily from short-term negative impacts associated with construction activities. 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 16 June 19, 2013

3.3 Air Quality

Air quality in a given location is defined by pollutant concentrations in the atmosphere and is generally 

expressed in units of parts per million (ppm) or micrograms per cubic meter (g/m3

). One aspect of 

significance is a pollutant’s concentration in comparison to a national and/or state ambient air quality 

standard. These standards represent the maximum allowable atmospheric concentrations that may 

occur and still protect public health and welfare with a reasonable margin of safety. The national 

standards, established by the US Environmental Protection Agency (USEPA), are termed the National 

Ambient Air Quality Standards (NAAQS). The NAAQS represent maximum acceptable concentrations 

that generally may not be exceeded more than once per year, except the annual standards, which may 

never be exceeded. State standards, established by the California Air Resources Board (CARB), are 

termed the California Ambient Air Quality Standards (CAAQS). 

The main pollutants of concern considered in this air quality analysis include volatile organic compounds 

(VOCs), ozone (O3), carbon monoxide (CO), nitrogen oxides (NOx), particulate matter less than or equal 

to 10 microns in diameter (PM10), and particulate matter less than or equal to 2.5 microns in diameter 

(PM2.5). Although VOCs or NOx (other than nitrogen dioxide) have no established ambient standards, 

they are important as precursors to O3 formation. The region of influence (ROI) for this air quality 

analysis is the entire San Diego Air Basin (SDAB), which encompasses San Diego County.

3.3.1 Existing Condition

The following discussions provide information on the regulatory conditions that are applicable to the 

Proposed Action Alternative. 

Ambient Air Quality

The USEPA designates all areas of the U.S. in terms of having air quality better (attainment) or worse 

than (nonattainment) the NAAQS. An area generally is in nonattainment for a pollutant if its NAAQS has 

been exceeded more than once per year. Former nonattainment areas that have attained the NAAQS 

are designated as maintenance areas. Presently, the San Diego Air Basin is in attainment of the NAAQS 

for all pollutants except O3. Additionally, the western portion of the SDAB (the portion of the County 

generally west of the interior desert region) was historically in nonattainment of the NAAQS for CO. Due 

to a reduction in emissions caused by national emission standards for new vehicles and a state vehicle 

emissions testing program, the region has attained the CO standards since 1991. As a result, the region 

was re-designated to attainment of the CO NAAQS by the USEPA in June 1998, and it is now considered 

a maintenance area for CO.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 17 June 19, 2013

Federal Requirements

The Federal Clean Air Act (CAA) of 1969 and its subsequent amendments establish air quality regulations

and the NAAQS and delegate the enforcement of these standards to the states. The CAA Amendments 

of 1990 established new federal nonattainment classifications, new emission control requirements, and 

new compliance dates for nonattainment areas. The requirements and compliance dates are based on 

the severity of the nonattainment classification. 

The General Conformity Rule (40 CFR 51.850-860 and 40 CFR 93.150-160) requires any federal agency 

responsible for an action in a nonattainment or maintenance area to determine that the action 

conforms to the applicable the California State Implementation Plan (SIP). Under existing federal 

guidelines, the action proponent must establish that the Proposed Action Alternative will not (1) cause 

or contribute to any new air quality standard violation, (2) increase the frequency or severity of any 

existing standard violation, or (3) delay the timely attainment of any standard, interim emission 

reduction, or other milestone (USEPA 2010). 

The emission thresholds that trigger requirements for a conformity analysis are called de minimis levels.

De minimis levels (in tons per year) vary from pollutant to pollutant and are also subject to the severity 

of the nonattainment status. Actions would conform to a SIP if their annual direct and indirect emissions 

remain less than the applicable de minimis thresholds. The rule allows for approximately 30 exemptions 

that are assumed to conform to an applicable SIP. Emissions of attainment pollutants are exempt from 

conformity analyses. The applicable de minimis levels for the project area are listed in Table 2. 

Table 2. De minimis thresholds

Pollutant Nonattainment 

Classification

De minimis Threshold, 

tons/year

Oxides of Nitrogen (NOx) (O3 precursor) Moderate (O3) 100

Volatile Organic Compounds (VOCs) (O3 precursor) Moderate (O3) 100

Carbon Monoxide (CO) Maintenance 100

Compliance is presumed if the net increase in direct and indirect emissions from a federal action would 

be less than the relevant de minimis level. However, if the increase in emissions for a nonattainment 

pollutant exceeds de minimis levels, a formal conformity determination process must be implemented.

If emissions exceed their respective de minimis levels, further analysis of the emissions and their 

consequences would be performed to assess whether there is a likelihood of a significant impact to air 

quality.

State Requirements

The CARB enforces air pollution regulations and sets guidelines to attain and maintain the NAAQS and 

CAAQS within the state of California. These guidelines are found in the California State Implementation 

Plan. 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 18 June 19, 2013

The California CAA of 1988, as amended in 1992, outlines a program to attain the CAAQS for O3, nitrous 

oxide (NO2), sulfur dioxide (SO2), particulate matter, and CO by the earliest practical date. Since the 

CAAQS are more stringent than the NAAQS, emissions reductions beyond what would be required to 

show attainment for the NAAQS would be needed to show compliance with the CAAQS. CARB delegates 

the authority to regulate stationary source emissions to local air quality management districts. The CARB 

requires these agencies to develop their own strategies for achieving compliance with the NAAQS and 

CAAQS, but maintains regulatory authority over these strategies, as well as all mobile source emissions 

throughout the state. The San Diego Air Pollution Control District (SDAPCD) is the local agency 

responsible for enforcement of air quality regulations in the project region.

Local Regulations

The SDAPCD is responsible for regulating stationary sources of air emissions in the SDAB. The SDAPCD

Rules and Regulations establish emission limitations and control requirements for stationary sources, 

based on their source type and magnitude. The SDAPCD and the San Diego Association of Governments 

are responsible for developing and implementing the clean air plan for attainment and maintenance of 

the ambient air quality standards in the SDAB, which is the SDAB’s input to the SIP. In addition, SDAPCD

Conformity Rule 1501 provides general conformity guidance to ensure that federal actions are 

consistent with the efforts of the SDAPCD to achieve its NAAQS attainment goals.

Greenhouse Gas Emissions

Greenhouse gases (GHGs) are gases that trap heat in the atmosphere. These emissions occur from 

natural processes and human activities. The accumulation of GHGs in the atmosphere regulates the 

earth’s temperature. Scientific evidence indicates a trend of increasing global temperature over the past

century due to an increase in GHG emissions from human activities. Global climate change is predicted 

to produce negative economic and social consequences across the globe. 

Recent observed changes due to global climate change include shrinking glaciers, thawing permafrost, a 

lengthened growing season, and shifts in plant and animal ranges (Intergovernmental Panel on Climate 

Change 2007). Predictions of long-term environmental impacts due to global climate change include sea 

level rise, changing weather patterns with increases in the severity of storms and droughts, changes to 

local and regional ecosystems including the potential loss of species, and a significant reduction in 

winter snow pack. In California, predictions of these effects include exacerbation of air quality problems, 

a reduction in municipal water supply from the Sierra snowpack, a rise in sea level that would displace 

coastal businesses and residences, damage to marine and terrestrial ecosystems, and an increase in the 

incidence of infectious diseases, asthma, and other human health problems (California Environmental 

Protection Agency 2006). 

The most common GHGs emitted from natural processes and human activities include carbon dioxide 

(CO2), methane (CH4), and nitrous oxide (N2O). Examples of GHGs created and emitted primarily through 

human activities include fluorinated gases (hydro fluorocarbons and per fluorocarbons) and sulfur 

hexafluoride. Each GHG is assigned a global warming potential (GWP). The GWP is the ability of a gas or 

aerosol to trap heat in the atmosphere. The GWP rating system is standardized to CO2, which has a value 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 19 June 19, 2013

of one. For example, CH4 has a GWP of 21, which means that it has a global warming effect 21 times 

greater than CO2 on an equal-mass basis. Total GHG emissions from a source are often reported as a CO2

equivalent (CO2e). The CO2e is calculated by multiplying the emission of each GHG by its GWP and 

adding the results together to produce a single, combined emission rate representing all GHGs. 

Federal agencies are, on a national scale, addressing emissions of GHGs by reductions mandated in 

federal laws and Executive Orders, most recently, Executive Order 13423. Several states have 

promulgated laws as a means to reduce statewide levels of GHG emissions. In particular, the California 

Global Warming Solutions Act of 2006 directs the State of California to reduce statewide GHG emissions 

to 1990 levels by the year 2020.

3.3.2 Proposed Action Alternative

Implementation of the Proposed Action Alternative would result in air emissions associated with 

construction of the parking structure and SCI/CLC building, and associated with operation of the facility.

Air quality impacts from proposed construction activities would occur from (1) combustion emissions 

due to the use of fossil fuel-powered equipment and (2) fugitive dust emissions (PM10) during 

construction activities including demolition of existing pavement to accommodate the parking structure 

and SCI/CLC building. 

Based on the project description, construction activities were assumed to commence in the latter half of 

2013 and continue through 2018. Construction of the Phase 1 parking structure (400 spaces) would 

occur first, with construction of the Phase 2 parking structure (800 spaces) occurring subsequently, and 

construction of the SCI/CLC building occurring after completion of the Phase 2 parking structure. 

During construction, best management practices to control emissions of fugitive dust would be 

implemented to reduce potential impacts from earthmoving activities. Best management practices 

include the following:

• Water active grading sites a minimum of 3 times daily

• Cover loads or use a minimum of 2 feet of freeboard in trucks transporting loose construction 

materials

• Reduce speeds on unpaved surfaces to 15 mph or less

• Promptly remove spilled or tracked dirt or other materials from paved streets at construction 

site entrances

Construction emissions were estimated using the CalEEMod Model, Version 2011.1.1 (ENVIRON 2011).

The CalEEMod Model is the latest version of the air quality model developed for land use planning 

projects by the South Coast Air Quality Management District (SCAQMD) for projects within the state of 

California. The CalEEMod Model uses emission factors from the CARB’s EMFAC2007 Model for on-road 

vehicles and the CARB’s OFFROAD2007 Model for off-road construction equipment. Table 3 presents a 

summary of the estimated annual construction emission by year of construction in comparison with the 

de minimis levels for the SDAB. 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 20 June 19, 2013

Table 3. Proposed Action construction emissions

Year of Construction Emissions, tons/year

VOCs NOx CO SOx PM10 PM2.5

2013 0.47 3.36 2.25 0.00 0.30 0.23

2014 1.28 8.02 5.76 0.01 0.74 0.54

2015 1.29 6.91 5.85 0.01 0.71 0.44

2016 0.74 5.30 4.00 0.01 0.49 0.34

2017 0.59 3.91 3.55 0.01 0.32 0.22

2018 1.73 4.74 4.36 0.01 0.41 0.31

De Minimis Emission 

Thresholds

100 100 100 N/A N/A N/A

Above de minimis? No No No N/A N/A N/A

Operational emissions associated with operation of the SCI/CLC building were also calculated using the 

CalEEMod Model. The CalEEMod Model includes calculations of emissions from area sources such as 

landscaping and consumer products use, emissions from energy use, and vehicular emissions. Table 4 

presents a summary of the emissions calculated for operation of the Proposed Action in comparison 

with the de minimis thresholds. 

Table 4. Proposed Action Alternative operational emissions

Source Emissions, tons/year

VOCs NOx CO SOx PM10 PM2.5

Area Sources 0.66 0.00 0.00 0.00 0.00 0.00

Energy Use 0.05 0.41 0.34 0.00 0.03 0.03

Mobile Sources 1.64 3.34 15.65 0.03 0.90 0.20

Total 2.35 3.75 15.99 0.03 0.93 0.23

De Minimis Emission 

Thresholds

100 100 100 N/A N/A N/A

Above de minimis? No No No N/A N/A N/A

As shown in Tables 3 and 4, the emissions for both construction and operation are below the de minimis

levels. The Proposed Action Alternative would therefore not be subject to the requirements of the 

General Conformity Rule.

The Proposed Action Alternative would result in emissions of GHGs from construction and operations.

Based on the CalEEMod Model, emissions of GHGs from construction would total 4,161 metric tons of 

CO2e over the duration of the construction activities. Emissions of GHGs from operation would total 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 21 June 19, 2013

3,449 metric tons of CO2e annually. Currently, there are no formally adopted or published CAA 

thresholds for GHG emissions. 

On February 18, 2010, the U.S. Council on Environmental Quality (CEQ) released draft guidance on 

addressing climate change in NEPA documents. The draft guidance, which has been issued for public 

review and comment, recommends quantification of GHG emissions, and proposes a threshold of 

25,000 metric tons of carbon dioxide equivalent (CO2e) emissions. The CEQ indicates that use of 25,000 

metric tons of CO2e emissions as a reference point would provide federal agencies with a useful 

indicator, rather than an absolute standard of significance, for agencies to provide action-specific 

evaluation of GHG emissions and disclosure of potential impacts. The GHG emissions associated with the 

Proposed Action are well below this proposed CEQ threshold. Construction of the new facilities will 

cause a minor, temporary impact to local air quality.

3.3.3 No Action Alternative

Under the No Action Alternative, the parking structures and SCI/CLC building would not be constructed.

Implementation of the No Action Alternative would result in no change to the ambient air quality or 

climate. Construction and operations associated with the Proposed Action Alternative would not occur. 

Ambient air quality would remain unchanged when compared to existing conditions.

3.4 Hydrology and Water Quality

Section 402(p) of the federal Clean Water Act (CWA), as amended, requires National Pollutant Discharge 

Elimination System (NPDES) permits for storm discharges to waters of the United States. The USEPA 

promulgated 40 CFR Part 122.26 which establishes requirements for storm water discharges under the 

NPDES program. The California State Water Resources Control Board (SWRCB) maintains the NPDES 

general permit for storm water discharges from small municipal separate storm sewer systems (MS4s) 

under Water Quality Order No. 2003-0005-DWQ, NPDES General Permit CAS000004 (SWRCB 2003). This 

permit is set to expire June 30, 2013 and will be replaced by Water Quality Order No. 2013-001 DWQ 

effective July 1, 2013. The VAMC San Diego campus is listed as a “non-traditional” MS4 and will be

designated to seek coverage under this new SWRCB general permit. 

The VA Medical Center is located within the Rose Creek watershed which drains into San Diego’s Mission 

Bay (KTU+A 2005). Runoff from this watershed is managed according to the City’s Mission Bay and La 

Jolla Watershed Urban Runoff Management Plan (City of San Diego 2008a, 2008b). Rose Creek is 

currently listed as an “impaired waterbody” on the State’s CWA Section 303(d) List of Water Quality 

Limited Segments for the following pollutants: lead, selenium, toxicity, and eutrophic conditions 

(RWQCB-SDR 2008). Total Maximum Daily Load (TMDL) values for these pollutants are not yet 

established for Rose Creek.

Section 438 of the Energy Independence and Security Act of 2007 (EISA) requires sponsors of 

development or redevelopment projects involving federal facilities to use site planning, design, 

construction, and maintenance strategies to maintain or restore, to the maximum extent technically 

feasible, the predevelopment hydrology of the property with regard to temperature, rate, volume, and
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 22 June 19, 2013

duration of flow (USEPA 2009). The design of the new VAMC facilities provides an opportunity for the VA 

to improve storm runoff through a combination of rain gardens, infiltration planters, porous pavements, 

green roofs, rainwater harvesting, and other sustainable design features.

Any discharges associated with hydrostatic testing or dewatering, and construction will follow the terms 

of San Diego Regional Water Quality Control Board Orders R9-2002-0020 and R9-2001-0096 (RWQCBSDR 2002 and 2001). The VA construction contractor will seek coverage under the 2009-0009-DWQ 

Construction General Permit prior to construction and will comply with the permit requirements 

(SWRCB 2010). 

3.4.1 Existing Condition

The Medical Center currently has underground storm drainage piping constructed across the campus to 

convey drainage from the existing buildings and the open landscape and parking lot areas to points of 

drainage discharge off-site. The existing drainage patterns, following the terrain of the site, divide the 

medical campus into three distinct drainage areas over the approximately 33-acre site. The total 

includes approximately six acres of parking lot area leased from UCSD (Halladay & Mim Mack 2011; 

gkkworks 2010b).

The largest drainage area, approximately 13 acres, conveys drainage from the northerly portion of the 

site, from Gilman Drive south to the Medical Campus Drive. This drainage area conveys 75 percent of 

the Building No. 1 site coverage, and all of Building Nos. 2, 11 and 13 (figure 4). This drainage area will 

completely encompass the new SCI/CLC building footprint. All storm drain runoff from this drainage area 

is eventually intercepted by underground drain pipes and carried toward the east where existing 12-inch

and 18-inch storm drain lines converge to outlet the drainage into the Caltrans right-of-way for 

Interstate 5 (gkkworks 2010b).

A smaller drainage area to the west, approximately three acres, conveys drainage westerly toward Via 

La Jolla Drive. This area includes storm runoff from the southwest quarter of Building No. 1, and Medical 

Drive descending to Via La Jolla Drive. Drainage in this tributary area is also intercepted by roof drains 

and onsite basins and conveyed to an offsite storm drain pipe in Via La Jolla Drive. Across the southern 

side of the campus and including a portion of the UCSD property, the third drainage area directs 

drainage southerly to the south Medical Center boundary line. Runoff from this 9-acre area is partially 

intercepted by a 12-inch storm drain line in the central parking lot which drains to the south property

line and outlets into the ravine south of the campus. The proposed construction of the new parking 

structure is entirely within this third drainage area (gkkworks 2010b).

The water quality of stormwater runoff from the southern parking lot is not known. There is evidence of 

historic soil erosion in the ravine below the outfall of the drain line, which is on UCSD property. The 

current configuration incorporates no specific stormwater "best management practices” other than 

adequate sizing and distribution of the drainage system.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 23 June 19, 2013

3.4.2 Proposed Action Alternative

Implementation of the Proposed Action Alternative, to include construction of both the new SCI/CLC 

buildings and the parking structures, will not alter the overall drainage patterns of the campus. In fact, 

because the individual drainage areas will remain unchanged and with the addition of new landscape 

areas the incorporation of “green roof” construction, and the planned implementation of rainfall 

harvesting of storm runoff in the parking structures, the total storm drain runoff is not expected to 

change significantly (gkkworks 2010b). The establishment of these new water features will ensure the 

project complies with Section 438 of the EISA. 

Both retention and detention of rainfall runoff are possible mitigation measures for storm runoff 

volumes and for water cleansing. Rainfall harvesting is planned for the areas of the parking structure 

and where possible, infiltration will be implemented as a means of reducing storm water runoff. Existing

8-inch and 12-inch storm drain lines lie below the future footprint of the SCI/CLC building. These lines 

will be removed and replaced with new lines to continue to convey storm water runoff easterly toward 

the existing drainage outlet for the northerly drainage area. New storm drain lines will be installed in the 

south portion of the site to convey overflow of the parking garage and surface flow from the parking lots 

to points of outlet into the ravine south of the Medical Center (gkkworks 2010b). A hydrologic and 

hydraulic analysis found that construction of the new SCI building and parking structure will not affect 

the existing drainage patterns and will have a negligible effect on storm drain runoff (Halliday & Mim 

Mack 2011).

During construction, surface vegetation will be removed and soils exposed to potential erosion. Any 

potential sedimentation would be short-term and would not likely cause adverse impacts to 

downstream water quality. VA CFM construction specifications, Temporary Environmental Controls (01 

57 19) and the mitigation measures highlighted in Section 5 will be followed to mitigate any potential 

contamination of surface waters by the construction activity. Consequently, the overall potential 

negative effect of the project on water resources is considered minor, mitigated to negligible.

3.4.3 No Action Alternative

Implementation of the No Action alternative would result in no change to the hydrology and water 

quality at the project sites. Construction of the Proposed Action would not occur and no reduction in 

water runoff amount or contaminants (from open parking areas) would be realized. 

3.5 Noise

Noise, or unwanted sound, was originally managed at the federal level by the Noise Control Act (NCA) of 

1972, which was administered by the USEPA. Under this Act, Congress tasked the USEPA with 

determining the extent and effects of different qualities and quantities of noise and defining acceptable 

levels of noise toward public health and safety. Since 1982, the responsibility of noise abatement and 

control has been delegated to state and local governments, but the noise levels and exposure 

recommendations developed by the USEPA under the Noise Control Act are still relevant (HDR 2009). 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 24 June 19, 2013

Noise is generally defined as unwanted sound. Sound is most commonly measured in decibels (dB) on 

the A-weighted scale, which is the scale most similar to the range of sounds that the human ear can 

hear. The Day-Night Average Sound Level (DNL) is an average measure of sound. The DNL descriptor is 

accepted by federal agencies as a standard for estimating sound impacts and establishing guidelines for 

compatible land uses. USEPA guidelines, and those of many other federal agencies, state that outdoor 

sound levels in excess of 55 decibels DNL are “normally unacceptable” for noise-sensitive land uses such 

as residences, schools, or hospitals (HDR 2009). In San Diego, noise is regulated under the City of San 

Diego noise ordinances (City of San Diego 1973). 

3.5.1 Existing Condition

The VA Medical Center experiences similar noise and vibration conditions as the adjacent University of 

California, San Diego campus. In 2004, UCSD conducted a campus-wide noise analysis as part of its Long 

Range Development Plan FEIR (URS 2004). Several of the noise sampling sites were within 1,000 feet of 

the Medical Center buildings, including sites near La Jolla Village Drive to the south, Villa La Jolla Drive to 

the west, Gilman Drive to the north, and Interstate 5 to the east. 

Vehicle traffic on Interstate 5, nearby thoroughfares, and internal access roads was found to be the 

primary source of noise on the UCSD campus (URS 2004) and presumably on the VAMC campus.

Emergency power plants; heating, ventilation, and air conditioning (HVAC) systems; and parking 

structures were the next greatest source. The University campus, including the VAMC, is not within two

miles of a public airport but is about two miles west of Marine Corps Air Station Miramar. The VAMC 

area is subject to periodic overflights by commercial, general aviation, and military aircraft. However, 

the campus is not within the 60 dB Community Noise Equivalent Level (CNEL) contour of any airport and 

is not subject to aircraft noise in excess of the regulatory limit (URS 2004). Construction on and around 

the UCSD campus was found to generate noise audible at nearby noise-sensitive land uses. Construction 

noise levels vary depending on distance between the activity and receptors, and the type of equipment 

used, how it is operated, and how well the equipment is maintained (URS 2004). 

URS (2004) found that the estimated increase in traffic related to UCSD development would not 

significantly increase noise at existing campus facilities but could have a detrimental effect on any new 

facilities placed near traffic sources. If facilities need to be built near noise sources, architectural 

features should be used to mitigate the impact. The establishment of new stationary noise sources, such 

as HVAC systems and parking garages, could negatively impact nearby noise-sensitive receptors like 

residences, dormitories, and classrooms. These potential noise impacts can be mitigated by appropriate 

architectural and engineering design measures. URS (2004) also found that construction equipment

noise could be mitigated through standard construction contract management and noise control 

methods. 

The VAMC San Diego facility is adjacent to and partially surrounded by the UCSD campus, and is 

presumably affected by the same noise sources. Early analysis of the VAMC property indicated that 

traffic noise was unacceptably high along the eastern edge of the property nearest Interstate 5 (GLHN
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 25 June 19, 2013

2008), which, among other factors, resulted in the new SCI/CLC building being designed closer to the 

existing hospital tower.

3.5.2 Proposed Action Alternative

A key design criterion for the Proposed Action Alternative is the control of interior and exterior noise so 

as to enhance the healing environment. The acoustic features of the new buildings will create a longterm benefit to the residents and workers at the facility. Because there will only be a small percentage 

change in the Medical Center residents and workforce, no long-term increase in traffic-related noise is 

anticipated on the interior road network or parking areas.

Demolition, excavation, and construction activities will create a temporary, short-term increase in noise 

within the vicinity of the project. Ambient noise levels associated with construction activities at the site 

will be minimized by application of the mitigation measures highlighted in Section 5, including the VA 

CFM standard Temporary Environmental Controls specifications (MF04 Section 01 57 19), which limit 

the maximum permissible noise levels to 75 dB(A) at 50 feet from most earthmoving or material 

handling equipment (VA 2010e). The construction contract specifications will also limit the hours of 

operation for construction equipment in compliance with City of San Diego noise ordinances (City of San 

Diego 1973). The project would have a temporary, minor impact on local sound resources.

3.5.3 No Action Alternative

Implementation of the No Action alternative would result in no change to the noise levels on the 

Medical Center or nearby communities. VA Medical Center residents and staff would not benefit from 

the acoustical improvements designed into the new buildings.

3.6 Solid and Hazardous Wastes 

The California Department of Resources Recycling and Recovery (CalRecycle) administers programs 

formerly managed by the State’s Integrated Waste Management Board and Division of Recycling 

(CalRecycle 2010). CalRecycle oversees regulations and permit requirements related to solid waste 

disposal and management. The California Department of Toxic Substances Control (DTSC) implements 

California's hazardous waste management program and enforces the hazardous waste management

rules (DTSC 2010). Hazardous waste activities must comply with regulations found in Title 22 of the 

California Code of Regulation, as well as all applicable Federal regulations under 40 CFR 260-268, 273, 

and 279 and 29 CFR 1910.

3.6.1 Existing Condition

The VA/gkkworks design team reviewed the current and proposed solid and hazardous waste handling 

procedures and facilities at the Medical Center. The Medical Center does not incinerate its waste. 

General waste is collected and compacted at the existing loading dock, and is hauled as scheduled by 

the contract waste hauler. A separate specialized waste contractor is used to pick-up and process 

Regulated Medical Waste (RMW), sharps containers and hazardous waste, which must be treated prior 

to disposal in a sanitary landfill. These waste streams are staged for pick-up within the Building 18 Waste 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 26 June 19, 2013

Management Center (WMC) (figure 4). Recyclable waste is also staged at the Building 18 WMC, and is 

hauled to a recycling center by VA staff for processing (gkkworks 2010b). 

3.6.2 Proposed Action Alternative

Implementation of the Proposed Action Alternative in accordance with current VA sustainability goals 

and LEED design criteria will substantially reduce the amount of operational waste generated by the 

SCI/CLC functions of the Medical Center and increase the amount of material recycling, based on the 

LEED NC 2009 scorecard developed for the project (gkkworks 2010c). There will be a temporary, shortterm increase in the amount of solid waste and hazardous waste produced by construction of the new 

SCI/CLC building and the parking garage. Removal of existing structures, utilities, and asphalt parking 

surfaces would create additional solid waste. The use of VA sustainability and LEED guidelines in the 

building design will reduce the amount of waste material produced. The adverse impacts of any 

necessary waste production will be avoided, minimized, or mitigated by application of the VA CFM 

construction specifications, including Temporary Environmental Controls (01 57 19), and Construction 

Waste Management (Section 01 74 19), as well as other mitigation measures highlighted in Section 5. 

The construction contractor will also comply with San Diego Municipal Code regarding the Collection, 

Transportation and Disposal of Refuse and Solid Waste (City of San Diego 2007). The project will 

therefore have a net beneficial effect on long-term solid/hazardous waste management at the Medical 

Center.

3.6.3 No Action Alternative

Under the No Action Alternative, the VA Medical Center would continue its current operations and 

would generate the same types and quantities of hazardous and non-hazardous wastes. Wastes would 

continue to be collected and transported for off-site disposal or recycling in accordance with federal, 

state, and local regulations. No changes in existing waste streams or adverse effects would occur. 

3.7 Transportation and Parking

Transportation and parking are important aspects of the safe and efficient operation of the Medical 

Center. Ingress and egress to the public road system, and within the internal road and parking network, 

affect emergency response, security, facility maintenance, and the movement of patients, residents, 

staff, and visitors within the campus. Traffic is a potential source of noise and air pollution at the 

Medical Center. The VA sustainability guidelines and LEED criteria encourage the use of alternative 

transportation (e.g., bicycles, public transport) features in new building design and operation.

3.7.1 Existing Condition

AG&S (2009) conducted an initial traffic and parking assessment of the VA Medical Center and, among 

other things, found the following:

• Currently the hospital has an average daily traffic of close to 10,000 two way trips.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 27 June 19, 2013

• The existing number of parking spaces is estimated at 2,095 parking spaces in Zones 1 to 3 of the 

VAMC parking lot.

• The current parking demand exceeds the available parking spaces, particularly in Zone 1. 

• The existing parking demand at 85% level per current practice will require an additional 400 to 

600 parking spaces. 

• The VA Hospital is well served by existing transit service in the area, including the Metropolitan 

Transit System (MTS) and other public and private operated services. 

3.7.2 Proposed Action Alternative

Implementation of the Proposed Action Alternative, to included phased construction of the parking 

garage associated with the SCI/CLC building, will meet the Medical Center’s current transportation and 

parking needs as well as those associated with the likely increase in residents and staff (AG&S 2009). The 

increase in new trips to and from the Medical Center resulting from this action was found to be 

insignificant relative to the total number of existing trips (AG&S 2009). The Proposed Action Alternative 

incorporates a new traffic circulation pattern that will move traffic efficiently around the facility (see 

figure 11, above). The new route alignment, designated drop-off area for the SCI/CLC building, and 

multiple/separate entrances would improve accessibility to visitors and staff (gkkworks 2010c). 

The construction and demolition activities associated with the Proposed Action Alternative would result 

in short-term loss of parking and road access. To mitigate for the loss of parking during construction, the 

VA will lease a remote parking facility for administrative and clinical staff. A shuttle transport will be 

used to transport staff to campus. The remote parking facility will be approximately five miles from the 

VAMC campus, and will pick up/drop off passengers every 30 minutes between 6:00 AM and 6:00 PM.

Consequently, the project will have a minor negative impact on traffic and parking at the VAMC during 

construction.

3.7.3 No Action Alternative

Under the No Action Alternative, neither the new SCI/CLC building or the new parking structure would 

be constructed. The SCI functions would continue to use the seismically deficient Building 11 and 

parking would continue to be inadequate to meet current resident, visitor, and staffing needs. 

Consequently, the Medical Center’s mission needs would not be met by this alternative.

3.8 US Environmental Regulations

The VA NEPA Interim Guidance for Projects (VA 2010c) provides guidance on compliance with key 

environmental requirements and pertinent legal authorities under NEPA. Table 5 lists these key legal 

authorities and the project’s compliance status. The project is anticipated to comply with all applicable 

legal requirements.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 28 June 19, 2013

Table 5 Project compliance with federal legal authorities

FI Requires Further Investigation 

MR Mitigation Required, Non Compliance Anticipated

CA Compliance Anticipated

NA Not Applicable

CA Executive Order 12898 – Environmental Justice 

CA Executive Order 13423 ¬Strengthening Federal Environmental, Energy, and Transportation Management 

CA Executive Order 13514 – Federal Leadership in Environmental, Energy, and Economic Performance 

CA Executive Order 11988 – Floodplain Management 

CA Executive Order 11990 ¬Protection of Wetlands 

CA National Environmental Policy Act (NEPA) 

CA National Historic Preservation Act (NHPA) 

CA Clean Air Act (CAA) 

CA Safe Drinking Water Act (SDWA) 

CA Clean Water Act (CWA) 

CA Coastal Zone Management Act (CZMA) 

CA Energy Independence and Security Act of 2007 (EISA)

CA Endangered Species Act (ESA) 

CA Executive Order 13175 ¬Indian Tribes 

NA Farmland Protection Policy Act (FPPA) 

CA Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (past actions) 

CA Resource Conservation and Recovery Act (RCRA) (ongoing operations) 

CA Emergency Planning and Right to Know Act (EPCRA) 

NA Marine Mammal Protection Act (MMPA) 

CA Migratory Bird Treaty Act (MBTA) 

CA Native American Graves Protection and Repatriation Act (NAGPRA) 

CA Noise Control Act (NCA) 

CA Oil Pollution Act (OPA) 

CA Spill Prevention, Control and Countermeasure Plans (SPCC) 

CA Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) 

CA Federal Environmental Pesticide Act (FEPCA) 

NA Food Quality Protection Act (FQPA) 

NA Federal Food, Drug and Cosmetic Act (FFDCA) 

CA Safe Drinking Water Act (SDWA) 

CA Toxic Substances Control Act (TSCA) 

NA Wild and Scenic Rivers Act
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 29 June 19, 2013

3.9 Cumulative Impact

The Council on Environmental Quality defines a cumulative impact as that “impact on the environment 

which results from the incremental impact of the action when added to other past, present, and 

reasonably foreseeable future actions, regardless of what agency (federal or non-federal) or person 

undertakes such other actions. Cumulative impacts can result from individually minor but collectively 

significant actions taking place over a period of time” (40 CFR 1508.7). In accordance with NEPA and to 

the extent reasonable and practical, this EA considered the combined effect of the proposed action and 

other actions occurring or proposed in the project area. In assessing cumulative effects to the 

environment, this EA considers key factors such as the incremental effects on natural resources, effects 

on traffic and parking, and any growth-inducing effects of the proposed action. The analysis also 

considers changes to the area resulting from cumulative effects from projects planned in close proximity 

of the Medical Center campus.

The VA is considering further expanding the proposed parking garage from 1,200 spaces to 1,600 spaces. 

The additional 400 spaces would be added as part of a future project. This action is consistent with the 

current VAMC land use and will not contribute to significant change in the local environment. Assuming 

similar LEED building design criteria is used for the future project, this project will have a similar overall 

beneficial effect as the Proposed Action Alternative. The VA has also considered the installation of solar 

voltaic systems on the rooftops of existing and proposed buildings (Potomac-Hudson 2010). This future 

project would provide additional energy efficiency to the Medical Center while not significantly 

impacting environmental resources. 

The VA Medical Center San Diego is a built-up, urban medical facility, adjacent to a major university 

campus, and near to developed shopping and high-density residential areas. The Proposed Action is

consistent with the planned land use of the area and development of the University facilities, and does 

not contribute significantly to cumulative impacts in the area (UCSD 2004, Helix 2010, PBS&J 2004b).

Two other potential future projects near to the Medical Center is Caltrans’ proposed construction of a 

freeway overpass at Gilman Drive (Moffatt & Nichol 2013), and SANDAG’s optional construction of an 

at-grade trolley station at the Medical Center as part of the Mid-Coast Corridor Transit Project (USDT 

2013). Although these projects may have temporary cumulative impacts to local traffic flows and 

parking availability (if implemented concurrent with Medical Center construction), the long-term effect 

will be to improve traffic flows, reduce parking needs, and increase public transportation available to 

the Medical Center.

The Medical Center project will provide incremental improvements to the facility, including increased 

energy, water, and material use efficiencies (through LEED design features), enhancements to utilities 

and parking infrastructure, and a long-term increase in health and safety to Medical Center residents 

and staff. The primary potential negative impacts of this project will occur during building construction 

and renovation which will be short-term and largely mitigated by best management practices and other 

environmental controls specified in the construction contracts. No cultural, vegetative, or wildlife 

resources would be adversely affected. Estimated emissions generated by the Proposed Action would be 

de minimis and would not be regionally significant; therefore, the Proposed Action Alternative would 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 30 June 19, 2013

not contribute significantly to adverse cumulative effects to air quality. The implementation of the 

Proposed Action is anticipated to have an overall beneficial cumulative impact to the local environment.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 31 June 19, 2013

4 PUBLIC INVOLVEMENT

A Notice of Availability (NOA) will be published in the San Diego Union-Tribune or other local newspaper 

with wide-ranging circulation in the San Diego area. The notice will serve to inform the public that this 

EA is available for review and comment for a period of thirty days. The NOA will also be forwarded to 

applicable agencies and jurisdictions that may have an interest in the project, including the US Fish and 

Wildlife Service; California Coastal Commission; San Diego Air Pollution Control District; Regional Water 

Quality Control Board; University of California, San Diego; and City of San Diego. Paper copies of the EA 

will be available for review at the VAMC San Diego and the local public library; an electronic version of 

the document will be posted on a VA website. All public comments received will be addressed and 

included in the final EA. 

5 MITIGATION

The following mitigation measures would be implemented to avoid, reduce, and mitigate for potential 

environmental impacts caused by construction of the new SCI/CLC building and parking garage, and 

demolition of existing parking lot pavement. These are in addition to mitigation measures listed in the 

VA CFM MF04 construction specifications (VA 2010e).

Air Quality

• VA CFM MF04 specifications to mitigate construction and demolition impacts, SECTION 01 57 

19, E - Protection of Air Resources, shall be applied.

• Water active grading sites a minimum of 3 times daily.

• Cover loads or use a minimum of 2 feet of freeboard in trucks transporting loose construction 

materials.

• Reduce speeds on unpaved surfaces to 15 mph or less.

• Promptly remove spilled or tracked dirt or other materials from paved streets at construction 

site entrances.

• The construction contractor shall apply water every 4 hours to the area within 100 feet of a 

structure being demolished, to reduce vehicle trackout.

• A gravel apron, 25 feet long by road width, shall be used to reduce mud/dirt trackout from 

unpaved truck exit routes.

• Dust suppressants (e.g., polymer emulsion) shall be applied to disturbed areas upon completion 

of demolition.

• Water shall be applied to disturbed soils after demolition is completed or at the end of each day 

of cleanup.

• Demolition activities shall be prohibited when wind speeds exceed 25 mph.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 32 June 19, 2013

• A minimum soil moisture of 12 percent for earthmoving by use of a moveable sprinkler system 

or a water truck shall be required. Moisture content can be verified by lab sample or moisture 

probe.

• Ground cover in disturbed areas shall be replaced as quickly as possible.

Hydrology and Water Quality

• VA CFM MF04 specifications to mitigate construction impacts, SECTION 01 57 19, C - Protection 

of Water Resources, shall be applied.

• The project contractor shall preserve existing vegetation as feasible.

• Temporary erosion control measures shall be applied as required by the California Storm Water 

Quality Association (CASCA) Construction BMPs Manual, Permits, and associated permits.

• During the rainy season (October through April), additional erosion control BMPs (i.e. fiber rolls, 

straw bale barriers, gravel bag berms) shall be applied at regular intervals to mitigate any 

impacts resulting from storm-created runoff.

• Areas that are non-active shall be stabilized with vegetation, erosion control blankets and flood 

control (see following) within 14 days of cessation of construction activities.

• Erosion control measures shall be applied in concentrated flow paths. These measures may 

include all or some of the following: erosion control blankets, check dams, erosion control 

seeding, earthen dikes and drainage swales, velocity dissipation devices, slope drains, etc. as 

required during construction, particularly during the rainy season.

• Physical or vegetative erosion control BMPs (not simply standby BMP measures) shall be 

installed as soon as grading and/or excavation is completed for any portion of the site during the 

rainy and non-rainy season.

• Sufficient erosion control measures shall be maintained on site to allow implementation in 

conformance with Permit requirements as specifically listed in the Storm Water Pollution 

Prevention Plan (SWPPP). 

Noise

• VA CFM MF04 specifications to mitigate construction impacts: SECTION 01 57 19, F -Reduction 

of Noise, shall be applied.

• Muffled construction equipment shall be used wherever possible.

• The contractor shall ensure that each piece of operating equipment is in good working condition 

and that noise suppression features, such as engine mufflers and enclosures are working and 

fitted properly.

• The contractor shall locate noisy construction equipment as far as possible from residential 

areas.

• Construction hours shall be comply with the San Diego Municipal Code §59.5.0404 (Construction 

Noise) regarding days and times of day when construction noise is permitted.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 33 June 19, 2013

• If a sustained high-noise construction activity takes place within 100 feet from noise sensitive 

uses on campus, measures shall be taken to limit the amount of noise affecting the sensitive 

receptor. 

Solid and Hazardous Waste

• VA CFM MF04 specifications to mitigate construction impacts, SECTION 01 57 19, B - Protection 

of Land Resources and SECTION 01 74 19 – Construction Waste Management, shall be applied.

• The contractor shall comply with San Diego Municipal Code Article 6: Collection, Transportation 

and Disposal of Refuse and Solid Waste, and other pertinent regulations when disposing of

waste material.

• Demolition and construction inert materials, including vegetative matter, asphalt, concrete, and 

other recyclable materials shall be recycled to the extent feasible.

• Demolition materials that contain hazardous substances shall be disposed of at certified disposal 

facilities in strict compliance with all applicable regulations.

Transportation and Parking

• VA will lease a remote parking facility for administrative and clinical staff. A shuttle transport 

will be used to transport staff to campus. The remote parking facility will be approximately five 

miles from the VAMC campus, and will pick up/drop off passengers every 30 minutes between 

6:00 AM and 6:00 PM.

• A flag person shall be employed as needed to direct traffic when heavy construction vehicles 

enter the Medical Center campus from main access roads. 

• Construction trucks shall avoid travel on residential areas to access the Medical Center campus.

• Construction-related truck traffic shall be scheduled to avoid peak travel time on the I-5 and La 

Jolla Village Drive, as feasible.

• If major pedestrian or bicycle routes on the Medical Center campus are temporarily blocked by 

construction activities, alternate routes around construction areas shall be provided, to the 

extent feasible. These alternate routes shall be posted on campus for the duration of 

construction.

• If any bus stop or other transit facility on campus is obstructed by construction activity, the 

Medical Center, in cooperation with the transit service providers, shall temporarily relocate such 

transit facility on campus as appropriate.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 34 June 19, 2013

6 CONCLUSIONS

The proposed construction of the new Spinal Cord Injury and Community Living Center building, along 

with the construction of a new parking structure and upgrade of the existing Spinal Cord Injury building, 

is not expected to result in significant adverse impacts to the human environment. The improvements in 

energy and water use efficiencies, the enhancement of indoor environmental quality, improvements in 

construction and operational material and waste management (largely due to implementation of LEED 

design standards), and the creation of a more favorable healing environment for the residents will have 

a long-term beneficial effect on the residents, visitors, and workers in these new facilities. 

The major impact of the project will be the short-term and temporary adverse effects caused by the 

construction and demolition activities. The potential adverse impacts to air quality, water quality, noise, 

solid and hazardous wastes, and transportation and parking, will be largely avoided or minimized by 

strict adherence and monitoring of the VA’s MF04 construction standards for temporary environmental 

controls, demolition, and waste management, and application of standard construction Best 

Management Practices (as listed in Section 5, above). 

This EA concludes a Finding of No Significant Impact (FONSI) is appropriate, and that an Environmental 

Impact Statement (EIS) is not required
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 35 June 19, 2013

7 LIST OF PREPARERS

NEPA and Specialist Consultants:

GeomorphIS, LLC

• Bruce F. Goff, PhD (BS Renewable Natural Resources, MS Watershed Management, PhD 

Watershed Science), Principal NEPA Planner

• Eileen D. Goff, GISP (BS Anthropology, MS Geography), Principal Geographer/GIS Specialist

• Jimmy Elmore, Professional Land Surveyor

• Lee Ann Heathcote (BA Environmental Studies), Document Manager/Editor

ECORP Consultants

• Roger D. Mason, PhD, RPA, Director of Cultural Resources

Scientific Resources Associated

• Valorie Thompson, PhD, Chemical Engineering, Principal Air Quality Specialist

Persons Contacted: 

VA Construction and Facilities Management, Region West

• Larry Villaluna, Project Manager

• Nelson Cancio, Environmental Engineer

VA Office of Construction & Facilities Management

• Thomas W. Moran, PE, Environmental Engineer

• Kathleen Schamel, Historic Preservation Officer

VAMC San Diego Engineering

• John S. Norwood, Facility Planner

• Noel Quilang, Chief, Engineering Service

A/E Prime Contractor (gkkworks) 

• Alberto Nicolau, Architect, LEED AP, Project Manager

• Mahmoud Mehrabian, AIA, Design Principal
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 36 June 19, 2013

8 REFERENCES CITED

AG&S. 2009. Traffic and parking analysis, Veteran Affairs Hospital, San Diego, California (Draft). Prepared 

for Veteran Affairs Hospital by AG&S, Yorba Linda, CA. December 2009.

Brightworks. 2010. Sustainability & LEED Kick-Off (PowerPoint presentation). Prepared for the 

Department of Veteran Affairs, Office of Construction and Facilities Management. January 27, 2010.

California Environmental Protection Agency. 2006. Climate Action Team Report to Governor 

Schwarzenegger and the California Legislature. March 2006. Available at: 

http://www.climatechange.ca.gov/climate_action_team/reports/2006report/2006-04-

03_FINAL_CAT_REPORT.PDF (accessed 3/22/2012).

CalRecycle. 2010. California Department of Resources Recycling and Recovery (CalRecycle) website. 

Available at: http://www.calrecycle.ca.gov/ (accessed 11/30/2010).

City of San Diego. 2008a. The City of San Diego City Council certified the Final Program Environmental 

Impact Report (PEIR) for the Draft General Plan and adopted the update to the General Plan on March 

10, 2008. Please click on the following links to access the Final Certified PEIR. Project No. 104495. SCH 

No. 2006091032. Available at: http://www.sandiego.gov/planning/genplan/peir.shtml (accessed 

10/10/2010). 

City of San Diego. 2008b. Mission Bay and La Jolla watershed, urban runoff management plan. Storm 

Water Pollution Prevention Division, General Services Department, City of San Diego, March 2008.

City of San Diego. 2007. San Diego Municipal Code Chapter 6: Public Works and Property, Public 

Improvement and Assessment Proceedings (11-2007) Article 6: Collection, Transportation and Disposal 

of Refuse and Solid Waste Division 7: Recycling Ordinance. Available at: 

http://docs.sandiego.gov/municode/MuniCodeChapter06/Ch06Art06Division07.pdf (accessed 

3/22/2012).

City of San Diego. 1973. San Diego Municipal Code Chapter 5: Public Safety, Morals and Welfare (6-

2000) Article 9.5: Noise Abatement and Control (“Noise Abatement and Control” added 9–18–1973 by 

O–11122 N.S.). Available at: 

http://docs.sandiego.gov/municode/MuniCodeChapter05/Ch05Art9.5Division04.pdf (accessed 

3/22/2010).

DTSC. 2010. California Department of Toxic Substance Control website. Available at: 

http://www.dtsc.ca.gov/ (accessed 11/30/2010).

ECORP. 2009. Phase I archaeological survey, spinal cord injury and seismic deficiency, phase I design 

project, Veterans Affairs Medical Center, San Diego, City of San Diego, San Diego County, California. 

Prepared by ECORP Consulting, Inc. for GeomorphIS, LLC and gkkworks, San Diego, CA. November 2009.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 37 June 19, 2013

ENVIRON. 2011. California Emissions Estimator Model User’s Guide. Version 2011.1. Prepared by

ENVIRON International Corporation for South Coast Air Quality Management District. February 2011. 

Available at: http://www.aqmd.gov/caleemod/doc/UsersGuide.pdf (accessed 3/22/2012).

ESRI. 2010. ArcGIS.com Mapper. Estimated median household income. Available at: 

http://www.arcgis.com/home/webmap/viewer.html (accessed 10/19/2010). 

gkkworks. 2010a. Schematic design: S-1 Report, Seismic Deficiency-SCI and CLC, Project No. 664-401. 

Veteran Affairs Medical Center in San Diego, California. Prepared by gkkworks for the Department of 

Veteran Affairs, Office of Construction and Facilities Management, 5 Jan 2010.

gkkworks. 2010b. Schematic design: S-2 Report, Seismic Deficiency-SCI and CLC, Project No. 664-401. 

Veteran Affairs Medical Center in San Diego, California. Prepared by gkkworks for the Department of 

Veteran Affairs, Office of Construction and Facilities Management, 14 May 2010.

gkkworks. 2010c. Design Development: DD-1 Technical Presentation, Seismic Deficiency-SCI and CLC, 

Project No. 664-401. Veteran Affairs Medical Center in San Diego, California. Prepared by gkkworks for 

the Department of Veteran Affairs, Office of Construction and Facilities Management, 29 September 

2010.

GLHN. 2008. Constructability assessment, seismic deficiency. Project 664-401, VAMC San Diego, CA. 

Draft Report prepared by GLHN Architects & Engineers, Inc. for the VA Office of Facilities Construction & 

Management. July 31, 2008.

Halladay & Mim Mack. 2011. Hydrology & hydraulic report for Phase II: Part A – Parking Structure 

(Project No. 664-329); Phase II: Part B – SCI/CLC Building (Project No. 664-401), Veterans Administration 

Medical Center, San Diego, CA. Prepared for gkkworks by Halladay & Mim Mack, Inc. Corona, CA. 

January 28, 2011.

HDR. 2009. Environmental assessment for the polytrauma expansion and cares supported bed tower 

upgrades. James A. Haley Veterans Hospital, Tampa, Florida. Department of Veteran Affairs Project No. 

673-900. August 2009.

Helix. 2010. East campus bed tower project, draft tiered environmental impact report. SCH 2009081053. 

Prepared by Helix Environmental Planning, Inc. for the University of California, San Diego. April 2010.

Helix. 2004. Biological resources technical report, 2004 UCSD Long Range Development Plan Update. 

Prepared by Helix Environmental Planning, Inc. for UCSD Physical Planning. September 2004.

Intergovernmental Panel on Climate Change. 2007. Fourth Assessment Report: Climate Change 2007. 

Available at: www.ipcc.ch/publications_and_data/publications_and_data_reports.shtml (accessed 

3/22/2012). 

KTU+A. 2005. Rose Creek watershed opportunities assessment, draft. Prepared by KTU+A for San Diego 

Earthworks, with funding by the California Coastal Conservancy and County of San Diego. July 31, 2005.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 38 June 19, 2013

Moffatt & Nichol. 2013. Draft Structure Type Selection Report. Gilman Drive Overcrossing at I-5 (Br No. 

57-1084). District-County-Route: 11-SD-5. University of California, San Diego. Prepared for Caltrans by 

Mofffatt & Nichol, April 2013.

Ninyo and Moore. 2005. Geotechnical evaluation, proposed seismic retrofit, Veteran Affairs Medical 

Center, La Jolla, California. Prepared for Leo A. Daly Company by Ninyo & Moore, Geotechnical and 

Environmental Sciences Consultants, San Diego, California. Revised May 4, 2005. 

Ninyo and Moore. 2003. Geological technical study, University of California, San Diego, 2004 Long Range 

Development Plan, Environmental Impact Report. Prepared for PBS&J by Ninyo & Moore Geotechnical 

and Environmental Sciences Consultants, San Diego, California. Revised September 12, 2003.

Parsons. 2007. Site inspection report, former Camp Calvin B. Matthews, La Jolla, California. FUDS Project 

No. 09CA111001. September 2007. In Support of FUDS MMRP Site Inspections Project. Prepared by 

Parsons, Norcross, Georgia. Prepared for U.S. Army Corps of Engineers, Los Angeles District, Los Angeles, 

California. U.S. Army Corps of Engineers South Pacific Division Range Support Center. Contract No. 

W912DY-04-D-0005, Task Order 0009, Project No. 744653. Available at: 

http://www.envirostor.dtsc.ca.gov/regulators/deliverable_documents/2698453605/matthews_si.pdf; 

(accessed 6/11/2010).

PBS&J. 2004a. UCSD long range development plan, hydrology study. Prepared for University of 

California, San Diego by PBS&J, San Diego, California. May 2004.

PBS&J. 2004b. Final environmental impact report for the University of California, San Diego 2004 long 

range development plan. Sch. No. 2003081023. Prepared for the University of California, San Diego, La 

Jolla, California. Prepared by PBS&J. September 2004.

Potomac-Hudson. 2010. Environmental assessment of proposed installation and operation of 

photovoltaic (solar) systems, San Diego VA Medical Center., VA Healthcare System, San Diego, California. 

Prepared for the Department of Veteran Affairs, National Energy Business Center. Prepared by PotomacHudson Engineering, Inc., Bethesda, Maryland, 17 May 2010.

RWQCB-SDR. 2008. San Diego Region, Clean Water Act Section 305(b) Surface Water Quality Assessment 

and Section 303(d) List of Water Quality Limited Segments. 2008 Integrated report, all decisions. 

Regional Water Quality Control Board, San Diego Region. Available at:

http://www.waterboards.ca.gov/sandiego/water_issues/programs/303d_list/index.shtml (accessed 

10/30/2010). 

RWQCB-SDR. 2002. Order No. R9-2002-0020, NPDES No. CAG679001, General Waste Discharge 

Requirements for Discharges Of Hydrostatic Test Water and Potable Water to Surface Waters and Storm 

Drains or Other Conveyance Systems within the San Diego Region. California Regional Water Quality 

Control Board, San Diego Region. Available at: 

http://www.waterboards.ca.gov/sandiego/board_decisions/adopted_orders/2002/2002_0020.pdf

(accessed 3/22/2012).
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 39 June 19, 2013

RWQCB-SDR. 2001. Order No. 2001-96, NPDES No. CAG919002. General Waste Discharge Requirements 

for Groundwater Extraction Waste Discharges from Construction, Remediation, and Permanent 

Groundwater Extraction Projects to Surface Waters within the San Diego Region Except for San Diego 

Bay. California Regional Water Quality Control Board, San Diego Region. Available at: 

http://www.swrcb.ca.gov/sandiego/board_decisions/adopted_orders/2001/2001_0096.pdf (accessed 

3/22/2012).

SRA. 2012. Air quality analysis for Department of Veteran Affairs, Medical Center San Diego, SCI/CLC 

Project. Prepared by Scientific Resources Associated for GeomorphIS, LLC. VA Project Number: 664-401. 

March 2012.

SWRCB. 2010. National Pollutant Discharge Elimination System (NPDES), General Permit for Storm 

Water Discharges Associated with Construction and Land Disturbance Activities, ORDER NO. 2009-0009-

DWQ, NPDES No. CAS000002. California State Water Resources Control Board. Available at: 

http://www.waterboards.ca.gov/water_issues/programs/stormwater/constpermits.shtml (accessed 

3/22/2012).

SWRCB. 2003. Water Quality Order No. 2003-0005-DWQ, National Pollutant Discharge Elimination 

System (NPDES) General Permit No. CAS000004, Waste Discharge Requirements (WDRS) for Storm 

Water Discharges from Small Municipal Separate Storm Sewer Systems (General Permit). California 

State Water Resources Control Board (SWRCB). April 30, 2003. Available at: 

http://www.swrcb.ca.gov/water_issues/programs/stormwater/docs/final_ms4_permit.pdf (accessed 

11/30/2010).

UCSD. 2004. Long range development plan. University of California, San Diego, La Jolla, CA. Available at: 

http://physicalplanning.ucsd.edu/plans/lrdp.html (accessed 10/10/2010).

URS. 2004. Noise analysis report for the University of California, San Diego, 2004 long range 

development plan. Prepared for UCSD Physical Planning. May 24, 2004.

USACE. 1999. Defense environmental restoration program, formerly used defense sites, findings and 

determination of eligibility. University of California at San Diego (UCSD), Formerly Camp Matthews, La 

Jolla, California. Site No. J09CA111000. Findings of Fact. September 21, 1999. US Army Corps of 

Engineers, Los Angeles District. Available at: 

http://www.envirostor.dtsc.ca.gov/regulators/deliverable_documents/5631803214/CA1110E1_UCSDCamp_Matthews.pdf (accessed 10/10/2010).

USDT. 2013. Mid-Coast Corridor Transit Project. Draft Supplemental Environmental Impact Statement 

and Subsequent Environmental Impact Report, Volume 1. US Department of Transportation, Federal 

Transit Administration, and the San Diego Association of Governments (SANDAG). April 2013.

USEPA. 2010. Revisions to the General Conformity Regulations. Final Rule. March 24. EPA-HQ-OAR-2006-

0669; FRL-9131-7; RIN 2060-AH93. 

USEPA. 2009. Technical guidance on implementing the stormwater runoff requirements for federal 

projects under Section 438 of the Energy Independence and Security Act. US Environmental Protection 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 40 June 19, 2013

Agency, Office of Water (4503T), Washington, DC. EPA 841-B-09-001. December 2009. Available at: 

www.epa.gov/owow/nps/lid/section438 (accessed 11/29/2010).

VA. N.d. San Diego, California – spinal cord injury and seismic deficiency, phase 1 design. 2010 

Congressional Submission, pp. 2-47 to 2-49. Provided by VA CFM. No date.

VA. 2013. Visitor Guide. VA San Diego Healthcare System Available at: 

http://www.sandiego.va.gov/docs/vicinitymap.pdf (accessed 6/15/2013).

VA. 2010a. Volume 4 of the Department of Veterans Affairs FY 2011 Budget Submission. February 2010.

VA. 2010b. Sustainable design & energy reduction manual. Department of Veterans Affairs, Office of 

Construction & Facilities Management. April 2010.

VA. 2010c. NEPA interim guidance for projects. Office of Construction and Facilities Management 

(OOCFM), Washington, DC. PG-18-17 (rev.). September 30, 2010.

VA. 2010d. VA San Diego Healthcare System website. Available at: 

http://www2.va.gov/directory/guide/facility.asp?id=119 (accessed 10/10/2010).

VA. 2010e. Department of Veteran Affairs, Office of Construction and Facilities Management. TIL - 

Master Construction Specifications. Available at: http://www.cfm.va.gov/til/spec.asp (accessed 

10/19/2010).

VA. 1998. Environmental compliance manual. Office of Facilities Management. Prepared by the 

Landscape Architect Professional Group, August 1995, Updated March 1998 & July 1998. 
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 41 June 19, 2013

9 LIST OF ACRONYMS AND ABBREVIATIONS

Term Definition

BMPs Best Management Practices

CAA Clean Air Act (federal)

CAAQS California Ambient Air Quality Standards (state)

CalRecycle California Department of Resources Recycling and Recovery 

Caltrans California Department of Transportation

CARB California Air Resources Board

CASCA California Storm Water Quality Association

CEQ Council on Environmental Quality (federal)

CEQA California Environmental Quality Act (state)

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFM VA Office of Construction and Facilities Management

CFR Code of Federal Regulations

CH4 methane

CLC Community Living Center

CNEL Community Noise Equivalent Level

CO carbon monoxide

CO2 carbon dioxide

CO2e carbon dioxide equivalent

CWA Clean Water Act (federal)

CZMA Coastal Zone Management Act

dB(A) decibel, A-weighting. A frequency weighting that relates to the response of the 

human ear

DNL Day-Night Average Sound Level

DTSC California Department of Toxic Substances Control

EA Environmental Assessment

EIS Environmental Impact Statement

EISA Energy Independence and Security Act

EO Executive Order (federal)

EPCRA Emergency Planning and Right to Know Act

ESA Endangered Species Act (federal)

ESRI Environmental Systems Research Institute

FEIR Final Environmental Impact Report (CEQA)

FFDCA Federal Food, Drug and Cosmetic Act

FEPCA Federal Environmental Pesticide Act

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FONSI Finding of No Significant Impact

FPPA Farmland Protection Policy Act

FQPA Food Quality Protection Act

GEMS Green Environmental Management System (VA facility)

GHG greenhouse gas

GSF gross square feet

GWP global warming potential

HVAC heating, ventilation, and air conditioning
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego 42 June 19, 2013

Term Definition

LEED Leadership in Energy and Environmental Design

LTC Long Term Care

MBTA Migratory Bird Treaty Act

MMPA Marine Mammal Protection Act

MS4 Municipal separate storm sewer systems

MTS Metropolitan Transit System

NAAQS National Ambient Air Quality Standards (federal)

NAGPRA Native American Graves Protection and Repatriation Act

NCA Noise Control Act (federal)

NEPA National Environmental Policy Act (federal)

NHPA National Historic Preservation Act (federal)

NOx nitrogen oxide

NO2 nitrous oxide

NPDES National Pollution Discharge Elimination System (federal)

NRHP National Register of Historic Places

NSF net square feet

O3 ozone

OPA Oil Pollution Act

PM10 particulate matter less than or equal to 10 micrometers in size

PM2.5 particulate matter less than or equal to 2.5 micrometers in size

ppm parts per million

RCRA Resource Conservation and Recovery Act

RMW regulated medical waste

ROI region of influence

SANDAG San Diego Association of Governments

SCI Spinal Cord Injury

SCAQMD South Coast Air Quality Management District

SDAB San Diego Air Basin

SDAPCD San Diego Air Pollution Control District

SDWA Safe Drinking Water Act

SHPO State Historic Preservation Officer (California)

SIP California State Implementation Plan

SO2 sulfur dioxide

SPCC Spill Prevention, Control and Countermeasure Plans

SWPPP Storm Water Pollution Prevention Plan

SWRCB California State Water Resources Control Board

TMDL Total Maximum Daily Load

TSCA Toxic Substances Control Act

UCSD University of California, San Diego

USEPA United States Environmental Protection Agency

USFWS US Fish and Wildlife Service

VA Department of Veterans Affairs

VAMC Veterans Affairs Medical Center

VOC volatile organic compounds

WMC waste management center
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego A-1 June 19, 2013

Appendix A Native American Tribes Correspondence

Correspondence with Native American Tribes is included in the accompanying report:

ECORP. 2009. Phase I archaeological survey, spinal cord injury and seismic deficiency, phase I design 

project, Veterans Affairs Medical Center, San Diego, City of San Diego, San Diego County, California. 

Prepared by ECORP Consulting, Inc. for GeomorphIS, LLC and gkkworks, San Diego, CA. November 2009.
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego B-1 June 19, 2013

Appendix B Agency Correspondence
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego B-2 June 19, 2013
Draft Environmental Assessment

Seismic Deficiency - SCI / CLC Project

VA Project No.: 664-401

VA Medical Center San Diego C-1 June 19, 2013

Appendix C List of Environmental Permits / Modifications 

Required

Order No. R9-2002-0020, NPDES No. CAG679001, General Waste Discharge Requirements for Discharges 

Of Hydrostatic Test Water and Potable Water to Surface Waters and Storm Drains or Other Conveyance 

Systems within the San Diego Region. California Regional Water Quality Control Board, San Diego 

Region. Available at: 

http://www.waterboards.ca.gov/sandiego/board_decisions/adopted_orders/2002/2002_0020.pdf

(accessed 3/22/2012).

Order No. 2001-96, NPDES No. CAG919002. General Waste Discharge Requirements for Groundwater 

Extraction Waste Discharges from Construction, Remediation, and Permanent Groundwater Extraction 

Projects to Surface Waters within the San Diego Region Except for San Diego Bay. California Regional 

Water Quality Control Board, San Diego Region. Available at: 

http://www.swrcb.ca.gov/sandiego/board_decisions/adopted_orders/2001/2001_0096.pdf (accessed 

3/22/2012).

National Pollutant Discharge Elimination System (NPDES), General Permit for Storm Water Discharges 

Associated with Construction and Land Disturbance Activities, ORDER NO. 2009-0009-DWQ, NPDES No. 

CAS000002. California State Water Resources Control Board. Available at: 

http://www.waterboards.ca.gov/water_issues/programs/stormwater/constpermits.shtml (accessed 

3/22/2012).

Water Quality Order No. 2003-0005-DWQ, National Pollutant Discharge Elimination System (NPDES) 

General Permit No. CAS000004, Waste Discharge Requirements (WDRS) for Storm Water Discharges 

from Small Municipal Separate Storm Sewer Systems (General Permit). California State Water Resources 

Control Board (SWRCB). April 30, 2003. Available at: 

http://www.swrcb.ca.gov/water_issues/programs/stormwater/docs/final_ms4_permit.pdf (accessed 

11/30/2010).